Emergency Alert: Stop EPA From Further Regulating Colloidal Silver as a "Pesticide"
We have only until January 20th to submit comments to the EPA against the proposal by radical environmental groups that want the EPA to immediately begin regulating nanosilver (read: colloidal silver) as a "pesticide" -- an action that would completely take colloidal silver off the market at some point in time.
Apparently, radical environmental groups and fake "consumer advocate" groups have joined hands to accellerate the ongoing campaign to have the EPA regulate all commercial forms of nanosilver, including colloidal silver, as a "new pesticide."
We received today an email from our good friend George Foss, a top nutritional supplement formulator and natural health watchdog, explaining that the Center for Food Safety (an elitist, pro-regulatory group masquerading as a "consumer advocacy" group) is now urging their readers to send comments to the EPA supporting the "Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”
This petition -- if accepted and acted upon by the EPA -- would essentially allow the EPA to regulate colloidal silver into oblivion, on the grounds that it could potentially cause harm to the environment. (See more on this issue below.)
Public Comments Soon to Be Closed
We also learned that public comments on this petition have been open for some time. But apparently only the rabid environmental groups and fake "consumer advocate" groups supporting the proposal have been told about the comment period, which ends January 20th. These pro-regulatory groups have been sending emails to their thousands of readers, urging them to go to a special web page they have set up where an automated system exists for submitting comments to the EPA en masse.
Unfortunately, this comment submission system only allows for comments from people who favor futher strict regulation of nanosilver by the EPA. Even if you use the system to send a comment against the proposal to regulate nanosilver as a "new pesticide," the system overrides your comment by superceding it with a "canned" favorable comment.
This means virtually all of the comments going to the EPA have been in favor of further regulation of nanosilver products.
Since EPA depends heavily upon public comments when deciding upon new regulatory action, it is vitally important that they get to hear the views of those who do not want to see nanosilver further regulated by the EPA as a "new pesticide."
Comments to the EPA will be closed as of January 20, 2009, so we have only a short time to act on this issue in order to save colloidal silver from being regulated into oblivion.
My Contact with the EPA
I picked up the phone this afternoon and called the EPA at the number under “Contact Us” on their web site (202-564-4700).
A very nice gentleman named “Peter” answered and I asked him how I could submit a comment on the nanosilver regulation issue, as their web site appears to offer no easy way to take and deliver such comments from the public. He said to send comments by fax or email directly to the EPA Administrator, Mr. Stephen Johnson:
Email: johnson.stephen@epa.gov
Fax: 202-501-1450
Be sure to reference Docket # EPA-HQ-OPP-2008-0650.
Also, be sure to state that you are commenting in regards to the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”
I also found a page on the EPA web site that says comments can be sent by mail to the following address:
Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P)
Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460-0001
Additionally, after much searching, I was able to figure out a way to post a comment to the EPA web site regarding the proposed regulations. I used this link, which I hope works for everyone else, too:
http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o...
Must Act Quickly and Decisively!
As quickly as possible we need to get the above contact information posted on as many relevant natural health internet forums as possible, and also circulated by email to all relevant people in the natural health industry.
