Darwin M. IrishWhen developing strategies around the safety of emerging technologies, there are several key areas to consider. For those tasked with this development, there are a plethora of articles detailing a variety of approaches, but as you delve into them all, it becomes clear that the thoughts and experiences written about this area lean, universally, toward the risk management of “minding uncertainty.”
Malcolm Gladwell wrote in his book Outliers: The Story of Success that “it takes roughly 10,000 hours of practice to achieve mastery in a field.” If you are dealing with uncertainty, particularly in the safety of emerging technologies, it is incumbent upon your organization to delve deeply into those unknown territories to gain an abundance of information and develop a strategic plan that exceeds safety precautions. The following steps are best practices when embarking on this difficult procedure, always keeping in mind that at all points in the journey, it’s imperative to not only ask “What do we know?” but more importantly, “What don’t we know?”
Conduct Research
Part of the challenge is that there already might be viable information out there and you simply need to know where to look. The academic world and technical agencies, such as the National Institute for Occupational Safety and Health (NIOSH), are a good place to start. Professional organizations will most likely have gathered and summarized data as well. The Centers for Disease Control (CDC) and the World Health Organization (WHO) are also likely to have technical guidelines. Use all of these resources and outline the similarities between the information, but also note any significant gaps. These gaps are worthy of further investigation. Rummaging through the literature will assist you in building a strong knowledge base.
Challenge Inconsistencies Across Safety Data Sheets
Another valuable tool at your fingertips is the information on product safety data sheets (SDS). But, be wary of SDS data. Remember, in an emerging technology, there are unknowns. You owe it to yourself to be suspicious. Be aware of inconsistencies with needed specific data, especially for the same compound. There are various methodologies used to create SDS and not all align. For example, when you see “fatal if inhaled” on a rather benign compound, contact the manufacturer and question it. More likely than not, it was an oversight. Normalizing the challenges of inaccurate SDS data is an important step in your safety strategy.
(AP Photo)Educate And Train Your Employees
Employee education and training should be paramount to (and is required for) the success of emerging technologies. It is vital that you talk to your employees about how the guidelines will be used and how — through an abundance of caution — the controls will provide the highest level of protection. Remember, we don’t all interpret information the same way. The Internet supplies us with a wealth of knowledge on any given topic. Your training information and hazard awareness education should accurately reflect what you know about the emerging technology well ahead of the employees’ knowledge. Ensure that you have assessed and accurately defined how your company is putting that emerging technology into practice through your own processes, usage, storage and emergency procedures. In your investigation of hazards, employ the highest level of control (using the hierarchy of controls) that enclose your processes. Your training should then include the highest level of information and protection factors. It’s always easier to have the option to back off controls as you learn more or as regulatory statutes are disseminated than it is to have to add on controls later.
Understand The Regulatory Framework
Following technical guidance (e.g., NIOSH Studies) and recommendations and then applying further controls can only serve to strengthen your strategy for success at the business and safety levels. Keep a close eye on regulatory thinking around establishing standards for new substances. The Environmental Protection Agency (EPA) sets Significant New Use Rules (SNURs) and the Occupational Safety and Health Administration (OSHA) will use the federal register to promulgate new standards. Knowing what’s coming is important for your safety strategy setting.
One example is the use of Carbon Nano Tubes (CNTs) where regulatory safe limits have not been established to date. Much work has been done (field studies) and industry experts convened around the development of various controls, and there’s a regulatory limit for exposure on the horizon. In this particular example, there appears to be a heightened sensitivity around CNTs mimicking asbestos fibers and laboratory studies have demonstrated health risks in lungs of mice for both CNTs and CNFs (Fibers). NIOSH is at the forefront of these studies and, while they are not the regulatory arm, they provide recommendations to EPA and OSHA when setting limits.
It might seem that the only known when developing safety guidelines for emerging technologies is the unknown, thus making the development of these guidelines a rather daunting task. However, if you approach the process using the steps outlined above, the unknown element can be minimized. That is, of course, until the next emerging field with accompanying unknowns comes along and the process begins again.
About The Author: Darwin Irish, director of risk management at FLEXcon, a global leader in coated and laminated films and adhesives, joined the company in 1985 with over 34 years of industry experience.
