Perhaps you can relate to this situation: Just as our client’s sales force was poised to ship a hot new product to a dozen market countries, one of the process chemists happened to mention to the environmental manager that the product contained a “nano” component. Suddenly these small particles became a very big deal to the environmental manager, who needed to determine the relevant regulatory restrictions on a tight schedule.
Although the use of nanomaterials dates back centuries, commercial use has increased dramatically over the last decade as manufacturers have used their unique properties to create competitive advantage. In response to this increased use, environmental managers now must navigate an ever-evolving suite of regulations and health and safety precautions for those employees working with nanomaterials.
Nanomaterials can offer increased strength, conductivity, or reactivity, but particle size can also affect certain physicochemical properties, and even the toxicological effects of the substance. These may include:
- Decreasing the size of a particle increases the relative proportion of atoms on the surface. Consequently, the dissolution rate and the relative rate of reactivity can increase, for example.
- Each atom on the particle surface has fewer bonds than it would have if it were located in the middle of the particle. As a result, the energy associated with those atoms, known as the “surface free energy” differs from the free energy associated with atoms in the center of the particle. The surface free energy can affect such physical properties as the melting point, equilibrium solubility, and reactivity. The latter explains why nanoscale catalysts can be so effective.
- When the diameter of the particle is of the same magnitude as the wavelength of the electron wave function, so-called “quantum effects” occur. At this point the electrical and optical properties of the particle may change, allowing for carbon nanotubes to conduct electricity, or silver particles to appear blue, for example.
Managing the potential risks of nanomaterials can be a daunting challenge for environmental managers. One of the most difficult issues to solve is that regulators around the world define “nanomaterial” differently, with the size cutoff ranging up to 2000 nanometers (nm) and some definitions including other parameters. An environmental manager concerned with product registration must carefully parse the regulatory definitions and their application to nanomaterials, to determine if their products are regulated differently than bulk materials. Other environment, health and safety (EHS) risks associated with nano-scale materials include:
- Evolving product registration requirements;
- Appropriate health and safety precautions for workers;
- Waste management;
- Perceptions and misperceptions by customers; and
- Other life cycle concerns.
The scenario described at the beginning of this blog ended with a twist. Although the raw material supplier characterized their product as a nanomaterial, perhaps for the “cool factor” associated with the name, it did not actually meet the regulatory definition of a nanomaterial in any of the market countries. No special registration, classification, or labelling provisions applied to the material, and our client’s product could be shipped without delay.
Kate Sellers is Principal Environmental Engineer with Arcadis and co-author of the book, “Nanotechnology and the Environment”. She will continue the discussion about managing nano-scale materials during NAEM’s upcoming webinar “Understanding the EHS Opportunities and Challenges of Nanotechnology” on August 16.
With more than 30 years in the oil and gas, and hard rock and coal mining industries, Sandy Stash has significant experience representing business on controversial natural resource, public health and environmental issues. A petroleum engineer by training, she spent her early career as one of the first women to work as a drilling engineer and drilling rig foreman at ARCO locations across North America. Today she is the Global Senior Vice President of Health, Safety, Security, Environment and Operational Assurance at Talisman Energy. Her current project is introducing a holistic operational management framework that will govern risk management across Talisman’s global businesses. We spoke with her at NAEM’s recent Environmental Women’s Leadership Roundtable about her career.
GT: You were one of the first women to work as a drilling engineer. What was it like for you back then?
SS: Actually, it was a blast! In all seriousness, I made a conscious decision, particularly as a woman, to get some good solid field experience. The first thing I learned about was the equipment. I also gained a better understanding of the culture of the oil industry. And finally, I learned an awful lot about influencing people because as you might imagine, I was a 22-year-old female thrown on a drilling rig, ostensibly to be “the boss,” yet I really didn’t know what I was doing. I think I learned a lot about how to listen to people, how to influence them and how to build the teamwork necessary to make me successful.
GT: Throughout your career, you’ve also been involved with driving change in a lot of complex organizations. What are some of the strategies you’ve used?
SS: Well, first of all, it’s very, very hard work because I think that as human beings we tend to be change resistant, so I think it’s important to take the time to understand everyone’s perspective. Number two, there’s a bit of collaborative work that needs to be done to come up with a common vision. In other words, it’s a lot easier if you own part of the change, rather than having someone else telling you that you need to change. The third thing is that once you’ve made the decision, you need to be very clear about who is accountable for the outcomes. And finally, and this may be the toughest part, you’re always going to have some people who don’t want to get on board, and you need to get them out of the way.
GT: You have been involved with structuring the EHS guidelines for Talisman’s hydrofracking operations. One of the most important components you identified was a commitment to transparency. Could you explain why you included that?
SS: Hydrofracking or ‘fracking’ comes under a lot of pressure because of the concerns that people have about the materials or the chemicals that go into the frack jobs. Truthfully, it’s a very, very small percentage because mostly it’s water and sand, but we feel that we can dispel a lot of concerns and bad information by just fully disclosing what chemicals are in our frack jobs. And finally, by being transparent about chemical usage and whatever it is, the next very important step is that you actually set metrics to improve, reduce or increase whatever the metric is. So transparency leads to very important target-setting, which is important for all of us to continuously improve our businesses.
GT: You also said that your attitude when it comes to incidents is “Not on my watch.” What did you mean by that?
SS: I think that as HSE professionals we should be preventing accidents, not responding to them. We may always have the need to respond, but the more we can do in the way we design our plants, operate our plants, train our people and create clarity around people’s accountability, the better we will be at preventing accidents in the first place.
For more interviews with speakers from the Environmental Women’s Leadership Roundtable, please visit www.youtube.com/NAEMorgTV.
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