Environmental Risk Management for Chemical Substances - Nanoco Technologies Ltd - Case Study Example

Environmental Risk Management for Chemical Substances (Nanoco Technologies Ltd) Introduction Contemporary industrial times have seen an emergence and continued growth in nanotechnologies; where according to Aitken, Creely, and Tran (2004:113), “many companies are in the startup phase or in operation, or they already incorporate nanoparticles (NPs) into their processes to improve their products’ performance”. A large percentage of the transported chemical products are liquid in nature and as a result, they pose a great threat to both humans and the environment in general in cases of accidents like spills however the risk is increased in cases where the substances spilled or rather involved in the accidents are hazardous. The transportation of these hazardous substances has gained much depth and importance hence raising concerns regarding the odds of chemical spillage occurring as a result of the higher intensity associated with the transportation of chemical products. In the wake of a chemical accident, Pritchard (2000) asserts that the degree of the damage caused by the substance is dependent on the type of the incident, quantity and nature of the substance, and primarily on the type of decision taken to cushion the damage as well as the speed at which the decision was implemented. The overall objectives of this paper are: 1. To identify the highest risks associated with the transportation of chemical substances 2. To produce a device which can be used by the organisation to respond to incidents in a timely manner 3. Development of guidelines for the prediction of impacts associated with similar incidences in the future. Company Background Nanoco Technologies Ltd, from hereafter referred to simply as the ‘organisation’ or the ‘company’, is based in the United Kingdom’s city of Manchester and it majors in the development of applications that incorporate nanotechnologies or rather semiconductor NPs called quantum dots (Nanoco 2012). The company is unique in that it manufactures quantum dots in large amounts as opposed to other companies. Due to its wide involvement in nanotechnologies, Nanoco (2012) reveals that the company’s chemical activities are protected by worldwide patents. The quantum dots produced by the company are used for authentication purposes as well as applications in life science and electronics. According to Nanoco (2012), these nanodots are supplied either as solutions of clear solvents, dry powders or are suspended in solid substances that are waxy to stabilise them for longer periods. The company has facilities operating in the UK and Japan. NPs are believed to be more toxic as compared to the corresponding large scale chemical substances with recent research showing augmenting real risks associated with NPs (Aitken, Creely, and Tran 2004:113). With the current knowledge state, however, it is possible for Nanoco Technologies Ltd to effectively manage the risks arising from exposure to NPs. In order to support continued production of nanotechnologies in the organisation and country as well, this documentation assembles the prevailing knowledge regarding the dangers’ identification, risk assessment, as well as risk management of NPs and related substances at Nanoco Technologies Ltd. Identification of Risks/Dangers Risk, in this case is defined by Kandlikar et al. (2007:137) as the possibility of the effects of a chemical substance occurring on a system, organism or a given population in specific state of affairs whereas danger, is a property intrinsic in a substance with the capability to cause harm to an organism, population or system when exposed to this substance. The company produces bunches of cadmium selenide as well as bunches of particles of cadmium selenide coated with cadmium sulphide or zinc sulphide in different sizes in accordance with the specifications of the customer (Nanoco 2012). Production of these nanotechnologies in bulk as Nanoco Technologies Ltd. does results in other hazardous materials being released into the environment via different means. Environmental Risks The existence of synthetic NPs in the environment is likely due to oil leaks and or spills, factory releases of waste water, air and solid wastes as well as through destruction, usage and or degradation of materials having NPs (NIOSH 2007). The presence of NPs in the environment enables them to interact with other particles, transform as well as vary in composition and size from their initial origin. This is later followed by a dispersal of the same via different media, either water, air or soil, causing a handful of effects on these media as well as on the organisms living in them. Little is known about the effects synthetic NPs have on the environment; however, NIOSH (2007) believes that the limited studies that exist provide a general notion regarding their probable impacts. These effects are of course dependent on a number of variables, for instance, the quantity of particles, their availability i.e. whether they are bonded to other particles/molecules or not, the charge of these particles, their speed of sedimentation