EPA wants to collect more information on the use of nanoscale ingredients in pesticide products. EPA’s currently proposed process for collecting and evaluating this information is marred by
- the lack of a clear definition of what constitutes a pesticide nanoscale material;
- the need to determine additional core data requirements (product chemistry, toxicology, environmental fate, ecotoxicology, etc.) and standard testing methodologies based on new information gathered since the 2009 SAP on nanosilver pesticides (http://www.epa.gov/scipoly/sap/meetings/2009/110309ameeting.html); and
- the need to propose regulatory processes, including the appropriate use of bridging data and identifying chemical classes of concern/triggers.
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