CRE previously published an article on this site which joins several stakeholders who have requested that EPA convene a Science Advisory Panel to review and provide advice on EPA’s regulation of nanotechnology in pesticides. This article is available online at http://www.thecre.com/forum1/?p=2130 .
This article explains that EPA should as soon as practicable convene a FIFRA Science Advisory Panel to review many problems plaguing EPA’s current proposals regarding regulstion of nanotechnology in pesticides. These problems include:
● 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.
CRE has sent this article to appropriate EPA staff, along with a request for SAP review.