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Project on Emerging Nanotechnologies
This column is by Philip Stiff, a member of the Project on Emerging Nanotechnologies team and a current student at the Georgetown Public Policy Institute:
On Nov. 19 EPA opened up a docket for comment on the May 1 petition filed by a coalition of 14 consumer advocacy groups that calls for regulation of products containing nanosilver. The petition requests that EPA ban the sale of products that contain nanosilver until the agency makes a regulatory determination that nanosilver is a new pesticidal substance, requiring toxicity and risk screening. Research summarized in the Project on Emerging Nanotechnologies document Silver Nanotechnologies and the Environment: Old Problems or New Challenges? shows that many nanosilver products release silver into public water treatment systems. This, in turn, presents toxicity risks to the aquatic environment. Consumer value of products containing nanosilver is great, especially in the medical field, which is all the more reason to move quickly to ensure risks are managed.
December 4th, 2008
Nanosilver on the EPA Agenda
More than six months after a petition filed by a coalition of consumer groups requesting that EPA regulate products containing nanosilver as registered pesticides and halt the sale of the products in the interim -- the agency on Nov. 19 invited public comment on the legal effort and opened the opportunity for official regulatory assessment on the risks of nanoscale silver (1).
The petition, filed May 1 by the International Center for Technology Assessment (CTA) on behalf of 13 other consumer and environmental advocacy groups, requests that EPA treat nanosilver as a new pesticidal substance, requiring toxicity and risk screening according to legal requirements under several laws including the Federal Insecticide, Fungicide, and Rodenticide Act, the Endangered Species Act, and the National Environmental Protection Act (2).
There currently are more than 200 manufacturer-identified nanosilver products on the market and contained in the online nanotechnology consumer products inventory maintained by the Project on Emerging Nanotechnologies (PEN) -- everything from baby carriages and air filters to athletic socks and coin-operated washing machines (4). Manufacturers often market these products with claims of health benefits or anti-bacterial qualities from the use of nanosilver.
Opening a docket for public comment on the CTA petition is not the first step EPA has taken this year to address nanoscale silver. Health and hygiene benefit claims in products containing nanosilver started to change after the EPA Region 9 office in San Francisco imposed in March a landmark fine of more than $200,000 on a California company selling computer keyboards and mouses coated with nanosilver (5). EPA issued the fine on the grounds that the products should have been registered under federal pesticide law because of the manufacturer's germ-killing claims. As a result, some manufacturers responded by removing health and sanitation claims and/or removing any labeling indicating the use of nanosilver ingredients (6).
The potential risks posed by nanoscale silver are complex, as Dr. Samuel Luoma pointed out in the PEN document Silver Nanotechnologies and the Environment: Old Problems or New Challenges? (7). The report highlights the fact that the form of silver used in a particular product may have varying implications on its toxicity to aquatic organisms. For example, ionic silver and non-ionic silver affect organisms differently, and nanoparticles that agglomerate, precipitate out of solution, adhere to sediments/soils, or join with other chemicals in the aquatic environment have impacts of varying degrees. Information like this makes nanosilver a hard material to analyze and points out the need to fund and oversee various types of research on its potential risks.
There is evidence that some applications of nanosilver have great promise. Silver has been used for its benefits in electronics, photochemistry, and antimicrobials (8). Silver also has photo-reactive and electrical conductivity that has made it useful for many inventions. More recently, nanosilver coatings on medical devices and implants such as artificial joints, catheters, and heart valves are showing positive results in avoiding or preventing post-procedure infections (9).
The market for such novel applications is valuable, providing even more reason to use the open docket to collect more information on the risks of nanosilver and urge the federal government to invest in risk research. In this case, ignorance is not bliss -- it is potentially very dangerous.
1) See EPA Docket at http://edocket.access.gpo.gov/2008/E8-27204.htm
2) and Federal Register at http://www.epa.gov/EPA-PEST/2008/November/Day-19/p27204.htm
3) See Press Releases on Nano-Silver at ICTA.org at http://www.icta.org/template/page.cfm?id=218
4) See the online nanotechnology consumer products inventory at http://www.nanotechproject.org/inventories/consumer
5) See "FIFRA and Fines" in the Nanotechnology Law Report at http://www.nanolawreport.com/2008/03/articles/fifra-and-fines/
6) See "Nanosilver—In Case You Forgot" in the Nanotechnology Law Report at http://www.nanolawreport.com/2008/03/articles/nanosilverin-case-you-forgot/
7) "PEN 15 - Silver Nanotechnologies and the Environment" can be found at http://www.nanotechproject.org/publications/archive/silver/
8) Ibid, page 9
9) Ibid, page 11