Please do your part to help by referring as many "natural health" people as possible to this blog post. The rabid environmentalists have had a huge head start on this issue, since they are the only ones who knew where to send comments to. And there is only a very short period of time left between now and January 20th to submit further comments. Wild and Invalid Claims As you may already know, the environmental groups and fake "consumer advocate" groups have been making wild and invalid claims about nanosilver for some time now, stating that it is in immediate need of EPA regulation due to its alleged potential to harm the environment. Through deception and chicanery these groups have managed to convince the EPA to re-classify nanosilver as a "pesticide" under an obscure set of regulations known as FIFRA. Now they are pressing the FDA to strictly enforce those regulations under the supposition that nanosilver products represents a dire threat to the environment. Yet not one study to date – I repeat, not one study -- has ever demonstrated nanosilver to have harmed any part of the environment. Instead, only test tube and lab studies extrapolating its alleged negative effects on the environment have been conducted. And for the most part, those studies have been conducted by researchers who were either hired by the environmental groups to demonstrate nanosilver’s alleged harmful environmental attributes, or by researchers specifically working to forward the agenda of these groups. In other words, the so-called studies have been conducted by researchers who are predisposed to believe nanosilver is somehow harmful, or somehow represents a dire threat to the environment. They have been paid to demonstrate exactly that. This means the study outcomes are decided upon in advance, before the studies are even started. This is junk science at its worst. Re-Defining NanoSilver to Include Colloidal Silver What’s more, the environmental groups behind this drive to have nanosilver regulated into oblivion have re-defined the term “nanosilver” to include just about any commercial form of natural silver available on the market today, including ALL colloidal silver products. In one of their petitions to the EPA demanding the regulation of nano-silver products, these groups have even named some of the top commercial colloidal silver brands on the market today (including Sovereign Silver, Meso-Silver, ASAP Colloidal Silver, Utopia Silver and more) as being in dire need of “regulation.” So the whole thing reeks of a stealth campaign to have colloidal silver banned. The Bottom Line The bottom line is that silver has been in the environment for millions of years. In its natural state, bonded to other minerals and natural substances, it causes no harm to the environment whatsoever. As commercially produced nanosilver returns to the environment it is very rapidly degraded as it agglomerates (i.e., bonds together) with natural minerals, salts and other natural environmental substances that in effect eliminate its commercial nano-scale attributes, as well as effectively neutralizing its so-called “potentially harmful pesticide qualities” (i.e., its ability to kill pathogens on contact). So in reality, there is no threat to the environment whatsoever from nanosilver products. Rigged Studies The researchers who have ostensibly demonstrated harmful attributes of nanosilver on environmental life forms such as bacteria or tiny minnows used extremely high quantities of pure commercially produced nanosilver products in their lab studies. In other words they used levels of nanosilver that would simply never be found in the environment, due to silver’s propensity to bond rapidly with a multitude of other minerals, salts and other substances and return to its natural state once back in the environment. In short, the studies are bunk. They prove nothing. The reason the studies were conducted in the laboratory rather than in the actual environment is because it was already known what would have been demonstrated in an true environmental study. No environmental harm whatsoever would have been found. But by doing lab studies under rigged conditions that could never be found in the environment itself, the environmentalist researchers were able to demonstrate exactly what they set out to demonstrate. In other words, these studies were a “fix” from the beginning, in my opinion. My Comments to the EPA Here is what I posted through the EPA web site comment submission system earlier today. Whether or not these comments actually get posted to the EPA web site is another story. We shall see. Nevertheless, I also intend to submit my comments through the EPA’s email and fax systems noted above, as well as through the U.S. mail at the address noted above. Folks, we need to bombard EPA with comments against the proposal to further regulate nano-silver as a “pesticide,” just as the environmentalists have been bombarding them with comments in favor of the proposal. Here’s the comment I submitted: To the Honorable Mr. Stephen Johnson, Administrator: The idea that nanosilver needs to be regulated by EPA due to ostensilbe harm to the environment is ridiculous at face value. No study has ever demonstrated nanosilver to have caused harm to the environment. The only studies conducted have been laboratory studies that have extrapolated nanosilver's alleged environmental impact. These studies have completely ignored the fact that once returned to the environment nanosilver rapidly bonds with minerals, salts and other natural substances, forming non-nano scale conglomerate particulates, essentially returning the silver to its natural harmless state. In other words, once returned to the environment it is no longer nanosilver. And it no longer has the attributes deemed harmful by the white coat lab researchers who have conducted their laboratory studies using nanosilver in its purest and most non-adulterated commercial form rather than looking at what actually happens to nanosilver once it returns to the environment. By promoting lab studies that assume nanosilver somehow remains in its nano-scale