Showing posts with label nanomaterials. Show all posts
Showing posts with label nanomaterials. Show all posts
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Wilson center issued a report on handling Nanowaste

Friday, July 27, 2007

The institutional capacity for handling nano waste is put under scrutiny. Wilson Center adresses the issue:

A new report from the Project on Emerging Nanotechnologies, Where Does the Nano Go? End-of-Life Regulation of Nanotechnologies, addresses these issues. Authored by Linda K. Breggin and John Pendergrass, legal experts from the Environmental Law Institute (ELI), the report presents the most comprehensive analysis to-date of two key Environmental Protection Agency laws that regulate the end-of-life management of nanotechnology. These are the Resource Conservation and Recovery Act (RCRA), and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), also known as the Superfund statute.

The report is timely. Today, there are over 500 company-identified nanotechnology consumer products on the market, all of which will sooner or later be disposed of. These products can be seen in an online inventory maintained by the Project on Emerging Nanotechnologies. This inventory does not include nanotech products being sold but not identified as such, or the hundreds of nano raw materials, intermediate components, and industrial equipment items used by manufacturers today.

The webcast and report is downloadable here.

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EPA's Nano Program -- open for public comment

Saturday, July 14, 2007

EPA has issued Federal Register (FR) notices seeking public comment on a concept paper and other materials related to its Nanoscale Materials Stewardship Program.

The debate still hovers around the issue if nanomaterials are to be considered as a 'new' material under the TSCA. J.C. Davies said:
“The agency’s current practice is inadequate to deal with nanotechnology. It is essential that EPA move quickly to recognize the novel biological and ecological characteristics of nanoscale materials. It can do this only by using the ‘new uses’ provisions of TSCA, a subject not mentioned in the EPA’s inventory document. With the approach outlined by EPA and because of the weaknesses in the law, the agency is not even able to identify which substances are nanomaterials, much less determine whether they pose a hazard.”
EPA also issued papers for public comment on Nanoscale Materials Stewardship Program (NMSP)—in order to encourage industry to provide a voluntary scientific information about the risk management practices currently applied.

The EPA's official website on the program is here. Project on Emerging Nanotech website containing a March 2007 Report (titled Nanotech: Oversight for 21st Century) plus a webscast is available here. To get a glimpse on the application of TSCA to nanomaterials, read a March 2007 paper from Lynn L Bergeson here. You might also want to read Scott Deatherage's discussion in his blog on this issue here.

H.T: Gregor Wolbring

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EU's "incrimental approach" in regulating nanomaterials

Thursday, June 28, 2007

We've had discussions on the Berkeley's regulation and I have posted some articles on EU's REACH. Here's an article explaining existing EU's regulatory infrastructure applicable to nanomaterials/nanoparticles and its weaknesses:
The European Commission has adopted a so-called ‘‘incremental approach’’, which focuses on adapting existing laws to regulate nanotechnologies, and therefore this paper aims to test the effectiveness of the ‘‘incremental approach’’. Three commercially available products containing fullerenes (C60 and carbon nanotubes) were analysed in a life cycle perspective in order to (1) map current applicable regulations, (2) analyse their applicability to nanomaterials, (3) identify their gaps, and (4) suggest proper solutions.
Read the full paper here.

My general observation: the paper still based itself on "emission" paradigm. Thus, the playing field is in the lowering of permissible emission. An important point here is that the paper suggested "free nanoparticles" to be exclusively categorized under the REACH and that it should be specifically registered. Interestingly, the paper recommends bottom-up nanoparticle to be regarded as "new substance".

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Environmental Defense and Du Pont Launched Nano Risk Framework

Tuesday, June 26, 2007

Webcast of the Nano Risk Framework is available at the Woodrow Wilson International Center for Scholars here.

Here's a glimpse of the "Framework":

The Nano Risk Framework is designed to be a comprehensive, practical and flexible tool for documenting and communicating the steps a user has taken to evaluate and address potential risks of nanoscale materials. The Framework offers guidance on the key questions an organization should consider in developing applications of such materials, and on the critical information needed to make sound risk evaluations and risk management decisions.

