Nano SNURs Can’t Overlook Engineering Controls, ASSE Tells EPA
ASSE submitted a comment on an EPA proposed rule to set significant new use rules (SNURs) for chemical substances, 7 of which included 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 requring the hierarchy of controls to be followed in protecting workers under the SNURs. ASSE said, “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 personal protective equipment (PPE) such as respirators, gloves and clothing. Yet, no mention is made of engineering controls in EPA’s required protections.”