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When nano turns washing machine into pesticide

Saturday, December 9, 2006

The EPA's nanosilver regulation still attracts me, as it reflects how a regulation that was initially intended to regulate pesticide can now be extended into device such as the samsung washing machine. As we have previously discussed, the EPA is investigating if the silver ions released by nanosilver appliances can kill friendly bacterias and harm human.

There has been news and post suggesting that the background of the regulation is unfounded since:
  1. People has been using silver appliances for ages (Yeah, for sure. But the problem with nanotoxicity is that, the behaviours and characteristics of nanoparticle of silver is different than its bulk form, right? Or is it the case that the old ages silver are already "nano" in essence?)
  2. The effect of silver in drinking water is cosmetic. (Does that apply to common silver or nanosilver?)
  3. Nanosilver ions bonds with chlorine and are inert.
  4. Other pharmaceutical that kills germs are flushed out of toilet every year, but they are not subjected to regulation
  5. There are so many nanomaterials out there, but why only regulate silver?
  6. Alternative anti-microbe such as Triclosan, which may be contained in Microban products is not regulated.
To Howard Lovy, nanosilver nay not be nanotech at all, it is simply "...nanoscale stuff being sprinkled into products". If we talk about jurisdiction, the EPA does have all the power to regulate anything that kills germs as "pesticide". The FIFRA seemed to take account only towards its effect. Whatever it is outside medicines, if it kills germs, its pesticide. The problem is, which one is more dangerous to the environment, triclosan from my toothpaste or some nanosilver coating?

Seeing the EPA revoked its previous decision, it is likely that they are of the opinion that the ions released by the nanosilver washing machines pose a threat to the environment and will therefore require a pesticide registration.

The moral message of the case:
  1. Effect-focus regulation can incorporate as many as nanotech product it deems necessary, so long as the effect is triggered (e.g. the effect is killing germs). The pros: broader preventive measure. The cons: overbroad interpretation, can include anything. On the other hand, some effect focused regulation constructed in bulk-scale chemicals paradigm (Referenced Dose, parts per million, etc) may be useless for nanotech.
  2. Interrelated and overlapped regulation may occur due to nanotech inventions. If today a washing machine is a pesticide, maybe some kind of lamps would be drugs tomorrow.
  3. Process-focused regulation is more precise, but not much can be constructed due to lack of nanotoxicology data.
  4. What you regulate today maybe obsolete in a few years. The tech progressed too fast, beyond our current capacity to legislate.