EPA Will Publish Notice Regarding TSCA Inventory Status of Carbon Nanotubes

According to the Office of the Federal Register, tomorrow the U.S. Environmental Protection Agency (EPA) will publish a notice regarding the Toxic Substances Control Act (TSCA) requirements potentially applicable to carbon nanotubes (CNT). EPA states that it “generally considers CNTs to be chemical substances distinct from graphite or other allotropes of carbon listed on the TSCA Inventory.” As a result, many CNTs may therefore be new chemicals under TSCA Section 5. Manufacturers or importers of CNTs not on the TSCA Inventory must submit a premanufacture notice (PMN) (or applicable exemption) under TSCA Section 5 where required under 40 C.F.R. Part 720 or Part 723. To determine the TSCA Inventory status of a CNT, a manufacturer may submit to EPA a bona fide intent to manufacture or import under 40 C.F.R. Section 720.25.  According to the notice, some time after March 1, 2009, EPA anticipates focusing its compliance monitoring efforts to determine if companies are complying with TSCA Section 5 requirements for CNTs.

Friends of the Earth Australia Calls for an Immediate Moratorium on the Use of Carbon Nanotubes

In its latest Background Paper, entitled Mounting Evidence That Carbon Nanotubes May Be the New Asbestos, Friends of the Earth Australia (FOEA) is calling “for an immediate moratorium on the commercial use of carbon nanotubes and the sale of products that incorporate nanotubes until research can demonstrate whether or not there is any safe level of exposure to them.”   FOEA also is calling for new nanotechnology-specific regulation to protect human health and the environment, as well as for mandatory labeling of all nanoscale materials used in the workplace and in consumer products.

FOEA’s paper summarizes various studies that have been conducted on carbon nanotubes and contends that these studies suggest “strongly that some forms of nanotubes could pose similar health risks to asbestos and that a wide range of nanotubes cause both localised and system toxic effects.” FOEA argues that suitable detection technologies to measure occupational exposure levels to nanotubes do not exist, and it decries the fact that material safety data sheets for carbon nanotubes “remain based on synthetic graphite.”

IARC Announces Carbon Nanotubes Nominated for Review

The International Agency for Research on Cancer (IARC) recently solicited nominations for substances for review in future IARC Monographs, which identify environmental factors that can increase the risk of human cancer. IARC states that it will select substances for review based on: (a) evidence of human exposure; and (b) evidence or suspicion of carcinogenicity. The 51 substances nominated include carbon nanotubes, which received three nominations:

Name

David Coggon

Principal affiliation

MRC Epidemiology Resource Centre, University of Southampton, United Kingdom

Public health reason for IARC to undertake this review?

Nanotechnology is developing rapidly with many potential applications. Evidence is beginning to emerge that nanotubes could pose cancer risks similar to those from asbestos.

Name

Jennifer Sass

Principal affiliation

Natural Resources Defense Council

If the substance was previously reviewed, what new information would lead to a change in the evaluation?

Multiwalled Carbon Nanotubes (MWCNT): Substantial animal studies report that exposure to MWCNTs by tracheal installation induces progressive, irreversible lung fibrosis that would likely lead to cancer. New data strongly suggests the potential for single-walled carbon nanotubes (SWCNT) to cause lesions that may lead to mesothelioma. The potentially-widespread use of these new materials and allied potential for exposure and harm argue strongly for an evaluation of existing literature. Objective review of existing information is critical to support appropriate actions across the globe on this potential carcinogen.

Public health reason for IARC to undertake this review?

Widespread water contaminant.

Name

Paul A. Schulte, Ph.D.

Principal affiliation

National Institute for Occupational Safety and Health

Public health reason for IARC to undertake this review?

Carbon nanotubes are likely to be used increasingly in a large number of products. Therefore, increasing numbers of workers may be exposed to them. Preliminary information indicates that carbon nanotubes may have similar carcinogens potential as other durable natural or man-made fibers.


To assist IARC in selecting substances for review, it is convening an Advisory Group to review all public nominations and to recommend those it considers to be of high priority. According to IARC, the Advisory Group “may also propose additional agents at the meeting for discussion and possible inclusion on their list of recommended priorities. In making their recommendations, the Advisory Group will consider near-term public-health priorities and recent research and research in progress.” The Advisory Group will meet on June 17-20, 2008.