commercial form once returned to the environment -- which is so demonstrably false as to be ludicrous -- the environmentalists behind the push to regulate nanosilver as a new “pesticide” have done EPA and the American public a grave injustice. They have created an environmental "crisis" where none exists. If you carefully read the petitions and press releases put out by the environmental groups now petitioning EPA in regards to regulating nanosilver, you will see they are so full of unsupported speculations and weasel words (i.e., "might cause harm" "could impact the environment," "may be highly destructive") as to be laughable. We respectively submit EPA ignore the rabid calls to regulate nanosilver being made by neo-Luddite environmentalist groups. It is simply and conclusively a non-issue, in terms of potential harm to the environment. Silver has always been in the environment and always will be. And when commercially produced nanosilver is returned to the environment it does not in any way, shape or form retain its commercial nanosilver properties. This issue is therefore moot; it is the proverbial "much ado about nothing." Respectfully, Positive Impact Hopefully we can make some positive impact against the proposal to have EPA regulate nano-silver as an environmental contaminant. But we have only a short time to act. And if we fail to act we will likely see the demise of the entire colloidal silver market. So please be sure to help us get this vital information out to the natural health community. Put the Means of Colloidal Silver Production For anyone wishing to put the means of colloidal silver production into your own hands, please consider getting a colloidal silver generator right away. With a colloidal silver generator you can produce all of the colloidal silver you'll ever need, any time you want, in the comfort and privacy of your own home, for only a few pennies per quart. Owning the means of colloidal silver production is the only way to make sure you will always have access to this powerful natural healing substance, especially if the EPA bows to pressure from the environmental groups and follows through on their plans to regulate nanosilver it into oblivion. Learn More... You can read more about the new Micro-Particle Home Colloidal Silver Generator by clicking here. You can read about the astonishing ability of colloidal silver to kill antibiotic-resistant superpathogens such as MRSA at the ColloidalSilverCuresMRSA.com web site by clicking here. And you can read more in-depth information about the many benefits of colloidal silver generators by clicking here to visit our good friends at TheSilverEdge.com Finally... For beginners, you can learn everything you need to know to get started using colloidal silver by watching the brand new, studio-quality, 60-minute Colloidal Silver Secrets Video, described at this link. And for those who would prefer more in-depth information about colloidal silver usage, including three full chapters of in-depth dosage information, check out the newly update, 547-page edition of The Ultimate Colloidal Silver Manual by clicking here. Regards,
S. Spencer Jones
Into Your Own Hands While There Is Still Time
S. Spencer Jones
http://wwww.LifeandHealthResearchGroup.com
That is an important alert, Spencer. I gave you a good message alert and will repost it in the News Forum and my private forum - minus the adverstisements you threw in at the end, which I think distract a bit from the message (though I do like your products).
Here is a related article from Natural News:
by Ben Kage, citizen journalist
Nanomaterials -- products and materials changed or created at the atomic and molecular level -- are quickly gaining popularity for their multitude of uses, and while the Environmental Protection Agency is preparing to regulate popular nanosilver antibacterial products, ostensibly to protect consumers, critics say the move is a thinly veiled attempt to solely regulate nanosilver as a health supplement.
Nanosilver is used to kill harmful bacteria in food storage containers, shoe liners, washing machines and even bandages. Particles of nanosilver and other nanomaterials can be as small as one-millionth the size of a pinhead. However, the EPA, citing pressure from silver industry workers and environmental groups such as Natural Resources Defense Council, is investigating whether silver ions could pose an environmental threat by killing beneficial bacteria in the environment, or even harming humans. The agency also received a letter from Chuck Weir, chairman of a California wastewater treatment plant advisory group known as Tri-TAC, which claimed "silver is highly toxic to aquatic life at low concentrations and also bioaccumulates in some aquatic organisms, such as clams."
Silver was brought under close EPA scrutiny when washing machine manufacturers began making models that were lined with silver ions or sprayed them onto the clothes as an antibacterial agent. Last year, the EPA decided that the machines should not be regulated under the Federal Insecticide, Fungicide and Rodenticide Act, since they were considered devices rather than pesticides. Recently, however, the agency re-examined its decision and reversed it.
"We took a second look at the release of silver ions, and it was very clear that this is a pesticide and not a device," Jim Jones, director of the EPA's Office of Pesticide Programs, told the Washington Post. "Our original determination proved not to be a correct one."
Under the regulations, any silver product that claims it has antibacterial properties must prove the product is safe to be released into the environment. Mike Adams, a consumer health advocate and proponent of colloidal silver, suggested the regulations might work better were they aimed at antibiotics and pharmaceuticals.
"Isn't it interesting that the EPA chooses to completely ignore the environmental safety of all the millions of tons of pharmaceuticals flushed down toilets every year while selectively targeting silver products?" he said. "Why isn't the EPA concerned about the environmental toxicity of pharmaceuticals?"
