A Project of the International Center for Technology Assessment
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Regulations

ICTA Comments to the U.S. National Organic Standards Board (NOSB) Materials Committee 

April 12, 2010

ICTA and the Center for Food Safety submitted comments to the NOSB, requesting that it classify engineered nanotech materials as "synthetic" and prohibit engineered nanotechnologies and materials as an "excluded method" in organic.

ICTA comments to the U.S. Department of Commerce, International Trade Administration on priorities for the Transatlantic Innovation Dialogue

February 5, 2010

ICTA submitted comments to the U.S. Department of Commerce, requesting for nanotechnology to be included as a priority for any Transatlantic Innovation Dialogue.   ICTA calls for representatives of the various U.S. and EU regulatory bodies to convene and establish common regulatory and goals for the oversight and assessment of nanomaterials. 

Joint Comments on NIOSH's Interim Guidance on Medical Screening of Workers Potentially Exposed to Engineered Nanoparticles Document
February 20, 2008
Joint comments of United Steelworkers of America, CTA, and other organizations in Response to the NIOSH Public Review of the NIOSH Document Entitled Current Intelligence Bulletin (CIB): Interim Guidance on Medical Screening of Workers Potentially Exposed to Engineered Nanoparticles, February 12, 2008

CTA and ETC Group oppose dumping of iron nanoparticles in ocean
December 11, 2007
    In a June 19, 2007 Letter of Concern, ICTA and ETC Group demand EPA fully investigate the legality of Planktos, Inc.'s past and future "iron seeding" activities under the U.S. Ocean Dumping Act. The San Francisco-based company intends to transport and dump 100 tons of iron nanoparticles off the coast of the Galapagos Islands without permit in Summer 2007. According to the company's website, they undertook a similar illegal dumping operation in 2002. Possible environmental impacts of this untested geo-engineering project include increased production of nitrous oxide and methane, possible toxic plankton blooms, and unforeseen impacts on ocean ecosystems.

Comments on EPA's TSCA Nanomaterials Voluntary Program and Concept Paper
September 10, 2007

Joint CTA-FoE Comments on EPA's "Concept Paper for Nanoscale Materials Stewardship Program (NMSP) under TSCA" and "TSCA Inventory Status of Nanoscale Substances - General Approach"

CTA urges the President's Council on Bioethics to apply bioethics principles to nanotechnology
June 29, 2007
CTA submitted this testimony to the President's Council along with oral comments by CTA staffer Jaydee Hanson. See this next item for Hanson's oral comments.

Hanson oral testimony to President's Council on Bioethics on Nanotechnology
June 29, 2007

    Jaydee Hanson, Director of Human Genetics and Nanotechnology Policy for CTA was the only Non-governmental person to testify during the public comments section of the President's Council on Bioethics first meeting on nanotechnology. For the complete written statement go to:

http://www.icta.org/doc/CTA%20Statement%20on%20Nano%20Principles%20Pres%20Council%2062907.pdf                                                                            

 

CTA Comments on Proposed EPA Oversight Change of Food Packaging; Nanosilver
April 23, 2007

CTA filed these comments jointly with Beyond Pesticides, the Center for Food Safety and Friends of the Earth on EPA's proposed abdication of its oversight of food packaging treated with a pesticide.

Joint Comments on NNI Environmental, Health and Safety Needs and Prioritization
January 31, 2007
CTA jointly filed comments with the American Federation of Labor and Congress of Industrial Organizations (AFL-CIO), United Steelworkers of America, and Sciencecorps, calling on the National Nanotechnology Initiative (NNI) to urgently prioritize and formulate a comprehensive risk research plan for the environmental, health and safety (EHS) risks of nanotechnology.  The organizations called on the NNI to make its top priorities the EHS risk research of: nanomaterial manufacturing and research worker health and safety; nanomaterial consumer products and consumer health and safety; and the environmental impacts of nanomaterials.

