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
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 was going to be the last post in my series on the fate of nanomaterials under the Toxic Substances Control Act (TSCA), where I turn to what will likely be – at least in the near term – the most common regulatory scenario that will apply: the extent to which EPA has authority to regulate nanomaterials as “existing” chemicals under TSCA. But there’s so much to cover that I’ve decided to split this last topic into three separate posts. 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]
In my last post, I decried EPA’s shortsighted decision to declare nano forms of chemicals listed on the Toxic Substances Control Act (TSCA) Inventory to be “existing” rather than “new” chemicals. But I noted that EPA did not rule that all nanomaterials are existing chemicals. EPA says it will consider buckyballs, carbon nanotubes, or anything else that has no counterpart – a substance with the same chemical structure – already on the TSCA Inventory to be “new.” So can we rest assured that, at least for these nanomaterials, EPA has sufficient authority under TSCA to effectively identify and address their potential risks? Would it were so. 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]
In this and my next two posts, I want to explore the question of whether EPA has sufficient authority under the Toxic Substances Control Act (TSCA) to effectively oversee nanotechnology. EPA (as well as the White House) maintains that the agency has ample statutory authority to do what’s needed to identify and address any potential risks nanomaterials may pose to consumers, the general public and the environment. I beg to differ. Read More
Richard Denison, Ph.D., is a Senior Scientist.
It’s been a few months now since the White House took the unusual step of articulating some “Principles for Nanotechnology EH&S Oversight.” Given recent events, it’s worth again reflecting on this official memorandum, which was signed by the heads of the White House’s Council on Environmental Quality (CEQ) and Office of Science and Technology Policy (OSTP) and sent to the heads of all federal agencies and departments.
Despite the title, it’s very hard not to read this document as one intended primarily to throw up barriers to effective oversight. Read More
