Regulating nano-silver as a pesticide

John BalbusCal Baier-Anderson, Ph.D., is a Health Scientist.

In May 2008, the International Center for Technology Assessment (ICTA) submitted a petition to EPA requesting that it regulate nano-silver used in products as a pesticide under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  The petition calls on EPA to take the following specific actions:

  1. Classify nano-silver as a pesticide.
  2. Determine that nano-silver is a new pesticide and require its registration as such.
  3. Analyze the potential risks of nano-silver to human health and the environment.
  4. Take enforcement actions against nano-silver-containing products being sold illegally without EPA approval under FIFRA.

EDF supports this petition.  The rapid increase in the largely unregulated use of nano-silver in consumer products is alarming, especially given the lack of systematic evaluation of their possible harm to human health and the environment.

As I have explained in past posts, bulk forms of silver, while having generally low direct human toxicity, have potent anti-bacterial properties and are quite toxic to many freshwater organisms.  In a recent report on nano-silver prepared for the Project on Emerging Nanotechnologies, Dr. Samuel Luoma characterized bulk-scale silver and silver ions as environmental hazards because they are toxic, persistent and bioaccumulative under at least some circumstances.  He also concluded that insufficient information is available to predict whether nano-scale silver's hazards will be comparable to or greater than those of bulk-scale silver and silver ions.   Baker and colleagues have described how silver nanoparticles appear to have greater antibacterial potency than larger-sized particles due to their larger surface area-to-volume ratio.

Product manufacturers are seeking to capitalize on nano-silver's antimicrobial properties by adding it to dozens of products.  Many are already on the market, including nano-silver-impregnated socks and nano-silver-containing cosmetics.  That means both human contact and the release of nano-silver into the environment are already occurring, yet we are unable to predict the consequences.

So it is essential for EPA to exert its authority under FIFRA to require each manufacturer using nano-silver in a product to demonstrate that the addition of nano-silver is effective in achieving any claimed benefits, that labeling is accurate and that its use is safe for both humans and the environment.

In a November 19, 2008 Federal Register Notice, EPA has solicited comments on this petition, with the comment period recently extended to March 20, 2009.   See that notice for details on how you can voice your opinion on this important issue.

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8 Comments

  1. Maija
    Posted February 13, 2009 at 2:57 pm | Permalink

    knowing various elements present in the wrong areas of life, mercury in water for example, why delay in stopping it?

  2. Posted February 24, 2009 at 2:39 pm | Permalink

    In Iran it is batter than your country. in here on company produce a nanosilver as title Nanocid .and by a simple test on the seed corn germination give his regulate and now sale its nanosilver in different city of Iran .and nobody don’t attention the risk of this use method. You are consider about silver ions that may release from plastic or sock .but in Iran nanosilver use directly on the crop and vegetable as a fungicide.
    I am Ms.c student of plant pathology and did some test about fungicide properties of nano silver and it was not effective for controlling the fusarium disease of lentis and I will publish it as soon possible .and I say that perhaps silver can control some germ in hospital but in Agriculture system it can not be effective and it is very dangerous for Ecosystem an human health but I don’t think it can help for controlling the sales nano silver in Iran Markets ,I will be glad at last my Article could change some idea in your country

  3. Posted March 18, 2009 at 11:49 am | Permalink

    You have got to be kidding me. We have already tolerated ridiculous amounts of government intervention in our private lives. You know as well as I that this has nothing to do with silver's effect on microorganisms in the environment (in the diluted quantities present in the environment, it is harmless), but rather on a roundabout way for the federal government to regulate something that is otherwise unable to be regulated.

    I for one am sick of government babysitting me, telling me what they think is safe, and therefore forcing companies to comply with their "safe" measures.

    Government actions like this have caused un-measurable cost and deaths to the American public. Just one example: For nearly a century, government has told us to eat a low-fat, high-carb diet. Today, we have many times more overweight and obese Americans, and millions who are dying of heart disease, diabetes, alzheimer's, cancer, and other illnesses due to overproduction of insulin thanks to government's mere suggestion that we eat a low-fat, high-carb diet. Just their suggestion has led manufacturers to strip fats from products and add in carbohydrates to restore and improve taste. Imagine how much trouble we would be in if it was illegal for companies to produce food products with "too much" fat in it? Of course, it would be "for our own good". No, we've had enough government intervention in our lives, get them the heck out of it.

