As originally reported here, EPA recently released its White Paper on nanotechnology and related issues. After reading through the White Paper, there are several interesting points that EPA makes.
The White Paper, as expected, lays out the Agency’s thoughts and ideas concerning nanotechnology and how EPA will treat it. While the Paper begins with the Agency’s role in the larger government plan concerning nanotechnology, it provides many EPA-specific items as they relate to research and regulation.
The Paper begins with EPA explaining EPA’s role with regards to nanotechnology, as well as why nanotechnology is important to the Agency. It then addresses issues such as risk assessment and development of nanotechnology from EPA’s perspective. Not surprisingly, EPA identifies several areas in which clear data gaps exist and must be filled in order to progress with nanotechnology. However, of particular interest to those in the regulated community, the Paper provides some of EPA’s thoughts on both potential regulation of nanotechnology, as well as its possible environmental benefits.
First, with regards to possible regulation by EPA, the Paper explains that the Agency maintains the position that current environmental statutes provide it with the authority to regulate nanomaterials. This statement alone is not surprising as it is a generally accepted thought. However, the Paper fails to discuss how some of these statutes contain trigger levels that may be inappropriate measures of nanomaterials. For example, statutes such as the Clean Air Act and Resource Conservation Recovery Act contain measurable levels at which regulation begins, such a specific concentration or weight emitted or discharged. Because nanomaterials may be a concern at vastly smaller measurements, many of these triggers that are measured in parts-per-million or pounds or tons emitted may be inapplicable; a point EPA does not fully develop. Similarly, EPA spends significant space on potential environmental harms, but also explains that nanotechnology may also provide environmental benefits, especially in terms of ground water or Superfund site remediation projects. It is important to remember that nanotechnology can be a positive in remediation efforts, not just something to regulate for protection. EPA does a good job remember this point, and should be commended for taking a two-vision approach: understanding remediation possibilities and understanding risk possibilities.
Second, the Paper goes into great detail concerning risk assessment. EPA believes it is very important to develop sound risk assessment concerning nanomaterials before moving to the next step. The Agency then reiterates its desire to work with stakeholders to develop the necessary information to make educated decisions.
Finally, the Paper concludes with a series of recommendations directed at EPA offices and staff. If EPA holds to these recommendations, the Paper provides a good road map as to the Agency’s priorities in the near future. While EPA’s work in nanotechnology will be largely driven by the research of research and risk assessment projects, its overall thoughts on nanotechnology provide a well-reasoned beginning its work in the field.
