Richard Denison, Ph.D., is a Senior Scientist.

For the past several years, EDF has been in the thick of discussions about whether the Toxic Substances Control Act of 1976 (TSCA) needs reform and, if so, what form it should take.  Happily, the former question has largely been answered:  With only a few remaining holdouts, even the chemical industry acknowledges the time has come.  So now we can move on to what such reform should look like – and what it should not. Read more »

Richard Denison, Ph.D., is a Senior Scientist.

You may have noticed some subtle changes to the look of this page.  That’s because EDF has decided to expand the focus of this blog to include the policy, legislative, regulatory and scientific issues surrounding the health and environmental impacts of chemicals, as well as nanomaterials. Read more »

Richard Denison, Ph.D., is a Senior Scientist.

In a previous post, I argued that the European Union’s REACH Regulation for chemicals goes a long way to address the regulatory needs for nanomaterials – despite the fact that REACH never mentions nano and was not developed with nano in mind.  I also noted, however, that REACH will clearly need more than fine-tuning to ensure adequate nano oversight.  Apparently at least some in the European Parliament agree.  Read more »

Cal 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. Read more »

Richard Denison, Ph.D., is a Senior Scientist.

It had to happen sooner or later. After several years spent by the UK and US governments conceptualizing, vetting, proposing, again vetting, developing, yet again vetting, and finally launching and reporting on their voluntary reporting programs for engineered nanoscale materials – only to have them largely spurned by the intended targets – other governments observing all this have decided that mandatory approaches are needed. Read more »

Richard Denison, Ph.D., is a Senior Scientist.

It’s been nearly a year since EPA launched its voluntary Nanoscale Materials Stewardship Program (NMSP) – and over three years since EPA was urged, by a diverse group of stakeholders, to do so only in conjunction with the development of mandatory reporting rules as a backstop and to limit the duration of the basic part of the program to at most six months.

EPA ignored that advice, and proceeded with an open-ended voluntary program and no development of backstop rules.  Now EPA has issued its first evaluation of the NMSP.  So what did EPA find? Read more »

Cal Baier-Anderson, Ph.D., is a Health Scientist.

Can nanoparticles get into our drinking water and if so, what’s the harm?

Nanoparticles are being used in cosmetics and other personal care products with increasing frequency.  Carbon fullerenes, also known as buckyballs, have recently been touted as imparting age-defying antioxidant benefits when added to skin cream.  And there are some studies that seem to support these claims.  But even if such claimed benefits turn out to be true, this is by no means the end of the story.  Read more »

Richard Denison, Ph.D., is a Senior Scientist.

My last post identified two Section 8(e) “substantial risk” notices pertaining to carbon nanotubes, one submitted by BASF, the other by Arkema.  I have in my files one additional Section 8(e) notice for a single-walled carbon nanotube (SWCNT), submitted by DuPont.  With three Section 8(e) notices submitted for different rat pulmonary toxicity studies on carbon nanotubes, it’s interesting to compare their results. Read more »

Richard Denison, Ph.D., is a Senior Scientist.

Section 8(e) of the Toxic Substances Control Act (TSCA) requires any company that manufactures, imports, processes or distributes chemicals in the U.S. to notify EPA within 30 days if it obtains new information that “reasonably supports the conclusion that such substance or mixture presents a substantial risk of injury to health or the environment.”  Are there Section 8(e) notices for nanomaterials? Read more »

Richard Denison, Ph.D., is a Senior Scientist.

Since my first post concerning EPA’s Consent Order, I’ve been reflecting further on the management conditions it imposes – or, more accurately, on what conditions it doesn’t impose.  The Order’s only such conditions address potential worker exposure.  What about the rest of the nanomaterial’s lifecycle? Read more »