New Report on EPA and Nanotech - just what I've been waiting for!

For those of us concerned with health and environmental impacts of new and old chemicals, the production and use of nanomaterials presents a fascinating opportunity to consider and then reconsider the mechanisms by which chemicals are tested and controlled in the United States. While I've been trying to keep up with the toxicology of nanomaterials, I've wondered about the adequacy of our current regulatory framework to evaluate and manage these materials. Fortunately for me and anyone else wondering the same thing, a recent report by Dr. Terry Davies entitled EPA and Nanotechnology: Oversight for the 21^st Century opens the door for us, by reviewing the principle laws and regulations developed to manage and control chemicals and considers the effectiveness of their application down in Whoville, where all things are nano.

As Davies notes, “In a few decades, almost every aspect of our existence….is likely to be changed for the better by nano. However, if the potential for good is to be realized, society must also faces nano’s potential for harm.”

One of the primary issues for toxicologists investigating nanomaterials, is my favorite, “It’s hard to find what you don’t know you’re looking for,” or it’s pretty difficult anyway…unless one is trained to expect the unexpected. And it seems that nanomaterials have the potential to behave quite differently not only from their non-nano counterparts, but also from different formulations of the same material. In some cases, as Davies notes, contrary to current underlying toxicological concept that smaller doses tend to be less toxic (in general – there’s a whole ‘nother discussion to be had about hormesis – the differential behavior of some chemicals at very low concentrations) in some cases nanomaterials may behave differently and potentially more toxic when present in lower concentrations than their non-nano counterparts. Just that issue alone has the potential to turn our current toxicity testing, assessment and regulatory practices upside down when it comes to nanomaterials!

But really the focus of Davies report is the “so what” question. Given where we are now – in terms of understanding the potential health and environmental impacts of these materials – what can be done in terms of regulation and management? As Davies points out, while some of EPA’s programs, as they are now, may provide adequate oversight of nanomaterials (he cites FIFRA – which has jurisdiction over all pesticides – as a program that has “strong legal adequacy” when it comes to nanomaterials) TSCA, the Toxic Substances Control Act, which has the greatest potential to cover the most nanomaterials, is “particularly deficient” for a number of chemical oversight functions. According to Davies “the Act desperately needs to be amended, both to deal with nano and to adequately address all types of chemicals.”

This is an informative and readable report, and if you’re at all interested in nanomaterials, you might want to take a look.

The full report is available free and online through the Project on Emerging Nanotechnologies, an initiative of the Woodrow Wilson International Center for Scholars and the Pew Charitable Trusts, www.nanotechproject.org.