The Victorian Trades Hall Council’s (VTHC) Occupational Health and Safety Unit.
Nanotechnology is the generic name given to the production or use of very small, or ‘nano’ particles. These are particles that are less than one hundred nanometres or about one thousandth the width of a human hair. A nanometre is one billionth of a metre.
Introduction
Nanotechnology is likely to be extremely important in the future as it allows materials to be built up atom by atom. This can lead to the development of new materials that are better suited for their purpose. There are several branches of nanotechnology, but most of them are in an early stage.
It is an area for which there is no regulation in Australia. Companies are under no obligation to even notify any government authority if they import, use or manufacture nanomaterials.
The potential effects of nanomaterials on worker health and that of the general community, as well as on the environment, are largely unknown.
The only nanotechnologies that are commercially available at present are ultra fine powders and coatings, although this is changing all the time. These are used in a variety of products including sunscreens, self-cleaning glass, and textiles – but the list of materials being developed commercially using nanotechnology is growing at a very fast rate. For example, there have been recent media reports of research into the use of nanoparticles to treat dental cavities. The Project on Emerging Technologies (based at the Woodrow Wilson International Center for Scholars) keeps a list of commercially available products containing nano materials. Recently updated (October 2013), the Nanotechnology Consumer Products Inventory now contains 1,628 consumer products that have been introduced to the market since 2005, representing a 24 percent increase since the last update in 2010. The list is updated regularly, and can be browsed, or searched by product or country.
Other forms of nanotechnology being developed include tiny sensors called nano-units, of which some simple types are readily available; ‘smart materials’ that change in response to light or heat; ‘nano-bots’ – tiny mobile robots that have yet to be developed but are theoretically possible; and self-assembling nano-materials that can be assembled into larger equipment. These are being actively developed. Australia’s own CSIRO, for example, has developed a building material that with nanotechnology, is able to repair itself multiple times.
Nanotechnology is already a huge industry with billions of dollars being spent on research and development worldwide. There is still a great deal to learn about both the potential benefits and risks of the technology. Nevertheless, most experts agree that the use of nanotechnology in electronics, the pharmaceutical industry and in areas such as medical imaging is outstripping our understanding of the OHS risks.
Nanotechnology could lead to significant developments in medicine, manufacturing and computing. However it may also bring significant new health hazards.
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What are the possible dangers of nanotechnology?
Although most of the press coverage has been on the dangers of ‘nano-goo’ such as self-replicating particles that get out of control, or ‘nano-robots’, the real risks are much more simple, and real. The miniature size of nanomaterials and the way their surfaces are modified to increase the ease with which they can interact with biological systems – the very characteristics that make them attractive for applications in medicine and industry – makes nanomaterials potentially damaging for humans and the environment.
Nanoparticles are likely to be dangerous for three main reasons:
- Nanoparticles may damage the lungs. We know that ‘ultra fine’ particles from diesel machines, power plants and incinerators can cause considerable damage to human lungs. This is both because of their size (as they can get deep into the lungs) and also because they carry other chemicals including metals and hydrocarbons in with them.
- Nanoparticles can get into the body through the skin, lungs and digestive system. This may help create ‘free radicals’ which can cause cell damage and damage to the DNA. There is also concern that once nanoparticles are in the bloodstream they will be able to cross the blood-brain barrier.
- The human body has developed a tolerance to most naturally occurring elements and molecules that it has contact with. It has no natural immunity to new substances and is more likely to find them toxic.
The danger of contact with nanoparticles is not just speculation. As more research is undertaken, concerns increase. Here are some of the recent findings:
- some nanoparticles cause lung damage in rats. Several studies have shown that carbon nanotubes, which are similar in shape to asbestos fibres, cause mesothelioma in the lungs of rats (see below)
- other nanoparticles have been shown to lead to brain damage in fish and dogs
- a German study found clear evidence that if discrete nanometer diameter particles were deposited in the nasal region (in rodents in this case), they completely circumvented the blood/brain barrier, and travelled up the olfactory nerves straight into the brain
- inhaled carbon nanotubes can suppress the immune system by affecting the function of T cells, a type of white blood cell that organises the immune system to fight infections.
