Nanotechnology: Improve Regulatory Policy

Posted: 18-Sep-2007; Updated: 21-Feb-2008

Government needs to provide for the comprehensive management of those risks that are identified—from a full life-cycle perspective, taking into account worker safety, manufacturing releases and wastes, product use and product disposal.  Government needs first to exert its existing authority to more effectively address nanotechnology risks in the near term.  An objective assessment is also needed to identify and address gaps in existing regulatory programs.

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• "Too Little, Too Late" - Environmental Defense's public statement [PDF] and final comments [PDF] submitted to the U.S. Environmental Protection Agency on its proposals to develop a Voluntary Nanoscale Materials Stewardship Program, in which we call on EPA to act much more aggressively to protect the public and the environment from the potential risks of engineered nanoscale materials. We urge EPA to rapidly develop and implement mandatory reporting rules in lieu of a voluntary program, and to designate nano forms of bulk chemicals to be "new" chemicals under the Toxic Substances Control Act (TSCA). (9/07)
   
• Summary of Environmental Defense's response [PDF] to a recent American Bar Association paper, in which we explain why nanomaterials should be considered "new" chemicals subject to EPA review before commercialization, even if their chemical structures are the same as existing chemicals already on the TSCA Inventory.  We presented our response at a briefing held with EPA staff.  (8/06)
• Letter from Environmental Defense to U.S. EPA [PDF] addressing why engineered nanomaterials should be considered "new" chemical susbtances under the Toxic Substances Control Act (5/06)
• Letter from Environmental Defense to U.S. EPA [PDF] addressing the Toxic Substances Control Act and nanotechnology issues (9/04)  
• Environmental Defense's presentations at the Environmental Law Institute/Woodrow Wilson Center Forum on Nanotechnology: Technical [PDF] and legal [PDF] aspects of identification and management of nanotechnology risks. (5/05)
• Interview: Can Nanotech be Regulated? Recent toxicology studies have given some concern that nanomaterials could pose unique hazards. Technology Review, a publication of the Massachusetts Institute of Technology, recently asked Richard Denison, senior scientist at Environmental Defense and a long-time observer of the U.S. environmental regulation system, how we should regulate nanotechnology. (1/06)
• Joint Statement of Principles [PDF] - Principles adopted by Environmental Defense and American Chemistry Council Nanotechnology Panel for presentation at an EPA public meeting on nanotechnology (5/05)