(Beyond Pesticides, November 24, 2008) Acknowledging the critical need for in-depth review of products utilizing nanotechnology pesticides, the Environmental Protection Agency (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.
In the Federal Registry notice released Wednesday, EPA determined that ICTA’s petition “raises serious issues that potentially affect private and public sector stakeholders” and is instituting a 60-day period for public comment. EPA will review the petition and any comments received “before deciding how best to respond to the petition.”
ICTA filed a legal petition in May 2008 challenging EPA’s failure to regulate nanomaterials in pesticides. The 100-page petition addresses the serious human health concerns raised by these unique substances, as well as their potential to be highly destructive to natural environments, and calls on the EPA to fully analyze the health and environmental impacts of nanotechnology, regulate nano products as new pesticides, and require labeling of all products.
“It’s unfortunate that it has taken seven months, but the agency has taken the first step towards potential regulation of these products and protection of the environment,” said George Kimbrell, ICTA staff attorney. “We are confident the agency will do the right thing and properly classify these products as pesticides.”
Nanotechnology is a powerful new platform technology for taking apart and reconstructing nature at the atomic and molecular level. The same size and chemical characteristics that give manufactured nanoparticles unique properties – tiny size, vastly increased surface area to volume ratio, high reactivity – can also create unique and unpredictable human health and environmental risks.
Increasingly, manufacturers are infusing many and diverse consumer products with nanoparticle silver (nano-silver) for its enhanced “germ killing” abilities. Nano-silver is now the most common commercialized nanomaterial. There are more than 260 nano-silver products currently on the market, ranging from household appliances and cleaners to clothing, cutlery, and children’s toys to personal care products and electronics.
“Nano-silver is an unknown threat not only to the environment but also to human health,” Kimbrell said. “The public has no idea that consumer products contain potentially dangerous nanoparticles because no labeling is currently required.”
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.
Many of the nano-silver infused products are for children (baby bottles, toys, stuffed animals, and clothing) or otherwise create high human exposures (cutlery, food containers, paints, bedding and personal care products) despite little research on nano-silver’s potential human health impacts. Studies have questioned whether traditional assumptions about silver’s safety are sufficient in light of the unique properties of nano-scale materials.
Comments must be received by EPA on or before January 18, 2009. Direct your comments to docket ID EPA-HQ-OPP-2008-0650. Submit comments online at http://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.