The EPA is considering action to define products using nanotechnology as pesticides. The EPA opened a 60-day public comment period in response to a petition filed by the International Center for Technology Assessment (ICTA) which demands the agency stop the sale of numerous consumer products with nano-silver. Classifying nano-products as pesticides helps develop parameters around how nano can be used, and how consumers can be informed that a product is a nano-product. Currently, there is nothing that regulates consumers be notified that a product using nanotechnology be identified as such.
Nanotechnology is the science and application of engineering on a molecular scale. It operates on the scale of matter a billionth of a meter in size. To put in into context and to use Andrew Maynard’s reference, nano-scale is akin to the size of the moon (yeah, that one up in the sky) to the size of a Twinkie.
Some of the potential benefits of nanotechnology include targeted delivery and time-release of pharmaceuticals, agricultural (soil) applications, and Rice University is doing some compelling work on utilizing nanotechnology to fight cancer.
Nanotechnology is a topic of spirited discussion as some of its potential benefits are pretty tough to argue with. Even with its potential, there is evidence that we do not know enough about the technology to evaluate it with meaning. Technology “watchdog” groups and now, natural product industry groups are reviewing the technology and the research. Notably in organic this year, both the Soil Association in the UK and the BFA in Australia made declarations regarding prohibiting the use of nanotechnology in certified organic products in their respective countries.
The premise of the ICTA petition is that items engineered on the nanoscale may exhibit unique and unpredictable properties that can have a detrimental effect on human health and the environment. At issue is the use of nano-silver which is commonly used in personal care products, and packaging. According to the ICTA, “Silver is known to be toxic to fish, aquatic organisms and microorganisms and recent scientific studies have shown that nano-silver is much more toxic and can cause damage in new ways. A 2008 study showed that washing nano-silver socks released substantial amounts of the nano-silver into the laundry discharge water, which will ultimately reach natural waterways and potentially poison fish and other aquatic organisms. Another 2008 study found that releases of nano-silver destroy benign bacteria used in wastewater treatment. The human health impacts of nano-silver are still largely unknown, but some studies and cases indicate that the nanomaterial has the potential to increase antibiotic resistance and potentially cause kidney and other internal problems.”
The Project for Emerging Nanotechnology has compiled a list of consumer products currently using nanotechnology. This list is eye-opening as it includes many products in food and beverage, and for children. Some of which we see on our shelves daily.
To comment to the EPA, direct your comments on or before January 18, 2009 to docket ID EPA-HQ-OPP-2008-0650. Submit comments online athttp://www.regulations.gov, or by mail: Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.