July 28, 2021
by Caroline Miller, senior regulatory specialist, UL Supply Chain
The National Institute for Occupational Safety and Health (NIOSH) released a draft of Approaches to Developing Occupational Exposure Limits or Bands for Engineered Nanomaterials: User Guide and Technical Report on July 13, 2021. NIOSH is requesting comments on the two-part draft report by Sept. 13, 2021. The draft report is intended to offer methods of assessing scientific data for developing occupational exposure limits or bands for engineered nanomaterials.
Currently, there are thousands of chemicals, including engineered nanomaterials, that do not have occupational exposure limits (OELs) established. Assigning OELs to every chemical or material that exists today would not be practical. It is also not cost-effective to assign OELs to research and development materials that may never be produced in a large quantity.
Although OELs may not exist, employees’ exposures to these materials must be considered and appropriate protective measures must be implemented. Where OELs do not currently exist, chemicals can be placed into categories or Occupational Exposure Bands (OEBs) based upon actual or estimated health effects. Currently, there are five OEBs (A through E), with the lowest toxicity in Band A and the highest toxicity in Band E. The OEBs would then be used to target controls for protecting workers’ health. The proposal includes the addition of Band F to address the safe use of engineered nanomaterials.
The draft report comprises two parts:
- User guide
- Full technical report and appendixes
NIOSH is specifically looking for feedback on the following:
- Does the draft document adequately describe the process for gathering and evaluating the information available on OELs or bands for engineered nanomaterials?
- Does the draft document adequately describe the development of a framework for categorizing engineered nanomaterials by potential occupational health hazards from inhalation exposure?
- Are the clustering and classification modeling methodologies reasonable for the data?
- Is a revision to current occupational exposure banding guidance needed to incorporate a Band F?
- How useful and practical is the approach described in both the user guide and full technical report for deriving categorical occupational exposure limits, and what are the opportunities for improvement?
- Are the current searches and collection of scientific data sufficient, and are there additional opportunities for obtaining data that were not included?
- Would the methods used in the report also be appropriate for a future comprehensive dataset of experimental, toxicological and physicochemical information for engineered nanomaterials?
Recommended action items
- Assess your chemical, including nanomaterials, inventory to determine which chemicals employees are exposed to that do not have OELs.
- Review the draft NIOSH technical report and assess if the approaches NIOSH is proposing will assist in assigning those nanomaterials without OELs into OEBs.
- Provide feedback to NIOSH on the draft technical report by Sept. 13, 2021.
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