ESH100.2.IH.16

Policy Area

ESH-Environment Safety & Health

Procedure Number

ESH100.2.IH.16

Procedure Title

Evaluate and Control Unbound Engineered Nanoscale Particles

Procedure Manager

HOOPER, LISA Z.

Status

Active

Subject Matter Expert

Christopher Ryan Mckean (Chris)
Daniel Kuey (Dan) (CA)

Applicability, Exceptions, and Consequences

This corporate procedure applies to all Members of the Workforce and visitors who participate in activities involving unbound engineered nanoscale particles (UNP) on Sandia-controlled premises.

The SNL Chemical Hygiene Plan (see ESH100.2.IH.4, Evaluate and Control Chemical Hazards) contains requirements for general chemical use in laboratories, including hazards and controls for all chemicals associated with UNP activities.

The requirements set forth in this procedure do not apply to:

Bound engineered nanoscale particles.
Biomolecules (e.g., proteins, nucleic acids, carbohydrates, etc.).
Nanoscale forms of radiological materials. The requirements of Department of Energy (DOE) Radiological Control Standards apply an equivalent level of control to protect workers, environment, and the public.
UNP for which a nanoscale-specific occupational exposure limit (OEL), national consensus, or regulatory standard has been established. These UNPs, whose hazards are well understood, will be managed in a manner consistent with the identified environmental and health risks and applicable regulations (see ESH100.2.IH.4, Evaluate and Control Chemical Hazards).
Nanoscale particles incidentally produced by human activities or natural processes, such as diesel engines and forest fires.

Exceptions to, or deviations from, this procedure must be approved through the Executive Policy Sponsor or Policy Area Manager, if delegated. Click here to view Contacts for Corporate Policies, Processes, and Procedures. See CG100.1.7, Request an Exception to a Policy, Process, or Procedure, for directions on how to obtain an exception to this procedure.

Granting or permitting exceptions or violations of policy, process, or procedure without authority, regardless of position or title, may be cause for disciplinary action up to and including termination of employment. Violating a policy, process, or procedure may be cause for disciplinary action up to and including termination of employment.

IMPORTANT NOTICE: A printed copy of this document may not be the document currently in effect. The official version is located on the Sandia National Laboratories Sandia Restricted Network (SRN).

Procedure Overview

This procedure details the requirements for working with unbound engineered nanoscale particles (UNP) on Sandia-controlled premises.

Procedure Requirements

Training

Activity	Responsible Individual	Required Action
Ensure Required Training Is Completed	Managers	Ensure that Members of the Workforce and visitors who participate in activities involving unbound engineered nanoscale particles (UNP) and their direct supervisors complete the required training identified in ESH100.2.IH.16 prior to performing the indicated work activity or fulfilling the indicated role. Note: See Sandia corporate procedure HR100.2.1, Identify and Complete Sandia Required Training for all Members of the Workforce.

Activity

Responsible Individual

Required Action

Ensure Required Training Is Completed

Managers

Ensure that Members of the Workforce and visitors who participate in activities involving unbound engineered nanoscale particles (UNP) and their direct supervisors complete the required training identified in ESH100.2.IH.16 prior to performing the indicated work activity or fulfilling the indicated role.

Note: See Sandia corporate procedure HR100.2.1, Identify and Complete Sandia Required Training for all Members of the Workforce.

Identification, Evaluation, and Control of UNP

Activity	Responsible Individual	Required Action
Identify, Evaluate, and Control UNP	Managers	Ensure that: All potential unbound engineered nanoscale particles (UNP) are identified, evaluated, and controlled. The division ES&H team industrial hygienist is contacted to perform an exposure assessment (industrial hygiene). The division ES&H team industrial hygienist is contacted to re-evaluate UNP activities when a change in workplace conditions indicates a new or increased hazard exits. Any control measures specified as a result of the exposure assessment are instituted and maintained.
Use Work Control Measures for UNP Activities	Managers	Ensure that: UNP activities are conducted in a ventilated full or partial enclosure designed to protect workers from airborne contaminants (e.g., an exhaust ventilation hood, glove box, glove bag, or Class II Type B2 biological safety cabinet). The use of high-efficiency particulate air (HEPA) exhaust filtration has been evaluated by the division ES&H team industrial hygienist. Ventilation systems with the potential to produce “blow back” (i.e., clean benches) are not used for UNP activities. The local exhaust ventilation (LEV) contact is consulted for any construction or purchase of new LEV systems or retrofitting of existing systems. See ESH100.2.IH.15, Control Hazards Using Local Exhaust Ventilation and High Efficiency Particulate Air Filters. Technical work documents (TWDs) are developed and implemented that specifically identify potential hazards and control measures at the task-level prior to the start of UNP work activities. TWDs meet the requirements outlined in ESH100.2.GEN.3, Develop and Use Technical Work Documents, and address the specific requirements of this section.
Use Work Control Measures for UNP Activities	Members of the Workforce and Visitors	At a minimum, use the following personal protective equipment (PPE) while handling UNP: Nitrile rubber or latex gloves for incidental contact. Safety glasses with side shields. Any additional PPE and other control measures identified as a result of the exposure assessment (industrial hygiene).

