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:
- Nano Inc. safety teams were trained and rehearsed to work with public agencies to control and prevent further nanomaterial dispersion resulting from transportation accidents;
- Both company and public employees wore hazmat suits and eye protection and carried closed circuit oxygen systems to prevent inhalation and exposure to nanomaterials as they applied foam to control wind-blown dispersion and then began to clean up the nanomaterials while preventing them from entering into the sewage system;
- Emergency medical technicians were advised how to treat employees, passersby or area residents for signs of toxicity, such as irritation to the skin or eyes and/or difficulty breathing;
- Hospitals had been informed about the nanomaterial hazards and were prepared both to treat cases of acute toxicity and to monitor for longer-term sensitivities to the eyes, respiratory system and skin;
- Persons in schools, residence and businesses were advised to remain in place and close their air circulation systems until public authorities had advised parents when they could pick up their children from school and when persons could leave from nearby businesses and residences.
- Nano Inc. had set up a hotline, 1-800-ALL-SAFE to respond to questions from employees and public officials. Nano Inc. had advised public authorities to set up a hotline to respond to public and press queries about the accident, its possible consequences for human, animal and environmental health, and the cleanup that is now underway.
- Nano Inc. will continue to brief employees and public officials about the accident and the cleanup. The next briefing will be at 6 p.m.
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:
- “Mr. Mayor, we believe that the citizens of Dayville are safe and that our accident and liability insurance and that of ABC ENM Trucking will be sufficient to cover all cleanup costs related to this regrettable accident. Nano Inc. is a good corporate citizen that will work with you, your city council and state and federal officials to minimize any harm from this accident.”
- “Mam, as long as nearby residents, businesses and parents of children at Dayville Elementary follow the orders and instructions of public authorities, Nano Inc. does not believe that there will be cases of acute toxicity. However, Nano Inc. will be working with public authorities and Dayville medical clinics and hospitals to treat cases of persons who may develop long-term chemical sensitivities that may be related to the consequences of this regrettable accident.”
- “Bunky, we are surprised and sorry to learn that the Nano Inc. loading dock does not have sufficient hazmat suits, eye protection and respiratory protection for you and your co-workers. But as you know, these protections only work if employees follow instructions for the proper use of this equipment, and shower thoroughly before putting on their non-work clothes to ensure that there are no nanomaterial residues on those clothes or shoes. Nano Inc. will ask for an Occupational Health and Safety Administration (OSHA) safety audit of all its facilities and will implement all OSHA recommendations to protect our employees.”
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.