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Precautionary Principle Urged (Again?)

Friday, June 15, 2007

A news from the EU (but it turned out to be not so new):
"Current scientific risk-assessment methods [for nanomaterials] are really not reliable. We don't have the knowledge. Nanomaterials are so small and reactive and we don't have natural defences in the body against them," said Eva Hellsten, from the Commission's DG Environment, Directorate Water, Chemicals and Cohesion.
EU are still debating as to whether nanomaterials/nanoparticles would be sufficiently regulated in its REACH directive. To sum up, their position on regulating engineered nanoparticles remans the same:
1. IS REACH enough or not?
2. We don't have "sufficent knowledge"
3. More money required for research
4. Precautionary Principle vs 'non' Precautionary Principle

So in this part of nanotech regulation, there is really nothing new in any part of the world. Boring!

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Compliance towards Berkeley's Nano Regulation

Wednesday, June 6, 2007

From the Berkeley Daily Planet:

By the June 1 reporting date the only business following the formal reporting procedure was Bayer Laboratories, according to Toxics Manager Nabil Al-Hadithy. The other two local users of the technology, UC Berkeley and the Lawrence Berkeley National Laboratory (LBNL) responded, but did not include the specific data required by the ordinance.

“I am especially disappointed because LBLN has been engaged in the process [of writing the reporting procedures] for two years and has failed to implement it,” Al-Hadithy said.

The policy requires companies working with engineered nanoparticles—materials one of whose axes is 100 nanometers or less (a nanometer is one-trillionth of a meter)—to submit a report disclosing the toxicology of the nanoparticles used and “how the facility will safely handle, monitor, contain, dispose, track inventory, prevent releases and mitigate such materials,” says the city ordinance.

For my previous post on this issue and my discussion with N. Hadithy with regards to the content of the Berkely regulation, click here and here.

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Weak regulation on cosmetics a time bomb

Thursday, February 22, 2007

Voluntary regulatory system in US cosmetic industry can be a time bomb:
Now, new nanotechnologies are being widely deployed in cosmetics products, despite evidence of serious potential health risks. Moreover, the physical application of some of the nanotechnologies to the body in cosmetics makes these uses uniquely prone to skin penetration, inhalation and ingestion of the nanotech materials.

List of cosmetics using nano products:
  • Penetration enhancer - Encapsulating or suspending key ingredients in so-called nanospheres or nanoemulsions, increases their penetration into the skin
  • L’Oreal (which ranks No. 6 in nanotechnology patent holders in the U.S.) 75 has used polymer nanocapsules to deliver active ingredients, e.g. retinol or Vitamin A, into the deeper layers of skin. In 1998 the company unveiled Plentitude Revitalift, an anti-wrinkle cream using nanoparticles.
  • Freeze 24/7, a new anti-wrinkle skincare line is planning to incorporate nanotechnology in future products.
  • La Prairie’s product, the Dollars 500 Skin Caviar Intensive Ampoule Treatment, claims to minimize the look of uneven skin pigmentation, lines and wrinkles in six weeks using nanotechnology. La Prairie’s vice president of retail marketing and training, Holly Genovese, says the nanoemulsions in the product “optimize the delivery of functional ingredients into the skin and allow these materials to get to the site of action quicker”.
  • Procter & Gamble’s Olay brand was designed with nanoemulsion technology in 2005.
  • Other companies using nanotech in their skin products as of 2005 include: Mary Kay and Clinique from Lauder; Neutrogena, from Johnson & Johnson; Avon; and the
  • Estee Lauder brand.
  • Hair products – using nanoemulsions to encapsulate active ingredients and carry them deeper into hair shafts.
  • PureOlogy began experimenting with nanoemulsions in 2000 when the company’s founder set out to create a product line especially developed for color treated hair.Sunscreens – the zinc and titanium in sunscreens are “micronized”, making them transparent, less greasy, less smelly and more absorbable into the skin.
  • DDF planned more nanotech-enhanced anti-aging products as of 2004.
  • Colorescience markets a product named Sunforgettable, a powder which contains titanium dioxide nanoparticles.
  • Paris-based Caudalie launched its Vinosun Anti-Aging Suncare, a sunscreen and anti-aging treatment that relies on “nanomized” UV filters and antioxidants, in the US in 2003.
I guess although the heading is "cosmetic", when nanoproducts are used, examination mechanism shall not be voluntary. Download IEHN report here.