Warning Signs and Labels

Activity	Responsible Individual	Required Action
Post Warning Signs and Labels	Managers	Ensure that: The Unbound Engineered Nanoscale Particle (UNP) Caution Sign (ES&H Sign Generator–UNP Caution Sign), is visibly posted at the laboratory entrance, within a designated area of a laboratory, and/or on a containment device (e.g., chemical fume hood or glove box) to identify the area(s) in which potential unbound engineered nanoscale particles (UNP) may be used. PPE and administrative control requirements are indicated on the UNP Caution Sign (ES&H Sign Generator–UNP Caution Sign), prior to posting. Storage and transfer containers, as well as dedicated HEPA vacuums, are labeled with the UNP Caution Label (ES&H Sign Generator–UNP Caution Label), to indicate UNP contents. The UNP Caution Label (ES&H Sign Generator–UNP Caution Label), is placed on the specific drawer or bin in which UNP containers are located when individual UNP containers are too small to be individually labeled.

Activity

Responsible Individual

Required Action

Post Warning Signs and Labels

Managers

Ensure that:

The Unbound Engineered Nanoscale Particle (UNP) Caution Sign (ES&H Sign Generator–UNP Caution Sign), is visibly posted at the laboratory entrance, within a designated area of a laboratory, and/or on a containment device (e.g., chemical fume hood or glove box) to identify the area(s) in which potential unbound engineered nanoscale particles (UNP) may be used.
PPE and administrative control requirements are indicated on the UNP Caution Sign (ES&H Sign Generator–UNP Caution Sign), prior to posting.
Storage and transfer containers, as well as dedicated HEPA vacuums, are labeled with the UNP Caution Label (ES&H Sign Generator–UNP Caution Label), to indicate UNP contents.
The UNP Caution Label (ES&H Sign Generator–UNP Caution Label), is placed on the specific drawer or bin in which UNP containers are located when individual UNP containers are too small to be individually labeled.

Material Safety Data Sheets for UNP

Activity	Responsible Individual	Required Action
Obtain MSDSs for Importing, Manufacturing, or Distributing UNP	Managers	Ensure that: Material safety data sheets (MSDSs) reflecting hazards associated with the nanoscale form of the material are obtained for imported unbound engineered nanoscale particles (UNP), manufactured UNP, UNP distributed to offsite users (excluding test samples unless required by the tester), and UNP transferred to other on-site users (excluding UNP samples transferred for routine chemical, physical, or structural analysis). SF 2001-MSR, SNL Generated MSDS Request Form (Word file/Acrobat file), is used to request an MSDS for SNL-generated UNP.

Activity

Responsible Individual

Required Action

Obtain MSDSs for Importing, Manufacturing, or Distributing UNP

Managers

Ensure that:

Material safety data sheets (MSDSs) reflecting hazards associated with the nanoscale form of the material are obtained for imported unbound engineered nanoscale particles (UNP), manufactured UNP, UNP distributed to offsite users (excluding test samples unless required by the tester), and UNP transferred to other on-site users (excluding UNP samples transferred for routine chemical, physical, or structural analysis).
SF 2001-MSR, SNL Generated MSDS Request Form (Word file/Acrobat file), is used to request an MSDS for SNL-generated UNP.

Housekeeping

Activity	Responsible Individual	Required Action
Use Housekeeping and Work Practices	Managers, Members of the Workforce, and Visitors	Ensure that: Housekeeping and work practices are used to limit worker exposure to unbound engineered nanoscale particles (UNP) and associated hazards. Working surfaces (e.g., benches, glassware, apparatus, exhaust hoods, support equipment, etc.) are maintained as free as practicable of UNP contamination. Cleaning of horizontal UNP working surfaces is performed by wet wiping no less frequently than at the end of each shift.

Activity

Responsible Individual

Required Action

Use Housekeeping and Work Practices

Managers, Members of the Workforce, and Visitors

Ensure that:

Housekeeping and work practices are used to limit worker exposure to unbound engineered nanoscale particles (UNP) and associated hazards.
Working surfaces (e.g., benches, glassware, apparatus, exhaust hoods, support equipment, etc.) are maintained as free as practicable of UNP contamination.
Cleaning of horizontal UNP working surfaces is performed by wet wiping no less frequently than at the end of each shift.

