I don't think this is anything new. I contacted the EPA some time ago
about selling aspartame as an ant poison and was told that it could not
be sold labeled that way since it was not proven safe. But they still
allow tons of it to be used in products. Also EIS is typically 90%
ionic, which is not being addressed, so likely it would be nothing more
than a labeling issue.
Marshall
Steven Foss wrote:
Dear Silver List,
Here are some links to websites on this issue. The CTA and FOE (Center for
Technology Assessment and Friends of the Earth) are making a big issue over
Nano Technology.)
However, in the case of the CTA the Nano Technology is only Silver, and the hit list contains a number of bottle Colloidal Silvers including Sovereign Silver and Meso Silver among Silver Socks and Cosmetics, etc.
I do not think that your generators would be confiscated, nor will there be
door to door searches. However, if you have any plans of purchasing additional
Colloidal Silver Generators after the EPA ruling you may be disappointed. The
Colloidal Silver Generator may go the way of the Rife Machine. It is illegal to
purchase a Rife Machine in California.
For those who inquired about not finding information on the EPA website, the federal government generally does not list lawsuits against them.
There are a number of pages at the EPA about Nano Silver and pesticides:
http://www.epa.gov/pesticides/about/intheworks/nanotechnology.htm
"Any product containing silver – in any form – that makes claims to control pests
(kills bacteria or fungi, my addition) must first be evaluated and registered by EPA to
ensure it meets the FIFRA human health and environmental safety standards before it can
be distributed or sold."
http://epa.gov/oppt/nano/
EPA is actively participating in the Working Party and contributes to all of
the projects. Of particular relevance to the in-depth portion of the Agency's
Nanoscale Materials Stewardship Program (NMSP) is the project on Safety Testing
of a Representative Set of Manufactured Nanomaterials. The WPMN has identified
a representative list of manufactured nanoscale materials for environmental
health and safety testing, including: silver nanoparticles
The WPMN has also published a list of testing endpoints in the following
areas:
nanomaterial information/identification
physical-chemical properties
material characterization
environmental fate
environmental toxicology
mammalian toxicology
material safety
You will find in the links below that the CTA website www.nanoaction.org states
that the petition (suit) against the EPA started in May 2008.
The CTA action states Nano technology but their focus is nano silver which
includes Colloidal Silver. The EPA has until March 2009 to make its ruling.
Quick background
The EPA using the The Federal Insecticide, Fungicide, and Rodenticide Act (or FIFRA) of 1947,
ruled that Silver particles are a pesticide using the the definition of antimicrobials contain with
that act. They have also ruled that Colloidal Silver Generators which produce Silver Ions and is
listed for sale as producing a substance capable of killing microbes is also a
"pesticide" in essence, "nano silver pesticide devices." The EPA ruled over
they had jurisdiction to regulate Sammsung Washing Machine that incorporated a small Generator to
add Silver Ions to kill bacteria in the wash water. More recently they had issues with a computer
company and its claims of nano silver (I can't recall if it was silver on the keyboard.)
Not to be outdone, the Friends of the Earth (FOE) is circulating petitions to the FDA for the removal nanotechnology in cosmetics, as well.
The size range for nanotechnology is definitely
in the Colloidal Range.
http://nanotech.lawbc.com/2008/05/articles/legalregulatory-issues/ictaled-coalition-petitions-for-fifra-regulation-of-nanoscale-silver-products/
ICTA-Led Coalition Petitions for FIFRA Regulation of Nanoscale Silver Products Posted on May 7, 2008 by Lynn L. Bergeson
On May 1, 2008, the International Center for
Technology Assessment (ICTA), together with 13 other consumer, health, and
environmental groups, filed a petition
with the U.S. Environmental Protection Agency (EPA) demanding that EPA regulate as pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and that it take additional actions under FIFRA and other environmental statutes concerning, consumer products containing nanoscale silver. ICTA also released an inventory
(http://icta.org/nanoaction/doc/CTA%20Petition%20Appendix%20A_nano-silver_product_inventory.pdf) of the nano silver-containing consumer products referenced in the
petition.
The petition contends that nano silver is “the most commonly used
nanomaterial in consumer products and the fastest growing sector of nanomaterial commercialization,” and that most companies “market
their nano-silver products [by] putting emphasis on the nano-silver ingredient, touting its antimicrobial and antibacterial qualities . . . .” The petition states that “research has mounted to indicate that nano-silver materials pose serious
risks to human health and the environment.” In support of the petition, the
ICTA-led coalition pointed to, inter alia, EPA Region 9’s recent FIFRA
enforcement settlement with a California company, IOGEAR, that had been making
antimicrobial claims for the nano silver coating on computer accessories it was
marketing.
The petition requests that EPA take the following actions:
Clarify that nano silver and
products containing it are pesticides requiring registration under FIFRA;
Classify nanomaterial pesticides such
as nano silver as new pesticides [i.e., new active ingredients]
that require new registrations, with nano-specific toxicity testing and risk
assessment;
Assess the potential human
health and environmental risks of nano silver under FIFRA, the Food Quality
Protection Act, the Endangered Species Act, and the National Environmental
Policy Act;
Take immediate action, including the issuance of
Stop Sale, Use, or Removal Orders, to halt the sale of nano silver products with
unapproved antimicrobial claims;
Fully apply all FIFRA regulations in the event EPA
registers any nano silver products; and
Utilize its FIFRA authority to
further review the potential human health and environmental impacts of nano
silver, including undertaking either a classification review or a Special
Review, amending the FIFRA regulations to require as part of a registration
application the submission of nanomaterial and/or nano silver-specific data,
undertaking a registration review of existing bulk silver registrations,
regulating nano silver pesticide devices, and establishing a tolerance for nano
silver under the Federal Food, Drug, and Cosmetic Act.
"Regulating nano silver pesticide devices" translates regulating Colloidal
Silver Generators.
http://www.icta.org/nanoaction/doc/CTA_nano-silver_press_release_5_1_08.pdf
http://www.nwrage.org/index.php?name=News&file=article&sid=2208
http://www.nanoaction.org/detail/news.cfm?news_id=205&id=244
http://www.newmediaexplorer.org/sepp/2006/12/07/nano_silver_kills_microbes_epa_up_in_arms.htm
http://www.icta.org/nanotech/index.cfm
http://www.foe.org/camps/comm/nanotech
http://www.nanotechproject.org/file_download/files/PEN2_MngEffects.pdf
http://icta.org/nanoaction/doc/CTA%20Petition%20Appendix%20A_nano-silver_product_inventory.pdf
Steve Foss
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