In a May 25, 2010, letter to the U.S. Environmental Protection Agency (EPA) Office of Chemical Safety and Pollution Prevention (OCSPP), the Silver Nanotechnology Working Group (SNWG) expressed its concern regarding the pending Office of Pesticide Programs (OPP) interpretation concerning the regulation of nanoscale pesticide products. In its letter, SNWG states that the new interpretation, which “includes an unsupported and arbitrary definition of ‘nanomaterial’ and ignores decades of historical safety data,” would be “a major and damaging change in policy.” SNWG lists the following concerns:
- Institutionalize an arbitrary definition of nanotechnology;
- Contradict the statutory language and purpose of Section 6(a)(2) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA);
- Improperly characterize nanosilver as a ‘new’ pesticide;
- Stifle innovation without any benefit to human health and/or the environment; and
- Promote a negative public perception regarding nanotechnology as a whole.
SNWG urges EPA to consider its concerns prior to releasing the pending policy.