Tell EPA to regulate untested and unlabeled nano-silver products!

Increasingly manufacturers are infusing a large and diverse number of consumer products with nanoparticle silver ("nano-silver") for its enhanced "germ killing" abilities. At least 300 products containing nano-silver are already on market shelves, ranging from household appliances and cleaners to clothing, cutlery, and children’s toys, to personal care products, food packaging, and coated electronics.  Yet scientists agree that nanoparticles are fundamentally different substances from their larger scale cousins and that nanomaterials can create new and unique health and environmental risks that need new forms of safety testing.   

 

In May 2008 the International Center for Technology Assessment (ICTA) and the Center for Food Safety (CFS) filed a legal petition with the Environmental Protection Agency (EPA) on behalf of a coalition of public interest organizations calling on EPA to regulate nano-silver products.  EPA has broad authority over all substances intended to kill pests, including germ-killers, but it has not yet addressed the growing nano-silver market.  The legal petition demands EPA assess the safety of these materials to the public and the environment before permitting commercialization.  The petition also calls on the agency to require safety data from manufacturers and require mandatory and approved labeling.  Finally, the petition calls on the agency to stop the sale of those nano-silver products currently on the market until the agency properly assesses their impacts.

 

With at least 300 consumer products containing nano-silver already on the market, many of them marketed toward children, it is time for EPA to do its job and regulate nano-silver products. Comments are now being accepted until March 20, 2009 – please send your comment today urging EPA to grant the ICTA/CFS petition and to regulate nano-silver products!

Sample Letter for Campaign

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products

Dear [ Decision Maker ] ,

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products

I write to express my support for the ICTA/CFS legal petition, Docket No. EPA-HQ-OPP-2008-0650. I am concerned about the rapid introduction of these potentially hazardous nano-materials into our bodies and into our environment. Many products now include potentially dangerous nano-silver without any regulation or safety analysis from EPA. The government's own investigations have concluded that current research and knowledge about nanomaterials' health and environmental impacts is wholly inadequate.

The same property that makes these nanomaterials lucrative to manufacturers-their highly enhanced germ-killing action-can be highly destructive to the environment and raise serious human health concerns. The wide range of products already available is creating broad and intrusive exposures to the public and the environment. Many of the products are meant 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 very little study of nano-silver's potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent scientific studies have shown that nano-silver is even more toxic and can cause damage in new ways. A 2005 study found that nano-silver is approximately 45 times more toxic than standard silver. A 2008 study showed that washing nano-silver socks releases 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 can destroy benign bacteria used in wastewater treatment, putting the safety and quality of our water at risk.

A 2009 study (see: http://www.iop.org/EJ/abstract/0957-4484/20/8/085102/) found that nano-silver used in food storage materials, such as plastic bags and containers, can directly interact with genomes and bind with DNA, interfering with DNA replication. DNA contains the genetic information and instructions (the genome) needed for all living organisms to develop and function properly. Such DNA interference could dramatically alter the genetic makeup of cells and disrupt the normal patterns within the genome, leading to scrambled or incomplete instructions. Like a recipe with the wrong proportions, all the ingredients may be there, but if put together incorrectly the end result may not be what we expect.

These novel materials must be regulated by EPA under its pesticide authority because of their germ-killing use. The agency should GRANT the legal petition it has pending and assess the safety of these materials to the public and the environment before permitting commercialization, require safety data from manufacturers, and require mandatory and approved labeling.

Finally, the agency should stop the sale of those nano-silver products currently on the market until the agency properly assesses their impacts.

Thank you for taking my views under consideration.

Sincerely,

Campaign Launched:
February 23, 2009


Background Information

Nano-silver is a product of nanotechnology, a powerful new platform technology for taking apart and reconstructing nature at the atomic and molecular level.  While the risks of nano-silver to the environment and human health are not completely understood, studies show that the fundamental properties of matter can change at the nano-scale, creating physical and chemical properties distinct from those of the same material in traditional, bulk form.

 

Despite a recent National Research Council study concluding that regulators remain woefully behind the curve, the nanotech market moves ahead largely unabated.  Nano-silver is now the most common commercialized nano-material, but it has yet to undergo analysis by any U.S. regulatory agency of its potential human health and environmental impacts.  Human exposure and release into the environment are already occurring, yet nano-silver may be highly destructive to natural environments and raises serious human health concerns.  Studies have shown that nano-silver can harm fish and aquatic ecosystems, potentially interfere with beneficial bacteria in our bodies and the environment, encourage the development of more virulent harmful bacteria, and directly interact with our genes, interfering with DNA replication.  Silver itself is classified as an environmental hazard because it is toxic, persistent, and bioaccumulative. Aside from releasing silver, the toxicity, bioaccumulative potential, and persistence of nano-silver materials are just beginning to be known. But enough is known to be certain that risks demand urgent investigation.

 

In May 2008 the International Center for Technology Assessment (ICTA) and the Center for Food Safety (CFS) filed a legal petition with the Environmental Protection Agency (EPA) on behalf of a coalition of public interest organizations calling on EPA to regulate nano-silver products.  The legal petition demands EPA assess the safety of these materials to the public and the environment before permitting commercialization.  The petition also calls on the agency to require safety data from manufacturers and require mandatory and approved labeling.  Finally, the petition calls on the agency to stop the sale of those nano-silver products currently on the market until the agency properly assesses their impacts.

If granted, the petition would have the following results:

·      Nano-silver will be classified as a new substance and nano-silver products under EPA’s jurisdiction will be regulated as new pesticides. 

·      EPA will require current and future nano-silver products to undergo mandatory EPA pre-market approval. 

·      Current pesticide products would have to be removed from the market until and unless they received EPA approval. 

·      Approval would only occur if the agency found the products did not create an unreasonable risk to the environment. 

·      EPA would also assess nano-silver’s potential impacts on human health, particularly on children and infants, and on the environment, particularly on endangered species and their habitat.

·      EPA would require manufacturers to submit any needed data about the nanomaterials and current unknowns to conduct its assessments.

·      If any of the nano-silver products were approved and registered as pesticides, their use would be conditioned as necessary to protect the environment and human health, including the use of warning and approved labeling.

·      EPA would also amend its regulations to require nano-specific data, testing, and risk assessments for nanomaterial pesticide products.