A major point of contention for silver proponents is the fact that only products making antibacterial claims are subject to regulation. Jones' commented that, "Unless you're making a claim to kill a pest, you're not a pesticide." This decision has caused a severe backlash since it was announced Nov. 22, but not from washing machine manufacturers. Advocates of the use of silver in health have expressed outrage that the EPA has become involved and made this a safety issue, as their decision directly affects sellers whose silver products claim any antibacterial benefits.
"People have used silver flatware, and in the past silver coins, for thousands of years, releasing silver into the environment with no question of harm," said New Jersey lawyer Ralph Fucetola, who runs the Committee for the Responsible Use of Silver in Health (CRUSH) and the www.SilverFacts.com website. "The EPA will require proof of the safety of silver in the environment only if the companies make germ-killing claims," said Fucetola. "They are only concerned about safety if the public is being given information about benefits."
Fucetola, who is known as the Vitamin Lawyer for his work in the realm of dietary supplements, said CRUSH was developed to prevent irresponsible use of silver in health -- with special focus on ingested silver -- from both sides of the equation; both entities that would off-handedly disparage silver's benefits and those who would exaggerate them for profit.
"This is not a regulation designed to protect the environment from nanotechnology, it's a stealth ploy that selectively attempts to remove colloidal silver from the marketplace," Adams said. "Silver was gaining momentum in the marketplace as a safe, effective and natural antibacterial element. It cannot be patented and directly competes with antibiotics, antibacterial cleaners and other products from powerful corporations. That's why Big Business had to knock colloidal silver off track and regulate it out of the marketplace."
Fucetola noted there is a conflict between the EPA's decision and its own safety data on silver.
"EPA public records show that for ingested silver there is a safe level of use, known as the Reference Dose (RfD), determined by science as the safe daily amount for consumers," he said. "The guidelines make it clear that the only concern for the RfD is for the potential for the skin discoloration known as argyria. You would have to consume so much silver that it would discolor your skin before there would be any safety concerns."
Agyria, the most common health concern associated with silver, is a permanent yet medically benign conditioned marked by discoloration of the skin, usually brought on prolonged exposure to large amounts of the substance.
The EPA considers silver a water contaminant, but its Office of Drinking Water decided in the early 1990s that the effects of silver exposure in drinking water were cosmetic, and therefore downgraded the substance from a primary contaminant level to a secondary contaminant level. Additionally, the U.S. Centers for Disease control reports that spills of silver less than 1,000 pounds are not required to be reported to the EPA.
"If the EPA were to take the position that all nanosilver products had to qualify as 'safe and effective,' it would be acting contrary to its own long history of determining scientifically valid RfDs," Fucetola said. "Silver is spread throughout the environment already. Taking silver from the environment, using it and having some of it return to the environment is no different than the use of any other metal from the environment, whether iron, copper, or whatever."
Another factor that is drawing anger from silver proponents is the seeming focus of regulations on nanosilver to the exclusion of other nanomaterials. Indeed, the majority of nanomaterials will not be subject to EPA scrutiny, as they do not make any antibacterial claims.
"Consider this," said Adams. "Out of all the countless nanotechnology particles used in sun lotion, clothing and cookware, the EPA has decided to regulate only one -- colloidal silver, which is a naturally-occurring mineral. In doing so, the EPA ignores all the synthetic nanoparticles introduced into the environment through consumer products made by Big Business."
"'Nanosilver’ is the sexy new term for ionic silver," said Jay Newman, CRUSH member and president of supplement maker Invision International, in a press release. "Yet the imperative for an efficient delivery mechanism for human use is still the bottom line."
Newman said in a NaturalNews interview that free silver ions are needed to have an antimicrobial effect, but the ions will automatically bond with chlorine if they find their way into common drinking water, thereby rendering the ions inert.
"Our patented Silver100 is a perfect case in point, where it took many years of development and achieved patent protection because it has a specific molecular structure to control the release of silver ions in microbial forms," he said. "Once that occurs, the silver ions do not hang around. That's just the way the chemistry works.
