Re: Emergency Alert: Stop EPA From Further Regulating Colloidal Silver as a "Pesticide"

Dear Curezone Members,

If you believe that Colloidal Silver is of benefit to you, your family, and your friends or are involved in the manufacture and sale of Colloidal Silver Generators or Products, now is the time to send your Comments to the EPA will close on January 20, 2009.

The EPA is being petitioned by fourteen Environmental Groups to have "Nano-Silver" (read Colloidal Silver ) to be reclassified a Pesticide. There intent is clear they are petitioning the EPA to:

"Take immediate statutory and regulatory action to prohibit the sale of nanoscale silver products, classifying these products as illegal pesticide products with unapproved health benefit claims.

In this regard, the petition claims that the nano-scale silver products currently on the market are in clear violation of FIFRA. The petition recommends that EPA pursue enforcement actions against and issue enforcement penalties to those manufacturers and/or distributors currently selling nanoscale silver products.

Nano Scale Silver is veiled name for Colloidal Silver!

Nanoscale refers to any size 0.1 microns (100 nanometers) or smaller, which means that 90% of the Colloidal Particle range is Nanoscale. Colloidal Silver Generators would likewise be considered under as Nano Technology.

The following is taken from http://www.epa.gov/EPA-PEST/2008/November/Day-19/p27204.htm


The following entities are listed as petitioners in the "Petition for Rulemaking Requesting EPA Regulate Nano-Silver Products as Pesticides":
1. International Center for Technology Assessment (CTA)
2. Center for Food Safety (CFS)
3. Beyond Pesticides
4. Friends of the Earth (FOE)
5. Greenpeace
6. Action Group on Erosion, Technology and Concentration
7. Center for Environmental Health (CEH)
8. Silicon Valley Toxics Coalition (SVTC)
9. Institute for Agriculture and Trade Policy (IATP)
10. Clean Production Action (CPA)
11. Food & Water Watch
12. Loka Institute
13. Center for the Study of Responsive Law (CSRL)
14. Consumers Union"

Apparently, only the above environmental groups pushing the EPA to regulate nano-silver have been given the proper contact information. This means their comments encouraging strict and overbearing regulation of nano-silver as a “new pesticide” by the EPA are the only comments being received by the EPA, to date.

We need to reverse that tide, or within a very short period of time we will see colloidal silver essentially regulated into oblivion.

"The Non Profit groups are well funded and currently sending out emails to their members:

Dear XXXXXXXXXX,

Nano-silver is a product of nanotechnology, a powerful new platform technology for taking apart and reconstructing nature at the atomic and molecular level. Increasingly manufacturers are infusing a large and diverse number of consumer products with nanoparticle silver ("nano-silver") for its enhanced "germ killing" abilities. Already at least 300 products containing nano-silver are on market shelves, ranging from household appliances and cleaners to clothing, cutlery, and children’s toys, to personal care products, packaging and coated electronics. Yet scientists agree that nanoparticles are fundamentally different substances from the larger scale cousins and that nanomaterials can create new and unique health and environmental risks that need new forms of safety testing.

While the nanotech market moves ahead largely unabated, as a recent National Research Council study concluded, regulators remains woefully behind the curve. Nano-silver is now the most common commercialized nano-material, but it has yet to undergo analysis by any U.S. regulatory agency of its potential human health and environmental impacts. Nano-silver may be highly destructive to natural environments and raises serious human health concerns. Studies have shown that nano-silver can harm fish and aquatic ecosystems, potentially interfere with beneficial bacteria in our bodies and the environment and encourage the development of more virulent harmful bacteria. The products are also misleadingly sold using very broad and unapproved health claims about the power of their nano-silver ingredients, such as: “eliminates 99% of bacteria” or “kills approximately 650 kinds of harmful germs and viruses.”

In May 2008 the International Center for Technology Assessment (ICTA) and the Center for Food Safety (CFS) filed a legal petition with the Environmental Protection Agency (EPA) on behalf of a coalition of public interest organizations calling on EPA to regulate nano-silver products as pesticides. The legal petition demands EPA assess the safety of these materials to the public and the environment before permitting commercialization. The petition also calls on the agency to require safety data from manufacturers and require mandatory and approved labeling. Finally, the petition calls on the agency to stop the sale of those nano-silver products currently on market until the agency properly assesses their impacts.

EPA has opened a public comment period on the ICTA/CFS petition and the nano-silver issue. With at least 300 consumer products containing nano-silver already on the market, many of them aimed at children, it is time for EPA to do its job and regulate nano-silver products as new pesticides.

TAKE ACTION NOW! Comments are being accepted until January 20th – please send your comment today urging EPA to grant the ICTA/CFS petition and to regulate nano-silver products as pesticides!

Visit the web address below to tell your friends about this.
Tell-a-friend!

If you received this message from a friend, you can sign up for Center for Food Safety."

As you can see the Enviros are twisting the facts. Silver is not being restructured. And how can any substance decreased in size engender the "cat becomes a dog" analogy?


