Posted July 28, 2016 by Dr. Steve Suppan
This imaginary message from a truck driver hauling 15 tons of a nano-copper (Cu) and nano-silicon (Si) powder could one day be the start of a very real accident. To think through the scientific and practical aspects of accident response preparation and intervention, U.S. and European participants, mostly scientists at an early June workshop in Washington DC on the environmental, health and safety (EHS) effects of exposure to nanomaterials, were asked to advise risk managers about EHS risk factors resulting from this and one other fake nano-accident scenario. Four hours after the truck rollover, “Nano Inc.” risk managers had to explain to public officials, to their employees and to the media what they had done to protect an elementary school, residential high rises and a business district, all downwind from the accident site. Wind, with gusts of up to 20 miles an hour, was blowing atomic to molecular size nano-particles with laboratory-characterized EHS risks. I was one of two risk managers for the nano-CU scenario.
The myriad details of the mock accidents are at the “2016 US-EU Communities of Research nanoEHS Scrimmage” website. Key among the Scrimmage documents is a Material Safety Data Sheet (MSDS) for the fictitious, but very plausible, “Nano-Cu-cide,” an agricultural fungicide. MSDS are required to be posted in every workplace that handles hazard chemicals. It lists the composition, use, workplace labeling and hazards of the chemicals and the first aid measures to be taken for acute and immediate exposure to the chemicals. Brief advice to firefighters and environmental precautions are also included in the 10 page MSDS. The “Nano-Cu-cide” MSDS comprised a mix of EU and U.S. regulatory and workplace safety requirements, which scientists remarked on just how far apart nanomaterial EHS standards are in the U.S. and EU.
The U.S. co-chair of the nanoEHS Scrimmage, Professor Christine Ogilvie Hendren of the Center for the Environmental Implications of Nanotechnology, cautioned participants that the objective of the exercise was not to make real EHS policy recommendations or to propose real emergency management measures. Rather, the purpose of the Scrimmage was to focus scientific specialists on a systems approach to nanoEHS in a quasi-real time scenario. Converting their scientific knowledge into a Nano Inc. public information statement was done with more improvisation than a risk communication expert would have liked.
Nevertheless, a few of the salient points in the Nano Inc. statement about the fictitious accident to employees and public officials were to assure that:
These kind of actions could help to minimize harm in the event of a real accident. In the fake accident scenario, those who played the roles of the Mayor, the Concerned Mother, Bunky Ferguson, long-time employee in the loading dock, etc. had very relevant questions, for which the Nano Inc. Public Information Officer and the Nano Inc. scientists had less than definitive answers:
In a post-Scrimmage review, participants had many criticisms to make of the Nano Inc. statement and of the Scrimmage scenarios as a whole. A lawyer said that to better defend the company against lawsuits, the Nano Inc. lawyers would never have allowed the public information officer to speak at length or in detail. Environmental toxicity scientists said that no measures were proposed to prevent entry into the sewage system of liquid that could result from applying a foam to the powdered Nano-CU-cide. How would Nano Inc. prevent panic resulting from false information spread by social media?
My view, expressed to the workshop participants, was that the Scrimmage was a very useful exercise, if only because an emergency focuses the mind to perceive better the regulatory, risk assessment and emergency management shortcomings relevant to nanomaterials. The U.S. National Nanotechnology Coordinating Office and the EU’s Joint Research Committee are to be congratulated for supporting the Scrimmage.
Whether or not nanomaterial companies are carrying out this kind of exercise already with local and state public authorities, IATP hopes that future iterations of the Scrimmage will be part of the U.S. and EU public engagement on nanotechnology and nanomaterials. In a well-regulated industry, companies using nanomaterials would be required to demonstrate to public authorities their training and technical capacity to respond to a more realistic and complex version of the mock accident scenarios in the Scrimmage.