CTA Comments on National Nanotechnology Initiative's Report on Environmental, Health and Safety Research Needs
January 4, 2007
CTA Staff Attorney George Kimbrell gave comment at an National Nanotechnology Initiative's "Public Meeting on Research Needs Related to the Environmental, Health, and Safety Aspects of Engineered Nanomaterials," calling on the relevant committees of the NNI to prioritize EHS research needs and provide a strategic research plan to federal agencies as soon as possible.  CTA recommended that three areas be given highest priority: Manufacturing worker and workplace safety; Nanomaterial consumer products and human health; and Environmental Impacts from nanomaterials. 

CTA Testimony at first-ever FDA Public Meeting on Nanotechnology
October 10, 2006
At the Food and Drug Administration's first-ever Public Meeting on Nanotechnology, CTA Staff Attorney George Kimbrell presented an outline of oversight and regulatory actions that the FDA should take to address the wave of nanomaterials in consumer products, particularly sunscreens, cosmetics, and other personal care products.

CTA Policy Analyst Jaydee Hanson comments to FDA on regulation of nanotechnology
October 6, 2006
Jaydee Hanson submitted these comments to the FDA docket on nanotechnology regulation. CTA coordinated comments to the FDA docket and succeeded in getting over 15,000 persons to comment on the docket Number 2006N-0107 "FDA-Regulated Products Containing Nanotechnology Materials."

CTA and Friends of the Earth Power Point on Challenge to Nanotechnology
May 16, 2006
Friends of the Earth (FOE) and the International Center for Technology Assessment (CTA) hosted a joint press conference on May 16, 2006 challenging the use of nanotechnology in personal care products, particularly sunscreens and cosmetics. FOE and CTA released a comprehensive report identifying and analyzing the nano-products made by some of the biggest names in cosmetics, including L'Oreal, Revlon, and Estee Lauder, as well as filing with the Food and Drug Administration, the first-ever legal challenge on the potential human health and environmental risks of nanotechnology and nanomaterials. The attached file contains the power point used in the press conference.

CTA Comments at EPA Meeting to Review Nanotechnology White Paper
April 20, 2006
CTA submitted written comments on the White Paper with several other groups in January 2006. These comments supplement and expand that earlier statement.  The EPA panel's charge includes the question of what issues were not adequately addressed in the White Paper. CTA believes one overarching issue stands out in its absence: While the scientific summary of the White Paper is perhaps commendable, the Paper fails to deliver much-needed nanotechnology policy and regulatory recommendations, in the short or long term.  Nanotechnology has the potential for various environmental and human health improvements. Adequate regulation and oversight are needed to safeguard against these unique and varied harms.

Given the urgent need for agency oversight of nanomaterials, and EPA's placement as possibly the "lead" agency in nanotechnology oversight, the White Paper falls woefully short in its discussion of this crucial issue. CTA requests EPA revise its White Paper to analyze the heretofore unaddressed or inadequately addressed aspects of its policy and regulatory recommendations.

Jaydee Hanson presentation to the Nano and Bio in Society Conference March 2006
March 28, 2006
In March 2006, CTA Policy Analyst Jaydee Hanson spoke at the Nano and Bio in Society Conference in Chicago and chaired a panel on the ethics of nanotechnology and needed regulations for nanomaterials. The power power of his speech details necessary tests that nanomaterials should be subjected to PRIOR to their commercial use.

CTA and other groups call on EPA to regulate nanotechnology
January 31, 2006
CTA and several other public interest groups filed the following comments in response to the Environmental Protection Agency's Nanotechnology White Paper (December 2005).  The agency paper lacks adequate policy recommendations to regulate the unique risks of engineered nanoparticles.  New nano-specific legislation must be enacted to address these human health and environmental risks; absent new law, agencies like EPA must enact binding regulations focused on nano-risks from existing statutory authority, rather than rely on volunteer submission programs such as the one currently proposed by EPA.

CTA Joins with other groups to call on EPA to regulate nano-materials
June 23, 2005