Friday, June 24, 2005

Report from the Front - EPA Meeting

Sorry, I've been kind of busy so here's my review of the EPA meeting from yesterday. I will blog more this week.

Report from the Front
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics

June 23, 2005
Public Meeting on Nanoscale Materials
Washington Plaza Hotel

The meeting of about 200 people from academia, industry, NGOs, etc., examined regulatory modalities appropriate for nanoscale materials. The distinction between new and existing materials becomes important since the materials may face different regulatory regimes. For example, existing materials may be subject to a voluntary pilot program, like HPV, DfE, Green Suppliers Network, etc. New materials would be subject to current mechanisms including exemptions for LVE, LORex, polymers, etc. As such, there was much interest expressed in whether nanomaterials were existing or new. There was recurring interest in characterization and nomenclature, esp. methodologies for measurement. Interest to share efforts with countries, esp. OECD, was expressed. Overall, there was interest in collecting information on production, use, exposure and release, health and environmental effect, and life cycle fate if products.

Speakers included:
First session
• David Jones of Nanoscale Materials who described his company’s products based on an active agent derived from magnesium oxide. I particularly enjoyed his remarks that everyone was a stakeholder.
• Fred Klaessig of Degussa discussed fumed silica and how it appears on the CAS. He commented on agglomeration and aggregate nature of nanoparticles and discussed some of the parameters for definitions.
• Jo Anne Shatkin of Cadmus encouraged a better understanding of persistence, mobility, and bioaccumulation in characterization.
In questioning, it was noted that most of the toxicological research deals with acute rather than chronic toxicity. The criterion of porosity was added to definition list. A brief discussion over safety protocols ensued and concern was expressed about new entrants.

Second session
• Karluss Thomas discussed the ILSI-ELSI reports.
• Julie Fitzpatrick from RSI recommended a toxicity screening strategy for nanoscale materials, including the need for testing protocols. Definitions need to include size distribution, agglomeration state, shape, crystal structure, chemical composition, surface area, surface chemistry, and surface charge.
• Sherry Ward from PCRM seemed exceedingly concerned on including animal rights groups as stakeholders.
• Phil Radford spoke and claimed to speak for over a dozen groups, including Greenpeace and the NRDC. Advocating the precautionary principle, he claimed the UK and Swiss RE reports called for releases into the environment should be minimized and materials should be treated as toxic. He also suggested Swiss RE called for a moratorium on same applications until more is known [sorry, I read that report and Hett calls for an active application rather than a strict application of the precautionary principle]. He made a long list of normative recommendations including: treating all materials as new. He called for “adequate” toxicity testing, an inventory for “all” engineered nanoscale materials, an export notification and tracking system, all testing be undertaken by independent bodies, “adequately” funded public dialogues, “equitable” impact analysis, increased federal funding for toxicity, bio-accumulation, and development of methodologies.
In questioning, there was agreement for broad stakeholder dialogues being a high priority. There was a case made for co-development or co-evolution along with a voluntary pilot program which should not be viewed as mutually exclusive with other regimens.

Third session
• Richard Dennison and Larry Andrews co-presented some fundamental principles of agreement between SCC and Environmental Defense.
• Denison called for increased government spending for EHS research, open and transparent rule making, appropriate protecting measures, etc. He called to extend rules to all such materials, existing and new, to collect and produce sufficient data for hazard and exposure potential, to study material across full life cycles, to identify appropriate safety measures, and to work within the existing regulatory framework. He warned against reliance on estimation methods for lack of data. He chided VPP on existing-new materials definitions, how it sidesteps current regulatory frameworks, was ineffective in terms of encouraging participation, and had unclear reporting methods. He wants rebuttal presumption to rest on “new” material status. He called for pro-active risk management.
• Andrews supported the VPP proposal and called for global harmonization of nomenclature, information gathering, transparency, and increasing EHS funding. He called for assessment data from testing proposals, opportunities for public education and communication, and steps in the VPP.
In open discussion, EPA admitted $5 million a year was spent for EHS funding. There was some discussion on transitioning beyond the VPP. A question arose on who should pay for research and there seemed to be consensus the government should pay for developing platform methodologies, but EHS research should be supported by government and industry. An advisory panel was discussed and some concern was expressed over the exclusion of CBI. A discussion ensued over requirements in a VPP including a minimum data set, obligation to notify, scope, schedules, checkpoints, etc. A representative from the Science Committee said some effort to limit dispersive uses might decrease some of the urgency expressed by the body. It was agreed start-ups may be especially challenged by nature of their budgets and time commitments when it comes to programs, like VPP, and would benefit greatly from stewardship. I complained about the deficit model of science communication with lay persons and how toxicology is more intuitive and how risk algorithms fail to value benefits across the range of nanomaterials activities.

