Page:Current Strategies for Engineering Controls in Nanomaterial Production and Downstream Handling Processes.pdf/21

 Many good resources are available on the occupational safety and health risk management of nanomaterials. Comprehensive documents have been produced by a number of organizations. Some of these are listed in Appendix A.

1.3.1 Prevention through Design (PtD)

The concept of Prevention through Design (PtD) is to design out or minimize hazards, preferably, early in the design process. PtD is also called inherent or intrinsic safety, safety by design, design for safety, and safe design. When PtD is implemented, the control hierarchy is applied by designers (e.g., engineers, architects, industrial designers) and business leaders (e.g., owners, purchasers, managers) who consider the benefits of designing safety into things external to the worker to prevent work-related injuries and illnesses.

PtD strategies, like the hierarchy of controls, can take many forms. Elimination and substitution measures are desirable, but these strategies may be difficult to implement when working with nanomaterials because these materials are likely being used for their unique properties. The pharmaceutical industry has addressed some of these challenges since their products must be contained rather than removed or eliminated from the process. They have adopted a containment hierarchy of controls that addresses designing inherent safety into the process [Brock 2009]. The initial levels of containment include elimination and substitution as well as product, process, and equipment modifications. Only after efforts have been made to design the process to reduce potential emissions sources should engineering controls be considered.

Other PtD strategies can be considered:


 * Limiting process inventories by producing the nanomaterials as they are consumed in the process.
 * Operating a process at a lower energy state (e.g., lower temperature or pressure), which typically results in lower fugitive emissions and therefore safer operation.
 * Using fail-safe devices where possible. Fail-safe devices are designed so that if they fail, the system reverts to a safer condition. An example of a fail-safe device is a valve controlling a reagent for a reaction. If the safe condition for the system is for this valve to be closed, the fail-safe valve would automatically close in the event of a failure.
 * Installing a closed transport system to eliminate worker exposures during transport activities.

PtD strategies typically do not include administrative controls and personal protective equipment (PPE) as the primary controls. These measures require worker interaction with the process or active steps to limit the extent of the hazard. Most effective PtD approaches reduce or eliminate hazardous conditions without relying on input from workers. Humans are generally recognized as being much less reliable than most machines, particularly in emergencies [Kletz 2001]. The use of administrative controls and PPE in PtD strategies is generally for redundancy—further safeguards should the primary control fail.