Past EDF work on nanotechnology policy

Nanotechnology –- the design and manipulation of materials at the atomic and molecular scale -– has great potential to deliver environmental and other benefits, but it may also pose significant risks to human health and the environment.

Government and industry should work to identify and manage possible health risks before new products are widely used.

OpEd pieces

Improve regulatory policy

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.

Get the details

  • “Too Little, Too Late” - Environmental Defense Fund’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 Fund’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 Fund 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 Fund to U.S. EPA [PDF] addressing the Toxic Substances Control Act and nanotechnology issues (9/04) 

  • Environmental Defense Fund’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: Few Rules on Nanotech Living on Earth’s series “Let’s Get Small” explored why federal agencies haven’t yet regulated nanotechnology in a radio conversation featuring Richard Denison. (8/08)

  • 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 Fund 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 Fund and American Chemistry Council Nanotechnology Panel for presentation at an EPA public meeting on nanotechnology (5/05)

Increase risk research

Government and industry need to act now to ensure that the risks of nanomaterials are identified and addressed before such materials are incorporated into products for commercial production. Far more federal research dollars need to be spent on health and environmental implications of nanotechnology, to ensure that the critical research needed to identify potential risks is done expeditiously. Similarly, private industry needs to invest in generating data on the hazards of nanotechnology products before exposing workers, consumers, the public and the environment.

Get the details

  • Testimony of Dr. Richard A. Denison [PDF] (10/07) and Supplemental Testimony [PDF] (11/07), submitted to the U.S. House of Representatives Committee on Science for a hearing on “Environmental and Safety Impacts of Nanotechnology: Current Status of Planning and Implementation Under the National Nanotechnology Initiative.”

  • Letters to Senate and House Appropriations Committees:
    • Letter signed by 19 organizations [PDF], including large and small businesses as well as environmental groups, urging Congress to provide funding for the National Academy of Sciences to develop a roadmap and strategy to guide the federal government’s environmental, health and safety research on nanomaterials. (2/07)

    • Letter signed by 14 organizations [PDF], including large and small businesses as well as environmental groups, urging Congress to “significantly increase appropriations directed to research on the health and environmental implications of nanotechnology.” (2/06)

  • Environmental Defense Fund proposal [PDF] to increase U.S. federal funding of nanotechnology risk research to at least $100 million annually. Analysis providing support for spending at this level to identify the potential risks of nanomaterials. (4/05)

  • Testimony of Dr. Richard A. Denison [PDF] to the United States House of Representatives Committee on Science for a Hearing on “Environmental and Safety Impacts of Nanotechnology: What Research is Needed?” (11/05)

  • Environmental Defense Fund presentation to the National Academy of Sciences’ Committee to Review the National Nanotechnology Initiative - Provides our views on the federal government’s role in addressing nanotechnology risks. Written statement [PDF] | PowerPoint slides [PDF] (3/05)

  • Bibliography [PDF] of references and abstracts of risk-related research studies on nanomaterials compiled by Environmental Defense Fund. (4/05)