Management of UNP Spills

Activity	Responsible Individual	Required Action
Clean Incidental UNP Spills	Managers	Ensure that Members of the Workforce and visitors who choose to clean incidental spills of unbound engineered nanoscale particles (UNP) are trained and equipped to do so in a safe manner by following the work instructions in this section, as a minimum.
Clean Incidental UNP Spills	Members of the Workforce and Visitors	Ensure that: Incidental spills of dry dispersible UNP, or otherwise dry UNP, are cleaned using the following techniques and considerations: Wet wiping. High-efficiency particulate air (HEPA) filter vacuuming using a dedicated, labeled, and approved vacuum. Potentially incompatible materials are not mixed in the vacuum or filters. HEPA filters are disposed of as UNP-bearing waste. Dry sweeping or compressed air is not used. Incidental spills of suspended UNP are cleaned using the following techniques and considerations: Standard spill response procedures based on the known hazards of the liquid portion of the spilled material. All spilled material, absorbents, neutralizers, and contaminated personal protective equipment (PPE) are disposed of as UNP-bearing waste.
Respond to Large Spills	Members of the Workforce and Visitors	Ensure that: In the case of a spill constituting an emergency (i.e., presenting an imminent human health concern, the environment is threatened, or if hazards are uncertain), call: 911 or 844-0911 (SNL/NM Cellular). 294-2222 (SNL/CA Cellular). The Non-Emergency Hotline 844-6515 (SNL/NM) or 294-3724 (SNL/CA) is used for spill response and cleanup not constituting an emergency. Entry into the area is restricted until spill response personnel arrive.

Medical Surveillance and Consultation

Activity	Responsible Individual	Required Action
Provide Medical Consultation/ Surveillance	Managers	Ensure that: Members of the Workforce who participate in activities involving unbound engineered nanoscale particles (UNP) are afforded the opportunity to participate in a voluntary medical surveillance program directed by SNL Health Services, which includes the following: A general physical exam. Pulmonary function test (PFT). General blood work. Other tests or exams as determined by medical services. Members of the Workforce who participate in activities involving UNP have the opportunity to receive a medical consultation when: They are concerned about working with UNP. They are injured, become ill, or develop signs and symptoms due to possible exposure to UNP. An event (e.g., spill, leak, explosion, or other occurrence) in the work area results in the likelihood of exposure to UNP. Exposure monitoring reveals exposure levels that routinely exceed the action level (or the OSHA PEL or ACGIH TLV in the absence of an action level) for OSHA-regulated substances requiring medical surveillance.

Activity

Responsible Individual

Required Action

Provide Medical Consultation/ Surveillance

Managers

Ensure that:

Members of the Workforce who participate in activities involving unbound engineered nanoscale particles (UNP) are afforded the opportunity to participate in a voluntary medical surveillance program directed by SNL Health Services, which includes the following:
- A general physical exam.
- Pulmonary function test (PFT).
- General blood work.
- Other tests or exams as determined by medical services.
Members of the Workforce who participate in activities involving UNP have the opportunity to receive a medical consultation when:
- They are concerned about working with UNP.
- They are injured, become ill, or develop signs and symptoms due to possible exposure to UNP.
- An event (e.g., spill, leak, explosion, or other occurrence) in the work area results in the likelihood of exposure to UNP.
- Exposure monitoring reveals exposure levels that routinely exceed the action level (or the OSHA PEL or ACGIH TLV in the absence of an action level) for OSHA-regulated substances requiring medical surveillance.

Unbound Engineered Nanoscale Particle (UNP) Worker Registry

Activity

Responsible Individual

Required Action

Maintain UNP Worker Registry

Managers

Ensure that:

The following information is recorded in the Chemical Information System (CIS) UNP Worker Registry for all UNP Workers at the time of initial assignment, prior to performing a new UNP activity, or performing work with a new UNP:
- Worker Name (e.g., John Doe).
- Job Title (e.g., Chemist, Technologist, etc.).
- A description of the UNP (e.g., Type: Carbon-based, Chemical Composition: Functionalized [PEG] single-walled carbon nanotubes).
- The location (building/room) in which the activity is located.

