Nanosilver (Particles) to be regulated by the EPA as a Pesticide?

In May of 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. The petition calls for the EPA to regulate nano-silver products as pesticides.  The legal petition requests that EPA assess the safety of these materials to the public and the environment before permitting them to be marketed.  The petition also calls on the agency to require safety data from manufacturers, to require mandatory and approved labeling, and last demands that the agency stop the sale of nano-silver products currently on market until the agency can properly assess their impacts.

Nanosilver - What is it?

A nanoparticle refers to any particle sized between 1-100 nanometers. This includes nearly all products on the market currently being sold as "colloidal silver", as well as numerous silver containing products being sold ( such as socks and anti-microbial mats ) as consumer goods.

Special Interest Action Groups Petition:
Nanosilver Particles - A Danger to the Environment?

The following organizations are listed as petioners, who claim that nanosilver particles are a danger to the environment:

• International Center for Technology Assessment (CTA)
• Center for Food Safety (CFS)
• Beyond Pesticides
• Friends of the Earth (FOE)
• Greenpeace
• Action Group on Erosion, Technology and Concentration
• Center for Environmental Health (CEH)
• Silicon Valley Toxics Coalition (SVTC)
• Institute for Agriculture and Trade Policy (IATP)
• Clean Production Action (CPA)
• Food & Water Watch
• Loka Institute
• Center for the Study of Responsive Law (CSRL)
• Consumers Union

The Real Target: Emerging Nanotechnologies

The attack on silver is the first exploratory step in a general assault on all non-regulated nanotechnology and nanoparticle products currently on the market. Silver is simply one of the first targets.

The ITCA states:

"Nanotechnology is the science of engineering on a molecular scale, in effect building matter atom-by-atom from the "bottom up." The prefix "nano" denotes a fraction of one-one billionth, and nanotechnology involves the construction of matter a billionth of a meter in size: roughly the size of several atoms. This developing industrial process would use microscopic machines, themselves only slightly larger than the products being constructed, to assemble atoms into precisely designed molecules. These nanotech machines would be capable of repairing and replicating themselves. In essence, they would become never-before-seen, manmade life forms."

"...CTA seeks to halt the commercialization of nanotechnology until products containing nanoparticles have been proven safe. CTA also seeks to force federal regulatory agencies to adopt an accurate and standardized definition of nanotechnology and to regulate emerging nanotechnologies as they would other materials whose safety has not been determined."

New York Times:
"Silver has been present in the environment as an antiseptic
far longer than humans have existed"

"With no evidence so far that nanotech is actually damaging anyone, they are focusing on the materials most widely used in consumer products and doing their best to worry the public — and government officials — about potential hazards that have yet to be thoroughly researched.

"The two groups of materials most often spotlighted in this strategy are nano-scale pigments, which are used in sunscreens and cosmetics, and nano-silver particles. The silver is already used in more than 200 consumer products to kill germs, according to some tallies. Silver has been present in the environment as an antiseptic far longer than humans have existed, but there are indications that manmade, nanoscale silver particles are more lethal to microbes — including beneficial microbes."

- Barnaby J Fetter, "No Silver Bullets", New York Times, May 6, 2008

Fear Mongering with no Real Science

"Silver is highly toxic to aquatic life at low concentrations and also bioaccumulates in some aquatic organisms, such as clams."

- Chuck Weir, chairman of Tri-TAC, a technical advisory group for wastewater treatment plants in California.

However, this purposefully misleading statement is quickly debunked by George J. Maass, Phd., chief chemist for Colloidal Science Laboratory:

"Nanoparticles are difficult to produce; they are difficult to stabilize once they have been produced; they are not stable enough to exist in nature for very long."

"... the high biological effectiveness of colloidal silver does not persist in nature because the nanoparticles agglomerate as soon as they come in contact with the environment, specifically soil and water."

- George J. Maass, Colloidal Science Laboratory

The paper written by Maass may be downloaded in full at their website:
http://www.silver-colloids.com/Papers/SilverNoThreat.pdf

Special Interest, Not Public Interest
Business as Usual in Washington

It is obvious that the position that the petitioning organizations are taking are biased and completely self serving. This is just one more example of Washington style politics as usual.

Many readers are no doubt flabbergasted by the following irony: While the FDA has attempted to discredit silver as being completely uneffective, the EPA is considering regulation due to the position that silver is far too effective. Well, which is it?

In actuality, neither.

While the FDA and the EPA consistantly bow down to special interest concerns, real scientific investigation reveals exactly what Dr. Maas stated in his response article:

Oligodyamic, isolated colloidal silver is an extremely effective antimicrobial, but only for a very short period of time. Silver nanoparticles and isolated silver ions, when produced properly, easily have a shelf life of decades if stored adequately. However, once the silver comes in contact with the environment, its antimicrobial action is short lived.

Therefore, the true public concern should obviously be limited to massive amounts amounts of nanosilver being dumped into an aquatic environment. In other words, it should be illegal to dump a thousand gallons of 15 PPM colloidal silver into a lake every day, but silver poses no real risk to the environment from even aggressive human use-- even if used on a large scale by the general public.

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