"All appearances are that the EPA has been succumbing to corporate pressure of vested interests that do not want to see the word get out that silver has these benefits," Newman said. "I remain optimistic that the EPA will have the ethics and responsibility to let science prevail and that this will go away as quickly as it emerged."
If any Curezone community members have contact with leaders within the natural health community, you really need to get this message out to them, so they can alert their customers or followers to start bombarding the EPA with comments against the petition to regulate nanosilver (read: colloidal silver) as a "pesticide."
If these regulations are set in motion, all access to colloidal silver or colloidal silver generators will be destroyed virtually overnight, as the new regulations demand that any purveyor of any nano-sized silver product must be able to prove their product will not harm "environmentally sensitive" microorganisms in the environment.
This will essentially destroy the colloidal silver industry, as the costs of proving that a colloidal silver product causes no harm to the environment would be prohibitive (environmental impact reports can cost millions of dollars), and the regulatory burden on colloidal silver product distributors would be unsustainable.
Please copy and send the following short note to every leader within the natural health community you may know:
Dear ____________,
The EPA is taking comments until January 20th on the petition to regulate nanosilver products -- including colloidal silver -- as a "pesticide" under the revised FIFRA regulations.
Please read the articles at www.colloidalsilversecrets.blogspot.com and then alert your readers.
We need hundreds of readers to let the EPA know that colloidal silver should not be included under these new regulations.
As it stands, the main petition sponsor, the International Center For Technology Assessment (CTA) has drawn up a list of nanosilver products they claim need to be regulated by EPA, and among that list are the four top brands of colloidal silver (Sovereign Silver, Meso Silver, ASAP Silver, Utopia Silver) as well as many lesser known brands.
This is clearly a ploy to regulate colloidal silver as a "pesticide" under the revised FIFRA regulations, which require you to prove your silver product causes no harm to beneficial microorganisms or other creatures in the environment. This, in effect, would ultimately and unjustly put just about every colloidal silver manufacturer out of business, as the costs of proving that a colloidal silver product causes no harm to the environment would be prohibitive, and the regulatory burden would be unsustainable.(signed)
Your name
Please help as quickly as possible. The EPA's comment period on this issue ends January 20th. EPA depends heavily upon public input when deciding new regulatory issues. Make sure they hear from thousands of colloidal silver supporters. Get this message out to as many leaders in the natural health community as you can.
If you haven't gone too the EPA web site and left your comments on this issue yet, then do so now by going to this link and posting your comments against the proposal to regulate nanosilver (colloidal silver) products as "pestiicides."
Or email the EPA Administrator, Stephen Johnson, at this email address: johnson.stephen@epa.gov
Or faxt EPA at: 202-501-1450
Be sure to reference Docket # EPA-HQ-OPP-2008-0650.
Also, be sure to state that you are commenting in regards to the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”You can read more about this issue on the first two articles on my blog at:
www.ColloidalSilverSecrets.blogspot.com
Regards,
Steve Barwick
I have to wonder where the EPA has been during the past decades when tens of thousands of industrial chemicals have been introduced to our enviroment with no testing singly or in combination for safety on humans or any other life forms?
To worry about re-introducing nano-particles of silver back into the ecosphere from whence it came is patently rediculous and an obvious ploy to try to regulate silver in a way that removes the threat it poses to the billions of dollars of profits that big pharma reaps from patented and approved anti-biotics and other drugs. If colloidal silver is a pesticide, why are those drugs not also pesticides? How about bleach, germicidal cleansers, household cleansers and disinfectants and a world of other things.
Nano particles of .9999 pure silver - as quality colloidal silver consists of - is merely silver reduced closer to its most basic form, the silver atom itself. Thanks to nano-particles of silver in colloidal silver products, only now has silver arrived as the natural immune system assistant it was in the early days of mankind when it was plentiful in its metallic form in ground water. In fact, the entire plant and animal life of the earth has flourished for millions of years in the presence of silver in the oceans, lakes, rivers and streams.
Equally laughable is the EPA efforts to classify silver generators as pesticide makers which must be submitted to the EPA for approval because they generate microscopic silver particles that get rid of pests (the definition of which they have decided to include bacteria, viruses, and fungi - much like the arbitrary way the FDA defines drugs as anything reputed to have health benefits). If such is the case, should not all plant and animal life likewise be submitted to the EPA for approval since the act of ingestion and digestion does the very same thing to all minerals, including silver?