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Nanotech will affect every regulations within five years.

Sunday, December 17, 2006

I mean what I say and I say what I mean.

Do you know why EPA bothers regulating a washing machine? It's because it contains tiny beene silver nanoparticles that can kill germs. Hell, it may even be the most primitive form of nanotech but look at its impact, they are declaring washing machine as pesticide!

Do you know that silver nanoparticles has been used in underwear, shirts, paint, deodorant, mineral supplement, toothpaste, liquid condom, refrigerator, vaccuum cleaner, ink, porcellain, make up, soap, rubber gloves, dental LED, dishwashing liquid, baby milk bottle, door handle, handy coating and air conditioner? Of course, not all of them will be categorized as pesticide!

Not only that we are only talking about a primitive use of nanotechnology, we also "only" talk about silver nanoparticles. There are still plenty other nanoparticle which its usage is still unknown. That's not all, this has not include "passive" nanostructures such as carbon nanotube, which will be used in transistors, computer hardware and medical appliances.

Nanotech market is going to be bullish in the next two years. Some even predicted that within a decade, people will no longer use the word "nanotechnology" because "Today's 'nano materials' are tomorrow's 'materials.'

The good news is (I mean, for lawyers) the regulation is still unclear and the risks associated with it is also unclear. This means not only more lawsuit but also more deals. So, let's catch up...

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EPA's first nanoproduct-focused regulation

Thursday, November 23, 2006

The press and the blogosphere have been echoing EPA's new nanoproduct-focused regulation. Yes, EPA has decided to "regulate" silver nanoparticles used in various consumer products such as high-tech odor-destroying shoe liners, food-storage containers and air fresheners. The silver nanomaterials are used to kill germs. However, there are worries that they will harm beneficial bacterias:
Until now, new products made with tiny germ-fighting particles of silver did not have to pass muster with regulators. That has concerned environmentalists and others who think that the growing amount of nanosilver washed down drains may be killing beneficial bacteria and aquatic organisms and may also pose risks to human health.
Companies using silver nanoproducts will have to prove to the EPA that their product is safe. According to WP:
Under the new determination, first reported on Tuesday by the Daily Environment Report, a Washington publication, and confirmed yesterday by the EPA, any company wishing to sell a product that it claims will kill germs by the release of nanotech silver or related technology will first have to provide scientific evidence that the product does not pose an environmental risk. "We will be able to evaluate them and ensure that these products are not going to do damage to the aquatic environment," said Jim Jones, director of the EPA's Office of Pesticide Programs.
I have not really seen the so-called "regulation" so I am not able to give my analysis here. However, there are several questions that can be asked:
  1. What will happen to products already on the market? Does this apply retroactively? Do they need to be suspended pending the scientific findings?
  2. Does this mean that it shifts the burden of proof from EPA to producers? Supposed EPA declared that a product is OK, but then someday something happens to the product (i.e. it turn out to be harmful for the environment) to what extent would the producer be liable for the product, either under environmental, health or consumer law?
  3. Since it deals with nanosilver, is it OK to cover similar products in a single exam? Scientific assessment may raise the burden of cost for the industry, if there is a product that is more or less similar, it could be economical to cover them in one assessment, rather than doing multiple assessment. To what extent will this be regulated?
  4. What are the relationship between this regulation and other regimes?