After brief introductory remarks by several EPA officials on the nature of the program and the purpose of the public meeting, comments were delivered by the following people. Public comments will be accepted by EPA through September 10, 2007. I have included links to statements that I could find in advance of this deadline.
- Shaun Clancy, DeGussa on behalf of the American Chemistry Council
- Richard Denison, Environmental Defense [statement]
- Bernard Made, Environment Canada
- Carolyn Nunley Cairns, Consumers Union [statement]
- Scott Slaughter, The Center for Regulatory Effectiveness
- Terry Davies, Woodrow Wilson Center [statement]
- James Cooper, Synthetic Organic Chemical Manufacturers Association
- Igor Linkov, Intertox, Inc.
- Kristen Kulinowski, International Council on Nanotechnology (ICON) [statement]
- Sean Murdock, NanoBusiness Alliance
In general, it's fair to say that the NMSP has generated a good deal of debate on both sides. ICON issued a statement calling for EPA to develop a publicly accessible database of information it collects on nanoscale materials, whether in a voluntary or mandatory capacity, and to participate in the development of consensus standards in terminology, methodology and characterization and encourage data submitters to conform to those standards.
The three trade associations that spoke (ACC, SOCMA and NbA) were largely positive about the program, finding it a reasonable approach to generating much needed data on nano EHS, and urging EPA to develop a specific timeline for submission of data and to protect confidential business information that is the lifeblood of many nanotech start-ups.
The two NGOs (Environmental Defense and Consumers Union) and a rep from the Woodrow Wilson Center were critical of the program. Common themes were that this is no good substitute for regulation and that EPA's failure to identify nanomaterials as "new" or to address their newness through the use of the Significant New Use Rule (SNUR) leaves this whole class of materials subject to no pre-market review.
Moreover, these groups are skeptical of the level of participation the NMSP will draw, given the small number of companies participating in the UK's voluntary program. While not able to make public commitments to participate on behalf of their member companies, the trade association representatives noted that, unlike the US EPA, the UK did not have in place a familiar mechanism for dealing with CBI, which may be the causative factor for their low participation.
Stay tuned for more comment and reaction to the program as the deadline for comments approaches. Meanwhile, EPA confirmed that it will hold a peer consultation on nanomaterial characterization needs for the NMSP on September 6-7, 2007 in Rosslyn, VA. This will provide a forum for exploring what types of data characteristics should be reported by participants of the NMSP.
