EDF Health

EPA Nano Authority under TSCA, Part 2: “New” Isn’t Necessarily All That Better

By / Published: May 27, 2008

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 »

Also posted in Nanotechnology, Regulation / Tagged , , | Read 1 Response

EPA Nano Authority under TSCA, Part 1: It All Depends on What “New” Means

By / Published: April 22, 2008

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 »

Also posted in Nanotechnology, Regulation / Tagged , | Read 1 Response

Double Standard: Nanotech Is New! Except When That’s Inconvenient

By / Published: March 26, 2008

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

As I noted in an earlier post, the federal government staunchly maintains that regulatory agencies’ current authorities and regulatory structures are adequate.  Yet I sense quite a bit of angst — even panic — in the agencies over how they will actually address the complexities of nanotechnology under those existing authorities and regulatory structures.

The claim that laws developed long before nanotechnology came along can nevertheless manage it flawlessly smacks of a double standard:  If there’s nothing novel here, why is the federal government investing $1.5 billion annually to develop nanotechnology? Read More »

Also posted in Nanotechnology, TSCA reform / Comments are closed

What Was the White House Thinking?

By / Published: March 4, 2008

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 »

Also posted in Nanotechnology, Regulation / Tagged , | Authors: / Read 3 Responses

NNI’s new strategy: Not quite

By / Published: February 20, 2008

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

Just when you thought it might never emerge, the National Nanotechnology Initiative’s (NNI) Strategy for Nanotechnology-Related Environmental, Health and Safety Research (PDF, 2.2 MB ) finally hit the streets last week.

It’s got good, bad and ugly. The good news is that here, at last, is a report from NNI that actually reads more like a strategy and less like yet another laundry list of research needs. The bad news is that key elements of a full strategy are still nowhere to be found. Read More »

Also posted in Nanotechnology / Tagged , , | Authors: / Read 1 Response