Any silver, large or small, kills bacteria, viruses and other single celled pathogens. Does that mean that silver jewelry and jewelry makers should also be under the auspices of the EPA?
Follow the money and see who has the most to gain from the regulation of silver. It is not the environment - unless one is talking about the environment in the board rooms of the drug makers.
DQ
Amen to that, wolf!
I have found people to be surprisingly apathetic to this issue. Even among people in the natural health industry. They don't seem to realize that once so-called "nano-silver" is regulated, every health product on earth containing "nano-particles" are going to be regulated.
If you go to this web site of the Project on Emerging NanoTechnologies(http://www.nanotechproject.org/inventories/consumer/browse/categories/food_be...) you will see they are already keeping lists of every nutritonal supplement that contains nano-particles.
There are five pages of products listed, including B-vitamin sprays, calcium/magnesium supplements, microhydrin, spirulina products, and more, along with numerous colloidal silver-based products.
All of these are being watched. Once they get EPA involved in "regulating" nano-particles, any health product on earth that has any amount of nano-particles in the ingredients will be singled out for "regulation."
The apathy from the natural health community on this issue is stunning to me. The comments on the EPA comments site are running a good 10 to 1 in favor of greater regulation of silver as a "pesticide" by the EPA.
That's not because more people believe the EPA should regulate silver as a "pesticide." It's because the fake "consumer protection" organizations behind this assault on silver have been able to rally their supporters in greater numbers to go to the EPA web site and post favorable comments on the petition to have EPA regulate silver products. Natural health advocates have been extremely lazy, and are not going to the EPA web site to register their comments against the further regulation of silver by the EPA.
Even colloidal silver manufacturers and distributors don't seem to realize that their companies are in dire jeopardy at this point. For if the EPA accepts that petition and begins to regulate "nanosilver," then colloidal silver manufacturers and distributors will have to do environmental impact reports costing hundreds of thousand if not millions of dollars to prove their products will not harm the environment, or harm "environmentally sensitive" microorganisms, as I explain in the articles on my blog at www.colloidalsilversecrets.blogspot.com. I don't know of any colloidal silver manufacturer or distributor who has that kind of money to throw away on environmental impact studies. They will be out of business before you know it. Or the price of a bottle of colloidal silver will have to go to $100 just so the companies can pay for the studies.
Please, everybody reading this, do your part and help stop the EPA from regulating silver products as "pesticides." The hidden agenda behind this is to remove colloidal silver products from the marketplace. They will also eliminate colloidal silver generators as "pesticide producing" machines, and they will try to regulate supplies for colloidal silver generators, such as silver wire, silver bars, etc. You'll have to have a jewelers license to order them.
Anyone who wants to post to the EPA comments system can do so at this web address: http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o...
Anyone wishing to email EPA Administrator Stephen Johnson with their comments against the petition to have silver regulated as a “pesticide” can do so here: johnson.stephen@epa.gov
Additionally, faxes can be sent to EPA, addressed to Administrator Stephen Johnson, at: Fax: 202-501-1450
All comments must reference Docket # EPA-HQ-OPP-2008-0650.
Also, comments should reference the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”
Let the EPA know that until actual evidence of environmental harm by "nanosilver" is demonstrated, there is no need for new regulations or oversight. Also, point out that the term "nanosilver" is being so broadly defined as anything up to 100 nm, that just about every colloidal silver product on earth will be in danger of being labeled a "pesticide" and would require oversight and regulation, even though these products have been widely used for over 90 years with no documented environmental harm whatsoever.
Regards,
Spencer
Spencer, you write the article the way you think it should read, with EPA comment and contact info and I will publish it at Mike Adams Natural News as well as The American Chronicle and other online publications I write for.
I am going to write the article anyway - but you are a very knowledgeable and well spoken (written) person when it comes to silver and I would like to have your input.
