These findings corroborated a similar analysis of a subset of
the same MSDSs presented at an international conference sponsored by the EPA in October 2008.9 The earlier analysis also
noted that, of those MSDSs that recommended local exhaust
ventilation, 25 percent recommended a face velocity greater than
100 feet per minute, even though NIOSH has indicated that standard fume hoods operated at that rate tend to create too much
turbulence to fully contain nanoparticles, which when dry are
extraordinarily buoyant. 10 The earlier study also reported that
none of the MSDSs reported that nanoparticles pose a much
greater flammability risk. As the British Health and Safety Executive warned, “An increasing range of materials that are capable
of producing explosive dust clouds are being produced as
nanopowders.” 11
Given the incomplete state of toxicological
knowledge, a major ethical question must
be posed about what workers manufacturing these products should be told
about the risks they face.
Ethical Scenario
Marie, a certified industrial hygienist working for a large, international manufacturer of single-walled carbon nanotubes, ar-guably one of the most toxic nanomaterials in animal studies,
has just been assigned to run the company’s product stewardship
program. She is troubled that their MSDS for the single-walled
carbon nanotubes lists the OSHA PEL for synthetic graphite ( 15
mg/m3) even though NIOSH has stated that “the occupational
exposure limit for graphite should not be used to allow extensive
exposure to carbon nanotubes that appear far more toxic than
graphite.” 12 OSHA does not have specific requirements about
warning language for nanomaterials, so the company is not in
violation of 29 CFR 1910.1200. Given the worldwide economic
downturn, Marie is under strong pressure from management not
to take voluntary steps that will further depress sales. Discussions of plant closings have been circulating.
Questions
AIHA members are encouraged to debate the following questions
on the AIHA blog at www.aiha.org/weblog/aihablog:
• Is it unethical for Marie to not include stronger warning lan-
guage in the MSDS?
• How should the lack of definitive toxicological research be
handled in an MSDS?
• If Marie worked as a field IH in a branch office and was not
in charge of the program, what would she be ethically obligated to do?
If the firm sold carbon nanotubes in Europe too, where the
precautionary principle holds much stronger philosophical sway,
would it have bearing on her ethical duties?
BruceLippy,PhD,CIH,CSP,ispresidentofTheLippyGroup,LLCinBaltimore,
Md.HeisamemberoftheJointIndustrialHygieneEthicsEducationCommittee
andcanbereachedat(410) 916-0359orbruce@thelippygroup.com.
References
1. Schulte, P., C. Geraci, R. Zumwalde, M. Hoover, and
E. Kuempel: “Occupational Risk Management of Engineered Nanoparticles.” Journal of Occupational and
Environmental Hygiene 5:239 (2008).
2. Schulte, P., C. Geraci, R. Zumwalde, M. Hoover, and
E. Kuempel: “Occupational Risk Management of Engineered Nanoparticles.” Journal of Occupational and
Environmental Hygiene 5:240 (2008).
3. Nichols, N., G. V. Nichols, and P. A. Nichols: “
Professional Ethics: The importance of teaching ethics to future
professionals.” Professional Safety (July 2007).
4. Woodrow Wilson International Center for Scholars:
“New Nanotech Products Hitting the Market at the Rate
of 3-4 Per Week.” [Online] Available at www.nanotech-project.org/news (April 2008).
5. U.S. National Nanotechnology Initiative: “Frequently
Asked Questions.” [Online] Available at www.nano.gov/
html/res/ faqs.html (April 2008).
6. Lindberg, J. E. and M. M. Quinn: “A Survey of Environmental, Health and Safety Risk Management Information
Needs and Practices among Nanotechnology Firms in
the Massachusetts Region.” PEN Research Brief Num-
ber1. [Online] Available at www.nanotechproject.org/
publications/archive/a_survey_environmental_health_
safety/ (Dec. 2007).
7. Crawford, C. and L. Hodson: “Guidance for Preparing
Good MSDSs for Engineered Nanomaterials.” Poster
session presented at the annual meeting of the American
Industrial Hygiene Association, Toronto, Canada (June
2009).
8. Crawford, C. and L. Hodson: “Guidance for Preparing
Good MSDSs for Engineered Nanomaterials.” Poster
session presented at the annual meeting of the American
Industrial Hygiene Association, Toronto, Canada (June
2009).
9. Lippy, B. E.: “MSDSs Fail to Communicate the Hazards
of Nanotechnologies to Workers.” Paper presented at
the International Environmental Nanotechnology Conference, Chicago, Illinois (Oct. 2008).
10. Lippy, B. E.: “MSDSs Fail to Communicate the Hazards
of Nanotechnologies to Workers.” Paper presented at
the International Environmental Nanotechnology Conference, Chicago, Illinois (Oct. 2008).
11. Pritchard, D. K.: “Literature Review—Explosion Hazards
Associated with Nanopowders.” HSL/2004/12. Health
and Safety Lab. Health and Safety Executive. Harpur
Hill, Buxton, UK (2004).
12. Schulte, P., C. Geraci, R. Zumwalde, M. Hoover, and
E. Kuempel: “Occupational Risk Management of Engineered Nanoparticles.” Journal of Occupational and
Environmental Hygiene 5:244 (2008).