as well as their level of toxicity in the environment. In order to assess the environmental impacts of these substances, it vital to take into account a number of factors (Hancock 2001): i. The nature of routes and transfer mechanism used by the substance. It can either be water, air, factory releases and wastes. ii. The nature and significance of the sources of emissions of the chemical substance. iii. Living things and their interrelations i.e. food (preys and predators). iv. The nature of the ecosystem. As earlier noted, an NP is a very small particle and as a result they are highly mobile in the environment. They can easily contaminate the plants and animals due to their presence in water, air and soil hence entry into the human food chain. To date, Kandlikar et al. (2007:151) report that a method that is effective in measuring and monitoring NPs in the environment has yet to be defined thus making it difficult to documenting the quantity and route taken by NPs in the environment as well. In cases where the prevailing conditions of the environment are not in the favour of agglomeration of the superfine particles as well as low pollution conditions, NPs could cover more ground via air. The larger particles that cannot be carried away by air will end up deposited on soil with the help of gravity or into the water by rainwater. For the environment to be protected from such pollutions, it is essential that all waste matter, including laboratory and factory releases be treated before they are incinerated or rather before they are discharged back to the environment (NIOSH 2007). Risk Assessment Risk assessment is defined by Kandlikar et al. (20071:37) as “the process by which risk is estimated or calculated, assumes a good knowledge of the identity of the danger (safety and toxicity of products, dose-response relationships) and the exposure levels and characterisation of the dangers at the various workstations”. Therefore, the process of risk assessment helps in determining whether the existing organisational conditions can: i. Give room for solid aerosols of explosive NPs to accumulate under conditions favouring an accident. ii. Allow toxic NPs to be released into the environment at concentrations harmful to the environment. Some chemical substances are flammable leading to risks such as explosions and fires. Working with chemical substances will often lead to generation of airborne aerosols hence the risk of environmental exposure. Working in wet media has a decreasing effect on the aerosols released in the air but does not totally eliminate the emission. Environmental exposure of NPs can occur either during production, usage, handling, storage, recycling, accidental leaks and spills, transportation, as well as during organisational and equipment maintenance. In order to cut down the risks above at Nanoco Technologies Ltd, it requires data from a quantitative risk assessment so as to make viable selection of measures to be implemented in the control of or in the limiting of the respective risks. Hence; with this approach, it is necessary that the control measures be proportional to the variety of risks identified. Risk Analysis Analysis of risks associated with NPs demands a great deal of knowledge regarding the toxicity of the different types of NPs, there potential levels of exposure as well as their related risks. At Nanoco Technologies Ltd, Nanoco (2012) affirms that steps involved in this process are to be carried out repeatedly with regular refining aimed at controlling the risk factors of the chemical substance in question. The purpose of repeating and constantly refining these steps is aimed at accounting for the new bodies of scientific knowledge and modifications subject to the prevailing organisational condition. As a result, the organisation adopts a case by case structured approach which estimates risks of a substance (NP) in the absence of the substance’s specific data by comparing the risks of the same substance but from a large-scale point of view. i. Information Gathering – this step involves a detailed gathering of all information available to help in the identification of the environmental risk factors of the substance. Information gathered include the potential routes of exposure, quantity of substance implemented, potential leaks, physical form of production and handling of the chemical substance, employee and management concerns regarding the determined and or potential risk factors in the environment etc. ii. Exposure Level Characterisation – a host of situations can favour the exposure to chemical substances during various stages of their life cycle. Among these situations are the collection, handling and packaging of nano-metric powders; generation of chemical substances in non-airtight environments and or open areas; cleaning of vents as well as maintenance of workplaces and their equipments. Since Nanoco Technologies Ltd handles products dissolved in clear solvents (Nanoco 2012), liquid NPs can also be exposed to the environment during transportation (accidental leaks and or spills), in cases of violent demonstration operations, and or during breakdowns of organisational equipment (Kandlikar et al. 2007). The major objectives of characterisation include: a. To identify the major sources of emissions so as to develop and or improve on the prevailing strategies for emission control. b. To assess how effective the current control measures are. c. Assessment of the environmental exposure which allows for links to be drawn with health effects in the long run. At this point, relevant strategies and or techniques for assessment and analysis must be tailored to the explicit intervention objectives. Regulatory Frameworks As earlier noted, the activities carried out by Nanoco Technologies Ltd are overseen and or protected by worldwide patents. In order to ensure continued sustenance of the environment, world governing bodies have enacted regulatory frameworks that control the activities by all industrial players that involve chemical and hazardous substances. Nanoco Technologies Ltd is no exception from these regulations. ISO 14001 This is a voluntary international standard which aims at defining the requirements for the development of an organisational environmental management system (EMS) with an objective of establishing an organisational EMS that is fully integrated into the general management process of the organisation (ISO 2004). According to ISO (2004), the standard maps out a framework with which a firm can formulate an effective EMS. The standard also helps in the prescription of controls for activities with an impact on the environment such as naturally occurring resources, usage, and treatment of wastes, chemicals and hazardous substances (ISO 2004). Through implementing the ISO 14001 standard, Pesendorfer (2006) believes that the organisation can save on costs via improved productivity and efficiency as an organisation can discover and take charge of the effects the company has on the environment. To achieve these, Nanoco Technologies Ltd is determined to put in place strategies to marginalise wastes production, efficiently dispose these wastes, as well as use energy efficiently and as such the organisation will be in compliance with the prevailing legislation thus making insurance cover flexible to access (Pesendorfer 2006; Nanoco 2012). REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Representatives of the Council of Ministers and the Environment Committee of the European Parliament that took place on 1 December 2006 regarding the control of chemical products in Europe agreed upon a regulatory framework entitled the REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation that came into action on 1st of July the following year (Heyvaert 2007). The provisions of the framework are still being implemented gradually and this implementation process is expected to run until 2018. According to Heyvaert (2007), the framework provides a regulatory framework that permits the production of information as well as making of vital decisions regarding all the chemicals produced and distributed in the EU region, detailing all aspects of the production and usage cycle of the chemicals. Information collected permits the following: i. Assessment of the production risks, usage risks, marketing risks and disposal risks of the substance in a way that is cost effective. ii. Identification of dangerous substances. iii. Establishment of concrete policies for managing risks associated with chemical substances. Below is a short description the REACH Regulation framework features: a. Registration – the regulatory framework has a policy that requires no chemical substance to circulate the market with no sufficient documentation. To achieve this, REACH has put in place a general requirement for registration that states that “manufacturers or importers of chemicals produced or imported in volumes of over 1 tonne per year must apply for registration, which is conditioned on the submission of a technical data file supplying health, safety, and environmental information” (Heyvaert 2007:201). Chemicals in articles and in preparations are no exception from this registration obligation; an indicator that all other groups of merchants apart from the official chemical importers and manufacturers dealing in selling of a variety of products containing chemicals are subject to these registration duties. It is vital to ensure that the organisation acquires all the registration requirements as per the REACH Regulatory framework in order to operate in a legal environment (Pesendorfer 2006:105). b. Evaluation – this feature of the framework takes into account the evaluation of files of registration submitted so as to reduce the risk of having a data redundant error. In addition, evaluation of the substance is carried out in cases where concerns are raised over the chemicals’ environmental and or health impacts. In case a given substance is subject to evaluation, an EU rolling plan of action is to be developed and assign these substances to an EU member state to act as rapport. Furthermore, in cases where the raised concerns are confirmed, further actions of management might be called into action with respect to evaluation, for instance, making a draft of measures to reduce the risks, or addition of the chemical substance