According to the USA’s Woodrow Wilson International Centre for Scholars chief science advisor (speaking at a conference organised by the Australian Institute of Occupational Hygienists – AIOH), Dr Andrew Maynard, ‘Whether [the research] is relevant to humans we’re not sure yet. But it does indicate nanometer-size particles and nano-structured materials behave in different ways to what we’re used to.’ One of the big problems is that it’s impossible to know whether a product or substance contains nanoparticles, as current legislation does not require these to be labelled.
The US government safety research body NIOSH has produced a guide (see below) which states nanomaterials may interact with the human body in different ways than more conventional materials, due to their extremely small size. For example, studies have established that the comparatively large surface area of inhaled nanoparticles can increase their toxicity. Such small particles can penetrate deep into the lungs and may move to other parts of the body, including the liver and brain.
NIOSH’s Nanotechnology Research Centre (NTRC), has also released an interim report Progress Towards Safe Nanotechnology in the Workplace [pdf] (Feb 2007). The NTRC was established to coordinate and facilitate research in nanotechnology and develop guidance on the safe handling of nanomaterials in the workplace. The report identifies 10 critical OHS areas and reports on the advancements to date. The areas include toxicity and internal dose -determined heart and lung responses to nanoparticles; risk assessment; epidemiology and surveillance – developing guidance for nanotechnology employers and workers on how to implement OHS surveillance programs in the workplace; engineering controls and PPE; and measurement methods.
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As hazardous as asbestos?
A major study published in Nature Nanotechnology in May 2008 suggested some forms of carbon nanotubes could be as harmful as asbestos if inhaled in sufficient quantities. The study used established methods to see if specific types of nanotubes have the potential to cause mesothelioma. The results show that long, thin multi-walled carbon nanotubes that look like asbestos fibres, behave like asbestos fibres. The study shows there is strong evidence that if carbon nanotubes get into the wrong place, they can cause mesothelioma. Still unanswered questions are whether exposure to the material will actually occur, whether people can breathe it in, and if they do, whether these fibres can work their way to the outer edge of the lung and then cause an effect.
Friends of the Earth has produced comment on the studies, and also interesting is a June 2009 article in the online magazine newmatilda.
Australian news
Safe Work Australia has done quite a bit of work on carbon nanotubes.
In June 2011: a research report, Durability of carbon nanotubes and their potential to cause inflammation. The report considered the durability of carbon nanotubes and the tendency to cause lung inflammation if inhaled, two indicators of potential asbestos-like behaviour. Carbon nano-tubes are already being used in a number of different applications.
Key findings in the report include:
- Some types of carbon nanotubes can be durable, but others may also break down in simulated lung fluid.
- Carbon nanotubes of certain length and aspect ratio can induce asbestos-like responses in mice, confirming previous findings. However, this response may be reduced if the nanotubes are less durable.
- tightly agglomerated particle-like bundles of carbon nanotubes did not cause an inflammatory response in mice.
In October 2012, a further report: Human Health Hazard Assessment and Classification of Carbon Nanotubes which it commissioned NICNAS to do. In addition, an information sheet Classification of Carbon Nanotubes as Hazardous Chemicals has also been published.
The report recommends classification of carbon nanotubes as hazardous for repeated or prolonged inhalation exposure and for carcinogenicity. With respect to the carcinogenicity of carbon nanotubes, the Information sheet summarises it as follows: ‘Based on the limited data available on mesothelioma formation in animal studies and difficulty in conclusively determining whether a specific multi-walled carbon nanotube (MWCNT) can present as a fibre of pathogenic dimensions, the report recommends that all MWCNTs should be considered as hazardous and classified for carcinogenicity as follows in accordance with:
- Approved Criteria – Classification: Carcinogen Category 3, Harmful (Xn). Risk Phrase: R40 Limited evidence of a carcinogenic effect
- GHS – Classification: Carcinogen Category 2. Hazard Statement: Suspected of causing cancer
The report notes that there are no studies demonstrating that single-walled carbon nanotubes (SWCNTs) cause mesothelioma.
