There are special precautions that should be taken due to the changes in physiological interactions and responses based on the nano-size of the particles even if the micro and macro sizes are not considered hazardous.  A prime example is carbon based nanomaterials.  Carbon nanotubes or buckeyballs are mostly pure carbon,  which at macro level would not be considered hazardous, but at the nano size range have indications of toxicological significance.  Legally, the person is correct, but best practice at this point is to contain nanomaterial size particles in any bulk form, label them and manage as potentially hazardous waste. 

A good source for information is www.goodnanoguide.org, or the NIOSH nanotechnology site

Larry. Gibbs, CIH

Associate Vice Provost for EH&S

Stanford University

480 Oak Road

Stanford, CA  94305-8007

650-723-7403

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Kim Gates
Sent: Thursday, April 11, 2013 8:58 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Nano materials spills?

Our hazardous waste manager has said that unless the "parent" material meets the hazardous waste definitions, the material is not hazardous due only to it being a nanomaterial.