on the list of substances to be authorised in the region etc. c. Authorisation – Subject to requirements for authorisation, the identified chemical substances can only be traded, produced and or used if the approval by the Commission has been obtained. The authorisation applicant has to provide an extensive data-file of proof that includes recommendations for both risk management and risk assessment; and that the apparent risks of the chemical substance are well contained pending the investigations ongoing regarding the substance’s substitute. According to Heyvaert (2007:197), REACH Regulation framework states that “if the risks are shown to be adequately contained, the Commission must authorise. If, on the other hand, it is impossible fully to contain the risks, the Commission may grant authorisation, depending on the severity of the risk and viability of alternatives. Authorisations are subject to review and monitoring”. d. Risk reduction – an alternative to authorisation may involve adopting restrictions to curb the production, use and marketing of chemical products. e. Institutional design – REACH has implemented a new regulatory management framework institutional design. The ECHA (European Chemicals Agency) has been developed by REACH to function as scientific expert providing scientific opinions to the Commission as well as acting as the chief administrator of the program. Formerly, private parties meeting the terms of the regulatory framework of EU were to first establish contact national authorities of Member states. However, this has changed thanks to ECHA who have eliminated the need for involvement of Member State national authorities and instead applicants are only to submit their applications directly to ECHA, which in turn will: check file completeness, review dossiers’ registration information, request further information in cases of clarifications, carry out the registration process as well as the assignment of registration numbers to applicants. Pesendorfer (2006:108) states that “the Commission takes the lead in decisions relating to substance evaluation and its outcome, and decides on authorisations, as well as on restrictions on manufacture, marketing, and use”. Furthermore, Member States have been presented with an opportunity to closely take part in the identification of substances for evaluation, substance evaluation task as well as in the decision-making process of the Commission. f. Enforcement – REACH has a firm stand on the policy of no data no market (Heyvaert 2007:201). Following the expiry date of the transition period, any chemical use or rather unregistered chemicals should be eliminated from the market. The integrity of REACH with respect to control of risks within the EU region will revolve around the effective enforcement of the prevailing regulatory provisions. It is the role of the Member state to see to it that all REACH requirements are enforced to the maximum. Control of Environmental Risks Controlling of environmental risks and their effects on the environment is a process that entails limitation of chemical substance emission into the environment (aquatic and terrestrial ecosystems). Pocklington (2006:306) reveals that it is practically impossible to keep track of NPs’ progression into the environment. In addition, he further argues that these substances have yet to find a method that can be used to eliminate them from the media of transportation, that is, water, air, and soil where in the long run they re-concentrate through the human food chains. It is vital that wastes like paper, disposable respirators, cleaning materials and fluids, filters etc. be disposed off according to the known best practices (NIOSH 2007). At Nanoco Technologies Ltd, storage of solid wastes is done in containers that are well sealed until they are treated and disposed. These liquid effluents have different compatibility hence special attention is needed in handling their disposal. Furthermore, Nanoco (2012) argues that the organisation can also employ incineration or rather waste stabilisation where the preferred approach in this process is the case by case approach. In order to limit the emissions of the organisation, advance treatment and or filtering of the respective factory releases are important. This is to be done under strict adherence to the standard practices, following the desired procedures in the regulatory framework of hazardous substances, their storage as well as their treatment before they are finally disposed (NIOSH 2007). Engineering Techniques i. Design – this technique involves plan development, production organisation, and installation of ventilations, production, procurement, storage, and shipping systems. Workstations’ layouts that are safe for relatively all health, safety and environmental risks, production imperatives, regulatory requirements as well as can eliminate high environmental risk circumstances are to be developed. Diffusion may occur in cases of leaks in the production system hence; it is the designers’ obligation to account for the chemical properties used as well as the control systems responsible for limiting emissions of NPs in the immediate work