prior rant, I raised the concern that EPA would oppose the use
of new cleanup technologies based on nanotechnologies on the basis
of the precautionary principle. I may not have been exactly on the
mark, but I was pretty close. On Thursday, the NRDC announced that it has filed suit
challenging EPA's decision to issue a conditional registration of a nanosilver-based
antimicrobial agent. The NRDC asserts that EPA's use of the
conditional registration process is "illegal," apparently
because EPA does not have sufficient information to justify a
conclusion that use of the nanosilver products do not cause
"unreasonable adverse effects to human health and the
environment." According to the NRDC, EPA's decision is
just the most recent example in a
long line of decisions that treats [sic] humans and our
environmental as guinea pigs for these untested pesticides.
As noted in my prior post, there is a difference between
regulating in spite of uncertainty
– which can frequently be justified – and
regulating because of uncertainty,
which is deeply troubling. Nanomaterials hold great promise in a
wide number of fields, including many uses – such as
antimicrobials – focused on
protecting public health and the
What is the basis for keeping these materials off the market
just because we haven't proved that they don't pose a
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