This work has had international implications, with the US’s NIOSH recommending a new level of exposure for carbon nanomaterials (see Update – April 2013). The recommendations include reducing worker exposures to airborne concentrations of those materials to no more than 1 microgram per cubic meter of air as a recommended exposure limit. This is the lowest airborne concentration that can be accurately measured. The recommended exposure limit is intended to minimize potential risk for adverse lung effects in workers who might be exposed at this concentration over a working lifetime.
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The importance of prevention
At the moment no one knows for certain how dangerous the many different types of nanoparticles are likely to be to humans. However it is important that we do not allow workers to be exposed to an unknown danger where effects may not be known for years, even decades.
These risks were highlighted in a report from the UK’s Royal Society which said ‘nanotechnology offers many potential benefits, but its development must be guided by appropriate safety assessments and regulation to minimise any possible risks to people and the environment.’ It also called for a tightening up of regulations.
The UK Royal Commission on Environmental Pollution released a report in November 2008: Novel Materials in the Environment: The case of nanotechnology, stating that nanomaterials are likely to kill people in the future just as asbestos did unless extensive safety checks are put in place. The team of experts assessing the likely impacts of the emerging technology expressed concerns that when nanomaterials escape into the environment they will damage people and wildlife – but that it will be years before the effects are seen. Past generations have brought into general usage materials such as asbestos, leaded petrol, CFCs and cigarettes without adequately considering the potential damage and the commission fears nanomaterials will prove similarly dangerous.
The international insurance company, Swiss Re issued warnings at least fifteen years ago that the uncertainty about the risks that nanotechnology and nano-pollution pose means that they currently will not offer insurance to the industry.
There has been very little attention paid to nanotechnology in Australia. Unions made a number of submissions to a Senate inquiry into Workplace Exposure to Toxic Dusts that raised the emerging issue of nanotechnology in Australia. The VTHC, together with the ACTU and our union affiliates is calling on government to use its existing capabilities and authorities, or develop new ones as needed, to ensure that the risks of nanomaterials are identified before they are incorporated into products for commercial production.
Employers should take a precautionary approach and ensure that workers are not exposed to nanoparticles. This is the advice given by the UK government, which adds that ‘as the risks arising from exposure to many types of nanoparticles are not yet completely understood, control strategies should be based on a principle of reducing exposure as much as possible.’
For unions that means seeking to ensure that the production and use of nanoparticles is done within a contained process so that employees are not exposed to any potential unknown risk. Nanomaterials should be treated just like any other serious health risk.
It is important that unions act now to ensure that we do not have a re-run of the asbestos tragedy where hundreds of thousands of people were exposed to a killer dust that even today kills many thousands of people a year. On September 19, 2007, the ACTU and its affiiates signed up to the international Declaration on the Principles for the Oversight of Nanotechnologies and Nanomaterials. The declaration identifies eight fundamental principles for the effective oversight and assessment of nanotechnology, including mandatory government regulation. It can be downloaded at the top right hand side of this page.
In June of 2008, the European Trade Union Confederation (ETUC) adopted its first resolution on nanotechnology and nanomaterials: that the precautionary principle must apply. The resolution states: ‘nanometre forms of chemicals should not be allowed on the market unless sufficient data are supplied to show no harmful effect for human health and the environment.’ It adds that risk reduction measures must be used and employers must involve workers and their representatives in the assessment and reduction of nanomaterial-related risks. Other measures called for by ETUC include training and health surveillance for workers exposed to nanomaterials, at least 15 per cent of public research budgets on nanotech to be dedicated to health and environmental aspects and for workplace health and safety to be included in all research programmes. Statement and Resolution.
The ACTU Occupational Health and Safety, Rehabilitation and Compensation Policy (2012) now has a specific section on Nanotechnology. Download the Policy here.