environment, for example local ventilation and or confinement (Heyvaert 2006). In cases where the use of explosive dusts is expected, it is appropriate to put in place the opposite building structure and equipment. Arguably all these types of structures already exist at Nanoco Technologies Ltd with further developments expected in the coming future (Nanoco 2012). ii. Substitution/Elimination – wherever possible, Nanoco Technologies Ltd prefers to eliminate the dangerous and or toxic substances from the environment. Nevertheless, when incorporating NPs into products and synthesizing them, it is not possible to completely eliminate them from the environment. Another means of environmental risk control that is being taken into huge consideration by the organisation, substitution, has a host of applications in nanotechnology and it involves the following: a. Modification of the process type, b. Modification of the process steps so as to eliminate or automate given operations involving high risks for instance transferring and or transportation, or trans-filling, c. Replacement of highly toxic and or dangerous chemical substances with less toxic and or less reactive chemical substances, d. Replacement of old equipment in order to minimise potential risks such as ignition sources and leaks. iii. Isolation, closed circuit and confinement – operations involving high environmental are sometimes performed in some processes. Consequently, the equipment to be used in these processes should be isolated, ventilated with suitable independent ventilation systems to ensure that the environment of work is free of contamination. iv. Ventilation – emanation of accidental airborne NPs is probable in various operations and or processes as not all of them are performed in airtight closed circuit. Consequently, the type of system installed is dependent on the competence in predicting the release site of the NPs (Heyvaert 2006). In opening of NPs bags, mixing, transferring, weighing and recovery of dry NPs, the discharge of airborne NPs into the environment is probable. An effective method employed by Nanoco Technologies Ltd to control the contamination of the working environment is capturing the contaminants at the source (Nanoco 2012). According to Heyvaert (2006), the process involves installation of local ventilation close to the source of emission, setting the speed of systems so as to capture all NPs escaping the process, treatment of emissions before venting them into the environment, and regular cleaning and maintenance of the ventilation system. Environmental regulations require scrubbing of the air before discharging it to the environment. However, in elimination of dangerous NPs from the environment, ventilation is not an effective method to implement unless quantification of the risk can affirm that this technique is enough to contain chemical substances to levels representing no significant environmental risks (Heyvaert 2006). The field of nanotechnologies is growing rapidly with potential risks of exposure increasing consequently. However, some NPs can involve risks such as explosions and fires which might also be affective to the environment as well. To avoid any exposure to NPs and other hazardous chemical substances, implementing a preventive approach is recommended. References Aitken, R.J., Creely, K.S., & Tran, C.L. (2004) Nanoparticles: an occupational hygiene review, Institute of Occupational Medicine, Health and Safety Executive (HSE), UK, Research Report 274, p. 113. Department of Energy (2007) Nanoscale Science Research Centres approach to nanomaterial, ES&H Revision 2, p. 23. Galow, P. (1998) Handbook of environmental risk assessment and management, Oxford, UK, Blackwell Science. Galow, P. (1998) Handbook of environmental risk assessment and management, Oxford, UK, Blackwell Science. Hancock, J. (2001) Environmental risk management and your business, London, Stationery Office HASREP, (2005) Response to harmful Substances spilt at sea. Project co funded by the European commission under the community framework for cooperation in the field of accidental or deliberate marine pollution. Heyvaert, V. (2006) ‘Guidance without constraint. Assessing the impact of the precautionary principle on the European Community’s Chemicals Policy’, Yearbook of European Environmental Law, vol. 27, p. 46. Heyvaert, V. (2007) ‘No Data, No Market. The future of EU chemicals control under the REACH regulation’ Environmental Law Review, pp. 196-201. Kandlikar, M., Ramachandran, G., Maynard, A. & Murdock, B. (2007) Health risk assessment for nanoparticles: a case for using expert judgment, Nanoparticle Research 9, pp. 137-156. Nanoco Group PLC (2012) viewed 16 February 2013 from . NIOSH (2007) Progress Towards Safe Nanotechnology in the Workplace, Rapport du NIOSH Nanotechnology Research Centre, Department of Health and Human Services, Centers for Disease Control and Prevention National Institute for Occupational Safety and Health, p. 177. Pesendorfer D. (2006) ‘EU Environmental Policy under Pressure: Chemicals policy Change between Antagonistic Goals?’ Environmental Politics, vol. 95, pp. 105-108. 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