TELL THE EPA TO TEST IT... MONITOR IT... COLLECT THE DATA.

Nano-pesticides and your health Tell the EPA to collect all the data The Environmental Protection Agency (EPA), like other U.S. regulatory agencies, currently has no regulations to ensure the health and safety of new nanotechnology products being introduced onto the market. Meanwhile, nanotech developers are not required to submit any product data, let alone health and environmental safety data, to regulatory authorities. The EPA has taken the first step toward regulation by requesting comments on its draft voluntary guidance for gathering data on pesticides that incorporate engineered nanoscale materials (ENMs).See the request for comment or submit a comment now. What is Nanotechnology? Nanotechnology is the manipulation of material at the atomic level to take advantage of the novel properties of ENMs. For pesticides, nanotech is being used to exponentially increase the plant surface area to which toxins are effectively applied. According to the EPA, nanoscale materials in pesticide products may allow for more effective targeting of pests, use of smaller quantities of a pesticide and minimizing the frequency of spray-applied surface disinfection. What are the risks? There are significant potential risks. As the draft guidance notes, experimental studies with laboratory rats indicate that inhaled ENMS, particularly certain configurations of carbon nanotubes, can have “adverse lung effects.” Experiments with rainbow trout demonstrate that ENMs absorbed through the skin or consumed orally can move through different organs with toxic effects and can contribute to decreased reproduction. Several companies have applied to EPA to allow into the marketplace pesticides with nano-silver compounds for commercial and agricultural use, and the EPA believes that there are already unapproved and unregulated pesticides “in the marketplace that contain nanosilver as an active ingredient.” Nanosilver is a bio-cide. It is urgent, therefore, that pesticide developers and manufacturers submit to EPA all data requested on pesticides with ENMS, so that EPA can determine whether such pesticides pose “unreasonable adverse effects on the environment” and unreasonable adverse affects to human health. What can you do? Everyone who works with pesticides and/or consumes foods with pesticide residues should comment on EPA’s proposal for collecting toxicological and other data on pesticides that incorporate ENMs. Your comment will become part of the first public record towards U.S. agri-nanotechnology regulation. For IATP’s latest analysis of the state of agri-nanotechnology regulation, see our newest report, Racing Ahead: U.S. Agri-Nanotechnology in the Absence of Regulation. Tell the EPA that: You support its proposal to collect ENM data under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA),section 6 (a) (2). You agree with EPA that this statute provides the most efficient and effective way to gather data both for pre-market safety assessment and post-market surveillance of ENMs in pesticides. The EPA should determine which part of the submitted information and test data must be made public to enable peer-reviewed studies of the data to assess public and environmental health effects. The EPA should make a public determination about each nanotech developer claim that such information and data should be classified as Confidential Business information, exempt from public review. Submit a comment now and help protect human health and environmental safety. Please forward this alert to colleagues, friends and family.

IATP works locally and globally at the intersection of policy and practice to ensure fair and sustainable food, farm and trade systems. IATP has offices in Minneapolis, Minnesota and Washington, D.C. iatp.org

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