  4. Michael D Collins
    Posted March 19, 2009 at 5:35 pm | Permalink

    There is no scientific basis for the EPA to regulate Silver Produces as a pesticide. Another way for pharmaceutical companies to eliminate competition.

    Let's regulate antibiotics as a pesticide!!! They have far more data to support antibiotic resistance!

    Also – Nano scale covers Silver Compounds and Silver Ions. THERE IS A HUGE DIFFERENCE between a silver compound and a silver ion – but both are nanoscale.

    Silver ion products offer SIGNIFICANT health benefits, and have 100 years of use to prove it. When silver ions are delivered in solution of distilled water they do not cause argyria.

    There is no evidence that bacteria develop resistance to silver ions. See below reference.

    The EPA site discussion:
    http://www.epa.gov/iris/subst/0099.htm, CASRN 7440-22-4 states that the following "silver compounds" causing argyria are the EPA's concern.

    Silver Compounds: “In addition to silver arsphenamine, any silver compound (silver nitrate, silver acetate, argyrol, Neosilvol and Collargol, etc.), at high dose, can cause argyria. Another important factor predisposing to the development of argyria is the exposure of the skin to light.” EPA Site

    Silver Ions do not act like silver compounds!!! Silver ions generated in distilled water do not create silver compounds, only silver ions, which are safe in the body and are transported by Metallothionein (a low-molecular-weight protein ubiquitous in the animal kingdom).
    http://www.worldwidewounds.com/2004/november/Thomas/Introducing-Silver-Dressings.html#ref88
    MRSA and the use of silver dressings: overcoming bacterial resistance
    Steve Thomas
    PhD
    Director
    Surgical Materials Testing Laboratory Bridgend, Wales, UK
    Email: steve@smtl.co.uk
    Although some bacteria can develop resistance to silver [88], this is not regarded as a serious problem as available evidence suggests that most preparations capable of delivering sustained silver-ion release are effective against MRSA and VRE, and as yet no resistant strains have been encountered clinically [89]. It follows, therefore, that any silver-containing dressing that shows acceptable levels of activity against a range of non-resistant bacterial species should show comparable activity against antibiotic-resistant strains of the same organism.
    88. Russell AD, Hugo WB. Antimicrobial activity and action of silver.. In: Ellis GP, Luscombe DK, editors. Progress in Medicinal Chemistry. : Elsevier Science, 1994; 351-369.
    89. Lansdown AB. Silver. I: Its antibacterial properties and mechanism of action. J Wound Care 2002; 11(4): 125-30.

  5. USYANKEE
    Posted March 20, 2009 at 9:39 am | Permalink

    This is lobbying at its worst. Pharmaceutical companies would lose much if people knew how silver kills bacteria, viruses and fungus much better than antibiotics, even killer bugs. In biowarfare, silver can kill anthrax.

    Silver has been used for thousands of years. Our forefathers and the framers of our Constitution used silver. In fact, we had invented "silverware" because of silver's benefits.

    Soon we won't have any antibiotics which kill these superbugs. It already is occurring in hospitals, and people are dying. It is astonishing how far these people will go because of their greed. They even tried to say Vitamin C had no benefit, then when that didn't work, then they tried to make Vitamin C available only by prescription, just so they could make money on it.

  6. Kevin
    Posted March 30, 2009 at 9:55 am | Permalink

    Drugs made in the U.S. kills millions each year due to side effects and toxicity levels and I don't see the FDA regulating the drug companies that manufacture these drugs. Anything that is capable of helping the "Average Joe" gets negative reviews by these organizations. I believe a better way to regulate this issue, would be to have each of the manufacturers selling the nano silver technology checked for quality and safety assurance. This way, if they are providing a good product which is harmless (compared to some pharmaceutical drugs) then it should continue.

  7. Posted April 19, 2009 at 9:05 am | Permalink

    Hi guys.
    First of all i want to thank Cal Baier-Anderson for this article and i just want to say :Guys this is science on it's way to completion and it needs it's cost.I mean i know this is not the best hopeful reality in the world but this is what it is and nobody knows what will happen in the feature.In this way i prefer to help the scientists to make their way and a Better Understanding of Global Warning, to do make it better.I would do that because in Iran we say "every body can discover everything together"

  8. jay
    Posted May 13, 2009 at 10:02 am | Permalink

    dear EDF where do you get your FUNDING??? i think this question will answer why you have the view that you due based on no scientific data.. benifits are not even mentioned .. this article is poorly written and oneside. propaganda at its finest..

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