A sample letter that you can sign your name at the Chronic-Fatigue-Syndrome website:

> Docket No. EPA-HQ-OPP-2008-0650
>
>
> Dear Docket No. EPA-HQ-OPP-2008-0650,
>
> Dear EPA Administrator Stephen L. Johnson, Docket No.
> EPA-HQ-OPP-2008-0650
>
> I write to express my support for the ICTA/CFS legal petition. I
> am concerned about the rapid introduction of these potentially
> hazardous nano-materials into our bodies and into our
> environment. Many products now include potentially dangerous
> nano-silver as a pesticide without any regulation or safety
> analysis from EPA. While the risks of nano-silver to the
> environment and human health are not completely understood,
> studies show that the fundamental properties of matter can
> change at the nano-scale, creating physical and chemical
> properties distinct from those of the same material in bulk
> form. The government's own investigations have concluded that
> current research and knowledge about nanomaterials' health and
> environmental impacts is wholly inadequate.


And a their response if you write to them stating you disagree with their position on Colloidal Silver

"Dear Steve,

I would like to thank you for your concern about the use of silver. We are well aware of the positive advantages to using silver. I would like to clarify, however, that the action alert we sent out regarding nano-silver is NOT silver as our ancestors knew it. It is another substance entirely and when we use the term nano-silver, we are not referring to the larger particles of silver that have been known to have health benefits. National Geographic gave a definition in 2006 that clearly explains the difference: Nanotechnology matters because familiar materials begin to develop odd properties when they're nanosize. It's like you shrink a cat and keep shrinking it, and then at some point, all at once, it turns into a dog.

We dont know what nanosilver can do, but we do know that it acts much differently than the large particles of silver you referred to in your email --which is exactly why manufacturers are using it and patenting it, because it is novel and different. One of the changes that nano-silver has is that it is a much more potent germ killer than larger particles of silver, in part because of its decreased particle size. With regard to the negative impacts nano-silver may pose, we are primarily concerned about environmental impacts, where studies have shown that the substance can be incredibly destructive to aquatic species. But human health safety cannot be assumed from testing done on bulk silver, as the two are entirely different substances.

I hope that this addresses your concerns.

Best wishes,

Allison Sack
Center for Food Safety
2601 Mission St. Ste. 803
San Francisco, CA 94110
415.826.2770"

Public comments are being taken until January 20th, but the EPA web site appears to offer no easy way to take and deliver such comments from the public.


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 on the EPA web site (at http://www.epa.gov/EPA-PEST/2008/November/Day-19/p27204.htm)
that 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=090...


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. 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 comments.

I would recommend to send at least one of each: FAX, Letters, and Emails. Ask everyone you know that you gave Colloidal Silver to do likewise.

I am copying the below Spencer Jones letter. And yes part of my post has cut pasted some of his information which bears repeating.

The environmental groups are making wild and invalid claims about nano-silver, stating that it is in immediate need of EPA regulation due to its alleged potential to harm the environment. They are also bombarding the EPA with petitions and letters demanding immediate regulation of all nano-silver products – referring to them as “new pesticides” due to the ostensible “harm” these products supposedly could cause to tiny creatures in the environment such as beneficial bacteria.

Yet not one study to date – I repeat, not one study -- has ever demonstrated nano-silver to have harmed any part of the environment. Instead, test tube and lab studies extrapolating its alleged negative effects on the environment have been conducted. And for the most part, these studies have been conducted by researchers hired by the environmental groups to demonstrate silver’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 nano-silver 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

What’s more, the environmental groups behind this drive to have nano-silver regulated into oblivion have re-defined the term “nano-silver” to include just about any 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 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 commercial nano-silver returns to the environment it is very rapidly degraded as it agglomerates 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).

The researchers who have ostensibly demonstrated harmful attributes of nano-silver on life forms such as bacteria or tiny minnows used extremely high quantities of pure commercially produced nano-silver products in their lab studies that will simply never be found in the overall environment, due to silver’s propensity to bond rapidly with a multitude of 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.

Here is what I posted through the EPA web site comment submission system earlier today. Whether or not it actually gets 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. 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 copied and 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 state.

In other words, once returned to the environment it is no longer nanosilver and 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 nano-silver 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 by neo-Luddite environmentalist groups to regulate nanosilver. 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 properties. This issue is moot; it is the proverbial "much ado about nothing."

Respectfully,


Hopefully we can make some positive impact against the proposal to have EPA regulate nano-silver as an environmental contaminant. We have only a short time, and if we fail we will likely see the demise of the colloidal silver availability in the future.

This is not a time to stick one's head in the sand.

Best Regards,

Argentum Metallicum

PS For those of you involved in Manufacture of Generators, The production and sale of nano silver related products not registered with the EPA as pesticide (even computer mouses and keyboards with coatings) will be fined.

The U.S. EPA fined a Southern California technology company $208,000 for “nano coating” pesticide and making unauthorized health claims on computer peripherals. The nano coating was Silver Particles.

From the EPA website, a news update "celebrating" their victory in California.
.
http://yosemite.epa.gov/opa/admpress.nsf/2dd7f669225439b78525735900400c31/16a190492f2f25d585257403005c2851!OpenDocument
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