nanotechnology and pesticide apparel · nanotechnology and regulation lexample: apparel that is...
TRANSCRIPT
Keller and Heckman LLPServing Business through Law and Science ®
®
Nanotechnology and Pesticide Apparel
February 5, 2004Hilton Crystal City
John B. Dubeck, Esq.Keller and Heckman LLP
(202) [email protected]
What is nanotechnology?
l Depends on who you askl National Nanotechnology Initiative
Definition:ØLength scale of 1-100 nanometersØNovel properties/functions related to
sizeØAbility to control/manipulate on atomic
scale
How big is a nanometer?
DNA~2-1/2 nm diameter
Things NaturalThings Natural Things ManmadeThings Manmade
Fly ash~ 10-20 µm
Atoms of siliconspacing ~tenths of nm
Head of a pin1-2 mm
Quantum corral of 48 iron atoms on copper surfacepositioned one at a time with an STM tip
Corral diameter 14 nm
Human hair~ 60-120 µm wide
Red blood cellswith white cell
~ 2 -5 µm
Ant~ 5 mm
Dust mite
200 µm
ATP synthase
~10 nm diameterNanotube electrode
Carbon nanotube~1.3 nm diameter
The Challenge
Fabricate and combine nanoscale building blocks to make useful devices, e.g., a photosynthetic reaction center with integral semiconductor storage.
Mic
row
orl
d
0.1 nm
1 nanometer (nm)
0.01 µm10 nm
0.1 µm100 nm
1 micrometer ( µm )
0.01 mm10 µm
0.1 mm100 µm
1 millimeter (mm)
1 cm10 mm
10 -2 m
10 -3 m
10 -4 m
10 -5 m
10 -6 m
10 -7 m
10 -8 m
10 -9 m
10 -10 m
Visi
ble
Nan
ow
orl
d
1,000 nanometers =
Infra
red
Ultra
viol
etM
icro
wav
eSo
ft x-
ray
1,000,000 nanometers =
Zone plate x -ray “lens”Outer ring spacing ~35 nm
Office of Basic Energy SciencesOffice of Science, U.S. DOE
Version 10- 07- 03, pmd
The Scale of Things The Scale of Things –– Nanometers and MoreNanometers and More
MicroElectroMechanical(MEMS) devices10 -100 µm wide
Red blood cellsPollen grain
Carbon buckyball
~1 nm diameter
Self -assembled,Nature -inspired structureMany 10s of nm
How big is a nanometer?
A hockey puck is 3 inches (or 76,200,000 nanometers) wide
It has an area of 4,560,000 square nanometers
What is nanotechnology used for?
l Water purification systemsl Catalystsl Drug delivery systemsl Clothing coating systemsl Nanocoatings on air conditioning
valves to reduce frictionl Many more applications in
development
What technology is on the horizon?
l Drug delivery systems
l Cooling chips
l Medical diagnostics
l Sensors for airborne pollutants
Concerns with small particle size
l Much promise, more uncertaintyl Toxicity? Reactivity?
l Studies with carbon nanotubes
Small particles: Steel
Small particles: TiO2
U.S. Government Initiative
Reaction to nanotech
“Given the concerns raised over nanoparticle contamination in living organisms, governments should declare an immediate moratorium on commercial production of new nanomaterials and launch a transparent global process for evaluating the socio-economic, health, and environmental implications of the technology.”
Reaction to nanotech
“Why not hold a citizens’ jury to determine scientific priorities on nanotechnology?”
Nanotechnology and pesticides
l Antimicrobial-treated clothing/fibers
l Microemulsions of pesticides
l Nanolayers of antimicrobials
Nanotechnology and regulatory schemes
l Emerging area—is EPA ready?
l Are current regulatory schemes adequate to address challenges posed by this technology?
Nanotechnology and regulation
l Example: Apparel that is made and then treated with a pesticideØCan damage fibers, alter material
vs.
l Apparel that is made from individual fibers that have a coating of pesticides
Regulatory issues, cont’d
l EPA’s regulatory system is set up on an agricultural model—very toxic pesticides over large area
l Nanotechnology is different
Other Nanotech Pesticide Examples
l Microemulsion with highly fabricated nanostructure
l Coated pesticide with unreactedingredients
More Regulatory Issues
l Issue: What kind of toxicity data would EPA require?
Exposure is considered.
Exposure is not considered. Why?
Regulatory issues, cont’d
l Is this the clash that will cause a restructuring of FIFRA?
l FQPA inserted special provisions in FIFRA for antimicrobials, allowing for different framework than other pesticides
Regulatory issues, cont’d
l How do you evaluate the toxicology of nanoparticles?
l Applications may be totally benign, and are difficult to accommodate in today’s regulatory structure
Regulatory challenges
l EPA must ensure public confidence in its decisions
l EPA must overcome public mistrust of government assurances of safety
Regulatory Questions
l Does EPA need a separate, specific pesticide nanotech rulemaking?
l Can EPA effectively deal with this technology under its current regulatory scheme?
l Occupational exposures?
Conclusion
l Emerging field
l Opportunities for industry and regulatory innovation and caution
l How will the government respond?
l How will the public respond?