The whole concept is such a thinly disguised attack against colloidal sivler it is pathetic. Misguided (or perhaps GUIDED) groups are making an issue about returning elemental silver to the environment that is patently rediculous. As I said earlier, where were these groups the past decades when tens of thousands of untested chemical compounds were introduced to the environment? What about all the chemicals that are flushed down our toilets, including drugs in our urine?
All silver, no matter what form, gives off ions upon contact with other materials. So should all silver be regulated as a pesticide? And when it comes to nano-particles, that is what happens to silver and all other minerals when they are ingested by plants and animals. Should all plant and animal life be regulated as pesticide producers?
The FDA made silver a number one target a decade back - that is an open fact. The EPA tested silver and found it to be non toxic. That is likewise a fact. Silver represents billions of dollars in potential profit losses to the big drug companies antibiotics, which also kill bacteria and which are released into our water supply via urine in much greater quantities - yet another fact.
Utopia Silver was singled out as a test case to regulate colloidal silver, as was admitted by a government official (but Utopia Silver fought back with a unique defense by standing on their constitutionally protected God given alienable rights and refused to accept the color of law court's jurisdiction, which appears to have stymied the governments case by opening up a can of worms they do not want to be aired publicly).
Next, they paraded around Paul Karason, who made his own homemade silver, contaminated it with salt and drank over a quart a day for years now. And then they resurrected Rosemary Jacobs, who took copious amounts of mainstream MD prescribed silver NITRATE drops. And now they are citing things like injuries to fish gills in San Francisco Bay - which comes from silver compounds used by industry, not silver nano-particles, or the CSP they call colloidal silver which is actually silver particles that are TOO LARGE to be suspended in water which uses animal and other proteins to artificially suspend them.
It is obviously not a coincidence. But people are either too apathetic, too ignorant or else they see names like Greenpeace attached to the petition and think that they would be "un-green" to protest, not realizing what really is at stake.
Send me the article and I will get it out as far and wide as I can. I'll even post it in Utopia Silver's Silver Bulletin to the tens of thousands of people on their mailing list.
As it is, I have already sent an urgent notice to Mike Adams asking him to put up an article under his own name and will be posting in other forums, including my own here and at Yahoo.
Tony (DQ)
Anyone who wants to post to the EPA comments system can do so at this web address: http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o...Anyone wishing to email EPA Administrator Stephen Johnson with their comments against the petition to have silver regulated as a “pesticide” can do so here: johnson.stephen@epa.govAdditionally, faxes can be sent to EPA, addressed to Administrator Stephen Johnson, at: Fax: 202-501-1450All comments must reference Docket # EPA-HQ-OPP-2008-0650.Also, comments should reference the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”
Hi Steve,Thanks for your interest in our legal petition to EPA. I’m one of the attorneys who drafted the action and your question was forwarded to me.To clarify and answer your question: the only consumer products that were included in our product appendix attached to our legal petition were those products that in our research we found were actively marketing their products, through labeling or advertising, as “nano” (i.e., containing manufactured or engineered nanoparticles) and that made health claims based on that “nano” ingredient.So if there are silver colloidal solution products in the appendix, they must be marketed (or were, as of May 2008, when we filed the petition) as nano-silver and we have documented evidence of such marketing claims.The appendix was illustrative not comprehensive. We only highlighted these products for the agency to investigate; we did not test the products ourselves. The product appendix included only those self-identified nano-silver products we could find.No doubt there are more nano-silver products available that are unlabeled and we are calling on the agency to investigate and apply its statutorily entrusted oversight to those products as well.If said products in the appendix are not “nano,” then they need to remove the misleading and illegal claims on their advertising and marketing. If the products are composed of nano-silver, then yes, they are different than other larger particles of silver and need to be regulated separately.As we explain in the petition, engineered and manufactured nanomaterials like nano-silver are new types of materials that required new forms of toxicity testing and data to properly assess their novel properties and associated potential risks. In our petition we are requesting that EPA properly analyze the health and environmental safety of these materials before permitting them to go to market.Sincerely,George A. Kimbrell | gkimbrell@icta.orgStaff Attorney,The Int'l Center For Technology Assessment & The Center For Food Safety660 Pennsylvania Ave., S.E. Suite 302Washington, D.C. 20003202-547-9359 | fax 202-547-9429
I'm on it. Send me a private email or message for further discussion.
Tony