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Government initiatives
The Federal Government established a National Nanotechnology Strategy Taskforce under the auspices of the then Department of Industry, Tourism and Resources (DITR). The taskforce did work in the following areas:
- details of research and other activities – recently undertaken, current and planned;
- a critical review of substantial work done. This will include input from nanotechnology scientific expertise to ensure the scope of the review is relevant and covers current technologies;
- a synthesis of the current state of knowledge in the area relevant to OH&S, and relevant to the workplaces in Australian industries; and
- identification of key gaps in knowledge and areas where further research may be targeted.
The Department of Industry, Innovation, Science, Research and Tertiary Education now ‘houses’ the Enabling Technologies area, and has a website with information on government initiatives on nanotechnology.
In August 2006 the ASCC (now Safe Work Australia) released its report: Review of the Potential Occupational Health and Safety Implications of Nanotechnology. The report stated: ‘The distinctive and oftentimes unique properties which are observed with nanoparticles have been proposed to revolutionise manufacturing and consuming in the future – much as the industrial revolution did in the late 18th and early 19th centuries’ and ‘At this early stage the potential applications of nanoparticles seem to be limited only by the imagination’.
It concludes that ‘[t]he occupational health and safety effects of engineered nanoscale particles are mostly unknown,’ while acknowledging however, that ‘findings from animal and in vitro test systems have provided some valuable information and these results indicate that human and environmental health consequences are possible from nanoparticle use and exposure.’
The report recommended addressing the ‘greatest gaps in our current knowledge’ as a matter of priority, namely:
- developing cost-effective and robust ambient air monitoring systems to provide accurate information on worker exposures
- setting priorities to acquire the necessary information for the determination of meaningful workplace exposure standards and adequate worker protection.
- undertaking chronic exposure studies in order to generate information on the long-term health effects
A 2007 publication from NSW WorkCover, Nanotechnology: OHS overview, summed up some of the concerns. It called for a more proactive approach to regulating public and worker safety when it comes to nanotech. The paper pointed out that the pace of the industry’s development meant OHS researchers and regulators already lagged behind. There is still no specific nano regulation. Some of the points in the paper:
- Existing regulations do not sufficiently cover nanotechnology.
- Current OHS risk management processes do not readily apply because of the different structures and behaviours of nanoparticles
- So, there is no guarantee that existing safe work practices will transfer to nanotech.
- There is a crucial gap because OHS regulations focus on the chemical composition rather than the size or surface area, such as is the case with nanoparticles.
- However an effective gap analysis of how existing legislation applies to nanotech will not be possible until further knowledge of measurement procedures and exposure levels is gained.Back to top
2008
In July, Senator the Hon Kim Carr, the then Minister for Innovation, Industry, Science and Research released two documents:
- The Australian Government Approach to the Responsible Management of Nanotechnology [pdf]: identified objectives to guide government agencies, including regulators and policy makers in their decision making process and policy development for nanotechnology.
- The independent report, A review of possible impacts of nanotechnology on Australia’s regulatory framework [pdf]: commissioned by the Australian Office of Nanotechnology to assess the adequacy of nanotechnology regulation and produced by the Centre for Regulatory Studies at Monash University. It concluded that there were a number of regulatory ‘triggers’ (that is ‘gaps’) that needed to be addressed. NOTE: in 2013, many of these gaps had not yet been fixed.
2013
In April 2010, a large group of Non-government organisations, including unions and Not for Profit organisations, raised concerns with government regarding the information being produced by various departments on nanotechnology. The groups believed that much of the information was biased – understating the potential problems with the legislation, and overstating the potential benefits. After much discussion and delay, an independent review of the material (and a number of events) was undertaken. While the review was completed in 2012, the findings of of the review were not released by government until the end of 2013. The review concluded: ‘Australian government public information on nanotechnology has had a bias in favour of promoting the technology.’
The reviewers, Toss Gascoigne from the Australian Science Communicators, and Dr Karen Cronin from the Asia-Pacific Science and Technology Studies Network, said, ‘Some of the items make only brief reference to scientific research and public concerns about potential health and environment risks. There is little in the materials about ethical, cultural or privacy issues.’
Below are the documents, now on the Department of Industry website:Review Panel Final Report (PDF 209KB) | (DOCX 105KB)
