Citizen Petition for Regulation of Nano-Silver
This post was written by Christopher Rissetto, Stephanie Giese and Areta Kupchyk.
In response to the influx of products engineered using nano-silver in the consumer marketplace, the International Center for Technology Assessment (“CTA”), in conjunction with a number of other consumer groups, filed a self-styled Petition For Rulemaking To The United States Environmental Protection Agency (“Petition”) on May 1, 2008. The Petition, citing to the rulemaking provisions of the Federal Administrative Procedure Act (“APA”) and other statutes, calls for the review and control of some 260 nano-silver products, most specifically through the regulatory process under the Federal Insecticide, Fungicide, and Rodenticide Act (“FIFRA”). In the Petition, CTA claims “nanomaterials present serious toxicity risks for human health and ecosystems” and asserts that “nano-silver has quickly become the most commonly used nanomaterial in consumer products.” The scattershot but substanti-ated approach of the Petition, combined with its prior administrative filings, and recent Environmental Protection Agency (“EPA”) enforcement and rulemaking actions, could well lead to future federal efforts to control nano-silver products.
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