The inventory of information called for by the body should include:
• toxicological data, both health and ecological for the full cycle of the materials,
• exposure data, test methods,
• lab safety standards of care and protocols,
• appropriate protective equipment and best practices inventories,
• stewardship procedures and risk management schemes.

Wednesday, June 15, 2005

Forest Report trumps Agr/Food Report

Imagine my surprise as another of my misapprehensions was corrected. I just assumed that two reports I was reading would be different in terms of quality but not in the direction I am going to report.

Nanotechnology for the Forest Products Industry: Vision and Technology Roadmap is excellent. This 102-page document includes the results of the October 2004 Nanotechnology For The Forest Products Industry Workshop which was attended by 110 researchers and scientists representing paper manufacturers, suppliers, government, and academia. Sponsored by the Nanotechnology Working Group from the Agenda 2020 Technology Summit II last May, 2004, the Workshop was designed to help participants plan the industry’s research future.


This report does an incredibly good job explaining the intersection of applied nanoscience with the forestry industry. It claims nano "holds the promise of changing all of the processes by which wood and paper products are now made." It covers surface/interface modification of wood and pulp fibers, adhesives and surface coatings, direct impregnation treatments, reinforced fibers with enhance recyclability, and new wood fiber-based products. True be told, there are some fascinating possibilities here, esp. in terms of improving "the efficiency of forest products raw material conversion processed by reducing energy consumption by processing 50 percent, using up to 60 percent less raw materials per unit of forest product, and reducing product degrade/off-specification."

The report discussed "genomic modification of trees and other lign0ocellulosic feedstock." Applications are numerous and include sensors, packaging materials, biocompatible or anti-microbial material, or substrates whose surface properties have been tailored for compatibility with other electronic or optoelectronic materials or devices."

The report brief covers early warning and self-healing brought on by mold or termites, spoilage and tampering sensitive packaging, intelligent papers, etc. And, it's a beautiful colorful publication.

On the other hand, Nanoscale Science and Engineering for Agriculture and Food Systems, A report submitted to Cooperative State Research, Education and Extension Service, USDA, based on a Workshop on November 18-19, 2002, and published in September 2003 was unimpressive and superficial. I found more complete information in the ETC Group's Down on the Farm.


Even once we factor out the obvious (the Workshops were held two years apart), there is simply a less understood understanding of the intersection nature of the relationships involved in the Ag/Food Systems report.

On p. 18, "scouting" is discussed. Think "smart dust" because that concept was lost in the report. Chapter 5 covers "Smart Treatment Delivery Systems" and this controversial subject gets three pages of double-space coverage. "Smart Fields" and "Smart Herds" got two more pages in the next chapter. By the way the entire chapter was two pages long. On educating the public, it recommends: "The public should be educated through television, Internet, and point-of-sale informative bulletins that explain the value-added, increased safety and food security due to application of nanotechnology." I particularly enjoyed p. 50 where 1% of their Centers of Excellence's budgets should be dedicated to Public Education/Outreach activities (irony intended). Maybe, we could do better!!! I sure hope these efforts are NOT added into the number used by bureaucrats when they tally the amount dedicated to outreach.

Tuesday, June 14, 2005

EPA Notice - Nanotox and Stakeholders

I took a brief vacation and will be off to Houston and DC next week. While vacationing, I completed a 25 pp. comment for the EPA Meeting on the PMN for nanoparticles next week. This is where it can be found:

It will take up to 72 hours to appear in this docket.

