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
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.
EDF’s recent news release that gave a less-than-glowing review to the performance of EPA’s Nanoscale Materials Stewardship Program (NMSP) engendered a critique from Michael Heintz of Porter & Wright, accusing us of being “irresponsible” and potentially “sector damaging.” Our release had lamented the mediocre level of participation and lack of transparency surrounding the NMSP. I’ve posted a reply to Michael’s post, but also want to post it here. Read More
Richard Denison, Ph.D., is a Senior Scientist.
[Links to posts in this series: Part 1, Part 2, Part 3, Part 4, Part 5]
This final post in this series goes to the ultimate question, where the nanorubber really hits the road: Can EPA regulate an “existing” nanomaterial’s production, use, or disposal under TSCA? Read More
Richard Denison, Ph.D., is a Senior Scientist.
[Links to posts in this series: Part 1, Part 2, Part 3, Part 4, Part 5]
Let’s now turn to dissecting just how limited EPA’s authorities are both to collect information that companies already possess on their nanomaterials, and to require companies to generate and submit new information. Read More
