As of at the
moment, there are solely eleven days left to voice your opposition to the proposal for
the EPA to regulate nanosilver merchandise -- together with colloidal silver -- as "pesticides."
Because it stands, the primary petition sponsor, the Worldwide
Middle For Expertise Evaluation (CTA) has drawn up a listing of nanosilver
merchandise it claims must be regulated by EPA. Amongst that listing are the 4
prime manufacturers of colloidal silver (Sovereign Silver,
Meso Silver, ASAP Silver, Utopia Silver) in addition to many lesser identified manufacturers.
That is clearly a ploy to regulate colloidal silver as a "pesticide" below the EPA's revised FIFRA laws,
which require you to show your silver product causes no
hurt to useful microorganisms or different creatures within the surroundings.
Placing Colloidal Silver Manufacturers Out of Enterprise
If the EPA begins to regulate colloidal silver
as a "pesticide" below its revised FIFRA laws, this
can, in impact, unjustly put each colloidal silver producer out of enterprise.
The prices of proving that a colloidal silver product causes no hurt to ecologically sensitive microorganisms within the atmosphere could
be prohibitive (environmental impression reviews can value tens
of millions of dollars), and the regulatory burden on colloidal silver
manufacturers could be unsustainable.
EPA is taking public feedback till January twentieth, after which they are going to make their resolution.
The right way to Cease Them From Regulating Silver As
a "Pesticide"
In case you have a pure well being advocacy group or
a well being freedom group, or an e-mail buyer listing of colloidal silver customers, or an electronic mail listing of pure well being
customers, please, please let your membership base learn about
this dire scenario, and the brief time now we have left to cease
it.
Direct your members or e mail recipients to put up their feedback towards regulating silver as a pesticide on the EPA
remark system (see internet deal with and additional directions beneath).
Or have them e mail the EPA Administrator Stephen Johnson immediately (see beneath) and let him know
that there isn't a compelling have to regulate nanosilver merchandise equivalent to
colloidal silver as pesticides, since there isn't any proof in anyway of any environmental hurt having taken place.
Tips on how to Contact the EPA
Anybody who desires to submit to the
EPA feedback system can achieve this at this internet deal with:
http://www.laws.gov/fdmspublic/element/fundamental?major=SubmitComment we didn't
take a look at the merchandise ourselves. The product appendix included solely these self-recognized nano-silver merchandise we might discover.
Little doubt there are extra nano-silver merchandise obtainable which can be unlabeled and we're calling on the company to analyze and apply its statutorily entrusted oversight to these merchandise as nicely.
If stated merchandise within the appendix are usually not nano,
then they should take away the deceptive and unlawful claims on their promoting and advertising.
If the merchandise are composed of nano-silver, then sure,
they're totally different than different bigger particles of silver and should be regulated individually.
As we clarify within the petition, engineered and manufactured nanomaterials like nano-silver are new sorts of supplies that required new types of toxicity testing and information to correctly assess their novel properties and related potential dangers.
In our petition we're requesting that EPA correctly analyze the well being and environmental security of those supplies
earlier than allowing them to go to market.
George A. Kimbrellgkimbrell@icta.org
Workers Legal professional,
The Int'l Heart For Know-how Evaluation & The middle For Meals Security
660 Pennsylvania Ave., S.E. Suite 302
Washington, D.C. 20003
202-547-9359 fax 202-547-9429
Please observe that he didn't in any approach, form or kind deny that his group contains colloidal silver as a "nanosilver" product.
He was very clear that so long as a colloidal silver product meets the requirements for nano-silver, then he intends to have EPA regulate it.
Be aware additionally his feedback, No doubt
there are extra nano-silver merchandise obtainable which are unlabeled and we're calling on the company to analyze and apply its statutorily entrusted oversight
to these merchandise as properly."
In different phrases, they're petitioning EPA to go after any colloidal silver product that matches their overly-broad definition of "nanosilver."
The Clincher
Now here is the clincher: In different literature, CTA and its supporting coalition of organizations declare nanosilver is outlined as silver particles of 100 nm in measurement or smaller.
Is EPA Regulation of Colloidal Silver It a Foregone Conclusion?
I believe the EPA has already determined upfront that they'll take on this "regulatory oversight," which suggests they're finally going to cease manufacturing and gross sales of something containing silver "nano particles" (beneath their definition of a hundred nm or much less) till it may be confirmed these particles will not trigger hurt to "ecologically delicate" microorganisms and different creatures within the setting, which is mainly not possible.
The one option to cease it's by a large outpouring of opposition from the American public. The EPA does strongly take under consideration public feedback of their choice-making course of. We should flip up the heat and let the EPA know we aren't pleased with this ruse to destroy the colloidal silver market by regulating nanosilver as a pesticide.
The Anti-Silver Propaganda Machine
This ridiculous petition to the EPA was preceded by months of propaganda towards "nanosilver" in the web "science information" media,
corresponding to at ScienceNews.org and ScienceDirect.com, each of which carried quite a few tales concerning the alleged "dangers" of permitting
"nanosilver" to get into the surroundings.
These the-sky-is-falling science information tales had been then re-translated for the popular media, leading to articles like
"Nanotechnology sparks fears for the long run" and "Scientists Suppose Small to search out 'Nano' Dangers," and the worst of all the
rooster little articles "Nanosilver fad poses 'severe threat to well being'" - and dozens like this,
all of those showing in numerous common on-line information media.
These guys are fairly good in how they go about constructing justification for
his or her place over a interval of many months
earlier than unleashing their campaigns for "regulatory oversight."
I am afraid they've us out-maneuvered. We actually must swamp
the EPA feedback system on this petition to regulate nanosilver as a pesticide with rational, properly-constructed feedback in opposition to the thought.
Proper now, the environmental teams and faux "shopper safety" teams have been stacking the EPA feedback system with feedback favorable to the concept of additional
EPA regulatory oversight of "nanosilver." They've achieved this by emailing their membership
bases, and asking them to ship in anti-silver feedback to the EPA.
Get On the Ball and We are able to Win!
The assorted pure well being organizations and the well being freedom group at massive has been woefully behind on countering this large anti-silver propaganda marketing campaign.
Thats why we want you to get entangled on this instantly.
When you belong to a pure well being advocacy group or
well being freedom group, please contact the membership
base and allow them to know what's happening. Give them the EPA contact
info above. Urge them to e-mail, fax, or submit feedback on the EPA
internet site, urging the EPA to reject the petition to regulate nanosilver merchandise.
In case you are within the pure well being enterprise and you've got
an electronic mail buyer base, electronic mail your prospects and clarify the
state of affairs to them, as properly because the dire have to
act rapidly. Give them the contact info above.
If you're merely a pure merchandise consumer, go to the EPA internet
site above and put up your feedback in opposition to the
petition to regulate nanosilver merchandise as
"pesticides." And cross this info alongside to
your entire like-minded mates straight away.
Something you are able to do to assist get the ball rolling on this path can be an enormous profit.
Sadly we have now so little time. However that's the hand weve been dealt.