Saturday, June 4, 2005

NANOTOXICOLOGY: An Emerging Discipline

Oberdorster, G., Oberdorster, E., and Oberdorster, J., NANOTOXICOLOGY: An Emerging Discipline Evolving from Studies of Ultrafine Particles, ENVIRONMENTAL HEALTH PERSPECTIVES, 22 March 2005, Retrieved from on 4 June 2005.

RECOMMENDED (as a resource)

This is a resource. There is a review of toxicology research related to ultrafines and nanoparticles with the text running about 35 pages. While it helps to have a background in biology, it is not necessary. The best part of the work is the bibliography which runs 20 pp. and 7 Tables.

The work opens: "...[E]xposure has increased dramatically over the last century due to anthropogenic sources. The rapidly developing field of nanotechnology is likely to become yet another source." They add that the research that has occurred and is ongoing "can be viewed as the basis for the expanding field of nanotoxicology" though it would seem upn reading the work and examining the bibliography that if there is a national center on nanotoxicology, it is probably located on the campus of Rice University in Houston, TX.

And the piece makes two excellent cases. First, there needs to be more research on nanotoxicology before we begin to configure regulations. Second, there needs to be a major efforts towards characterization and standardization of nomenclature.

Wednesday, June 1, 2005


And the winner is Mike Treder of the Center for Responsible Nanotechnology. STOP. First of all, I really like their web page ( Check out their Science, Science and Politics, and Science and Security Archives. Secondly, I really like them. They are great people and a pleasure to have as colleagues in the debate over nanotechnology because they bring a unique voice into the discussions.

The AWARD is about exaggeration and as such....

Mike Treder, "War, Independence, and Nanotechnology," FUTURE BRIEF, 2005.
Retrieved from on June 1, 2005.

The article includes many rhetorical flourishes, such as "looming just over the horizon is a grave threat. It is nanotechnology. From the dawn of the nuclear age until the present day, we have relied on two mechanisms to protect us from World War III: the doctrine of Mutually Assured Destruction (MAD) and the growing interdependence of nations."

While I love the acronym MAD, the truth is we have stepped back from this doctrine for some time now. Sec. of Defense Brown in 1980 in a commencement address outlined Presidential Directive 59. Donald Snow, PPS from Alabama discusses it in detail at
/aureview/1983/Nov-Dec/snow.html#snow. This counterforce strategy legitimated small nuclear bunker busters in Afghanistan. In addition, interdependence didn't seem to deter our recent foray into Iraq.

"However, in the very near future we may not be able to count on these controls. The tenuous balance of MAD and the worldwide network of commercial trade are both threatened by the rise of advanced nanotechnology." What controls?

This observation moots a concluding sentence. "When individual countries are able to provide their own goods and service, without the need for import or export trade, they will have less incentive to maintain good relations with others. When economic security is no longer an issue, the only remaining security concern will be military." Interdependence has had no effect on current military policies. Furthermore, with China owning a lot of our debt, you would have thought there would be reluctance to anger them with the Iraq venture and our revalidated policy on Taiwan.

Here's the primary rub. "Unless molecular manufacturing is contained, the number of nanotech-possessing nations in the world could be much higher than today's... increasing the chance of inflaming regional conflicts that could spin out of control..."

We remain no where near molecular manufacturing capability despite the long treatises on what could be given an extended series of breakthroughs, a series of events that would be affected by intervening variables that could easily mitigate or frustrate whatever connection the events has with a future event. Simply put, this is probability baiting. There are sufficient concerns in the present without directing us to bogeys in some probabilistic future.

For example, the EPA is holding a meeting in June because a PMN (pre-manufacture notification) has been filed by a company about to market carbon nanotubes. They are seeking a TSCA (Toxic Substances Control Act) review that could have serious environmental implications in the present.

I have NEVER said there is no reason to examine scenario constructions of distant future events. However, it is incredibly important that we inform readers that the bulk of our focus should deal with near and intermediate-term events. The CRN manifesto on molecular manufacturing is interesting but needs to be situated in an appropriate setting.

Maybe, we should be watching how nanoparticles and nanoelectronics might affect triggering devices for current nuclear weapons or how nano-armor and the human-free battlefield might make warfighting more likely once human damage is removed from the equation, etc.