ASSE submitted a comment on an EPA proposed rule to set significant new use rules (SNURs) for chemical substances, seven of which include carbon nanotubes. For those substances involving nanotechnology, ASSE told EPA it could not ignore established industrial hygiene and safety practice, NIOSH and its own research by not requiring the hierarchy of controls to be followed in protecting workers under the SNURs. “An appropriate risk assessment based on the hierarchy of controls requires that engineering controls be considered first, and if deemed feasible, implemented before considering the use of PPE," ASSE says. "Yet, no mention is made of engineering controls in EPA’s required protections.”
Read the proposed rule
here and ASSE's comment
here.
