Tuesday, April 19, 2005

Nanotechnology and Regulation

Wardak, Ahson, NANOTECHNOLOGY & REGULATION: A CASE STUDY UNDER THE TOXIC SUBSTANCE CONTROL ACT: A DISCUSSION PAPER, Foresight and Governance Project. Woodrow Wilson International Center for Scholars, Publication 2003-6.


This report is recommended for its review of the Toxic Substances Control Act (TSCA) and how it might apply to nanomaterials, esp. carbon nanotubes. It explains the Chemical Abstracts Service (CAS) and the host of acronyms associated with TSCA.

It is weak on the health risk research part of the report reducing the research to five studies (Oberdorster, G., Warheit, Lam, Huczko, and Baron). The CBEN people claim there are about 50 studies on toxicology and nanomaterials to date. In defense, this paper does focus on workplace inhalation concerns.

The paper ends with a series of questions which walk the readers through the process of TSCA such as significant new use notification (SNUN) and exemption qualification {low volume, low release and exposure, and text-marketing). The section ends with a flowchart that explains the step by step proceed which I have found useful in explaining TSCA to interested parties without any experience in regulation of potentially toxic substances.

A second weakness is the limited range of the paper. We can expect regulatory initiatives under the auspices of the FDA, NIOSH and OSHA, and other entities who have regulatory authority granted under different legislation. Also, the subject of liability as a market regulatory response is unanticipated.

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