Implementing Tools

Form

SF-2001-MSR, SNL Generated MSDS Request Form (Word file/Acrobat file)

Guidance

Guidance to Evaluation and Control of UNP

Signs

ES&H Sign Generator–Unbound Engineered Nanoscale Particle Caution Sign
ES&H Sign Generator–Unbound Engineered Nanoscale Particle Caution Label

Tool

ES&H Sign Generator

Website

Nanotechnology Safety website
Chemical Information System (CIS) UNP Worker Registry module

Requirement Drivers (Prime Contract Baseline Directives)

DOE O 456.1

Additional Drivers

DOE N 456.1, The Safe Handling of Unbound Engineered Nanoparticles.
10 CFR 851, Worker Safety and Health Program.

Training Requirements

Responsible Individual	Required	Recommended
Members of the Workforce and visitors who participate in activities involving unbound engineered nanoscale particles (UNP) and their direct supervisors.	NANO101	N/A

Related Processes and Procedures

Process

ESH100.2, Analyze and Control Hazards.

Procedures

ESH100.2.ENV.15, Hazardous Waste Management at SNL/CA.
ESH100.2.ENV.22, Hazardous Waste Management at SNL.
ESH100.2.ENV.27, Maintain an Accurate Chemical and Biological Material Inventory.
ESH100.2.GEN.3, Develop and Use Technical Work Documents.
ESH100.2.IH.15, Control Hazards Using Local Exhaust Ventilation and High Efficiency Particulate Air Filters.
ESH100.2.IH.4, Evaluate and Control Chemical Hazards.
ESH100.2.IS.8, Assess Workplace Hazards and Provide and Maintain Personal Protective Equipment.
ESH100.3.3, Provide Health, Benefits, and Employee Services.

Required Reviews

Review Completion Dates
In Process

Change Summary

Date	Summary
03/29/2012	*Administrative* Modified Changed SF 2001-UNP to the ES&H Sign Generator-UNP Caution Sign throughout the document. Added Reference to "ES&H Sign Generator–Unbound Engineered Nanoscale Particle Caution Label." (Forms, Links & Tools, Signs) The ES&H Sign Generator was added as a tool. (Forms, Links & Tools)
02/03/2012	*Administrative* Modified Updated the links to “Guidance to Evaluation and Control of UNP (unbound engineered nanoscale particles)” and “Nanotechnology Safety website” in Forms, Links & Tools.
01/26/2012	*Administrative* Modified Corrected the dictionary term ID number for "Members of the Workforce" in the requirements table "Medical Surveillance and Consultation."
01/26/2012	*Substantive* Added Added a new requirements table "Unbound Engineered Nanoscale Particle (UNP) Worker Registry." This includes a requirement for managers to maintain records for UNP workers in Sandia’s Chemical Inventory System, UNP Worker Registry module. Reason for Change This updated procedure meets the increased worker tracking requirements associated with the Unbound Engineered Nanoscale Particle (UNP) Registry under DOE 0 456.1. Prior to adoption of DOE 0 456.1, the Worker Registry was limited to the name of individuals identified as UNP Workers. Under the new order, Sandia will have the additional requirement to track CR01(b)(2)-(4), including Job Title, a brief description of the UNP, and the area in which the activity is located. *Administrative* Deleted Removed DOE N 456.1 from Additional Drivers. Added Added DOE O 456.1 to Prime Contract Drivers. Added a dictionary link to "unbound engineered nanoscale particles (UNP) worker.
12/12/2011	*Administrative* Modified Changed ESH100.2.IH.20 reference to ESH100.2.ENV.27; no title change. (Related Processes & Procedures) Replaced SAPLE links for subject matter experts with direct links to e-mail for improved usability.
12/09/2010	*Administrative* Modified Changed contact link for industrial hygienist. Change contact link for local exhaust ventilation. Correct link for dictionary terms. (Requirements & Instructions, Training)
11/18/2010	*Administrative* Modified Updated SAPLE link to subject matter expert for system consistency. Un-merged cells in Requirements & Instructions for display purposes. Updated all dictionary terms to contain term identification numbers for system consistency.
6/24/2010	*Administrative* Added Added a period after the Guidance title in Forms, Links, and Tools.
6/22/2010	*Administrative* Modified Updated the Change Summary
6/17/2010	*Administrative* Added Guidance document to Forms, Links, and Tools
06/16/2010	*Administrative* Added Added a new heading "Sign" to Requirements and Instructions, Forms, Links & Tools. Modified Moved the sign data from the heading “Form” to “Sign” in Requirements and Instructions, Forms, Links & Tools.
05/07/2010	*Administrative* Modified Corrected links to exposure assessment, high-efficiency particulate air (HEPA) exhaust filtration, high-efficiency particulate air (HEPA) filter, HEPA, Members of the Workforce, agglomerates, and aggregates in Requirements & Instructions and Training Requirements.