Comments on: Resolving the carbon nanotube identity crisis http://2020science.org/2008/10/31/resolving-the-carbon-nanotube-identity-crisis/ Providing a clear perspective on developing science and technology responsibly Thu, 11 Mar 2010 19:49:49 +0000 http://wordpress.org/?v=2.9.2 hourly 1 By: Carbon Nanotubes http://2020science.org/2008/10/31/resolving-the-carbon-nanotube-identity-crisis/comment-page-1/#comment-10792 Carbon Nanotubes Thu, 21 May 2009 11:21:28 +0000 http://2020science.wordpress.com/?p=395#comment-10792 Hello, I have read your blog and I feel that the information about Resolving the carbon nanotube identity crisis share here it's really helpful to me... Thanks for it .. : ) Hello,
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]]> By: Working safely with carbon nanotubes http://2020science.org/2008/10/31/resolving-the-carbon-nanotube-identity-crisis/comment-page-1/#comment-9256 Working safely with carbon nanotubes Mon, 11 May 2009 09:46:28 +0000 http://2020science.wordpress.com/?p=395#comment-9256 [...] Resolving the carbon nanotube identity crisis [...] [...] Resolving the carbon nanotube identity crisis [...]

]]> By: Martin Griffin http://2020science.org/2008/10/31/resolving-the-carbon-nanotube-identity-crisis/comment-page-1/#comment-40 Martin Griffin Wed, 05 Nov 2008 19:14:56 +0000 http://2020science.wordpress.com/?p=395#comment-40 Another thought. Even if on a perfect world all variants of CNT are considered new under TSCA and PMNs are required, it appears to me that more than likely these CNT variants would be listed under the confidental portion of TSCA and this not available to anyone unless you are a manufacturer or an importer, so just listing something in TSCA still won't give the public or state government or anyone the crucial information that is submitted in the PMN. So even though it appears that EPA is moving forward and actually gathering necessary information to protect the environment and public healtht via the PMN requirements, who can actually use it to create policies to actually protect the environment and human health from unknowns. Any thoughts on this conundrum? Another thought. Even if on a perfect world all variants of CNT are considered new under TSCA and PMNs are required, it appears to me that more than likely these CNT variants would be listed under the confidental portion of TSCA and this not available to anyone unless you are a manufacturer or an importer, so just listing something in TSCA still won’t give the public or state government or anyone the crucial information that is submitted in the PMN. So even though it appears that EPA is moving forward and actually gathering necessary information to protect the environment and public healtht via the PMN requirements, who can actually use it to create policies to actually protect the environment and human health from unknowns. Any thoughts on this conundrum?

]]> By: Andrew Maynard http://2020science.org/2008/10/31/resolving-the-carbon-nanotube-identity-crisis/comment-page-1/#comment-39 Andrew Maynard Mon, 03 Nov 2008 22:16:51 +0000 http://2020science.wordpress.com/?p=395#comment-39 Thanks Martin. This is a pretty significant issue. Vicki Colvin's (Rice University) back-of-the-envelope estimation for the number of different "flavours" of carbon nanotubes is around 50,000 - and we don't yet know which attributes associated with these variations are important in initiating an adverse response. While major differences in nanotubes are likely to trigger the "new substance" part of TSCA - say, the difference between single walled and double walled carbon nanotubes - there are likely to be subtle differences that are not caught on the basis of unique molecular identity. Does this mean that broad categories of carbon nanotubes will appear on the TSCA inventory that allow materials of unknown hazard to slip through the net? Quite possibly, while EPA sticks to a rather out-moded approach of determining when a substance is new, and when it is not. Thanks Martin.

This is a pretty significant issue. Vicki Colvin’s (Rice University) back-of-the-envelope estimation for the number of different “flavours” of carbon nanotubes is around 50,000 – and we don’t yet know which attributes associated with these variations are important in initiating an adverse response.

While major differences in nanotubes are likely to trigger the “new substance” part of TSCA – say, the difference between single walled and double walled carbon nanotubes – there are likely to be subtle differences that are not caught on the basis of unique molecular identity.

Does this mean that broad categories of carbon nanotubes will appear on the TSCA inventory that allow materials of unknown hazard to slip through the net? Quite possibly, while EPA sticks to a rather out-moded approach of determining when a substance is new, and when it is not.

]]> By: Martin Griffin http://2020science.org/2008/10/31/resolving-the-carbon-nanotube-identity-crisis/comment-page-1/#comment-38 Martin Griffin Mon, 03 Nov 2008 21:52:13 +0000 http://2020science.wordpress.com/?p=395#comment-38 Excellent summary Dr. Maynard. However one more 'fly in the ointment' that needs elaboration is the lack of specifics on how CNT will be listed. As we all know one manufactured CNT could be completley dirrerent in purity, checmial make up etc to another maufactured CNT. And what about other nanomaterials embedded in the CNT interstitial spaces? Since CNT is such a general thing it is unclear how EPA will proceed when they get 20 PMN for 20 different variations of CNT. EPA also made no mention of SWCNT or the difference in SWCNT vs. DWCNT toxcicity in how they are synthesized. To use your analagy, CNT can be as different from one another as different cuts, qualities of diamonds, and as any jewler will tell you all diamonds are not the same. Keep up the good fight! Excellent summary Dr. Maynard. However one more ‘fly in the ointment’ that needs elaboration is the lack of specifics on how CNT will be listed. As we all know one manufactured CNT could be completley dirrerent in purity, checmial make up etc to another maufactured CNT. And what about other nanomaterials embedded in the CNT interstitial spaces? Since CNT is such a general thing it is unclear how EPA will proceed when they get 20 PMN for 20 different variations of CNT. EPA also made no mention of SWCNT or the difference in SWCNT vs. DWCNT toxcicity in how they are synthesized. To use your analagy, CNT can be as different from one another as different cuts, qualities of diamonds, and as any jewler will tell you all diamonds are not the same. Keep up the good fight!

]]> By: Andrew Maynard http://2020science.org/2008/10/31/resolving-the-carbon-nanotube-identity-crisis/comment-page-1/#comment-37 Andrew Maynard Fri, 31 Oct 2008 18:36:13 +0000 http://2020science.wordpress.com/?p=395#comment-37 Thanks Richard. I guess my bar for an enthusiastic response has been suppressed to a rather low level when it comes to nanomaterials and regulation. You are right though EPA could have acted long before now... Andrew Thanks Richard.

I guess my bar for an enthusiastic response has been suppressed to a rather low level when it comes to nanomaterials and regulation. You are right though EPA could have acted long before now…

Andrew

]]> By: Richard Denison http://2020science.org/2008/10/31/resolving-the-carbon-nanotube-identity-crisis/comment-page-1/#comment-41 Richard Denison Fri, 31 Oct 2008 17:40:38 +0000 http://2020science.wordpress.com/?p=395#comment-41 Andrew: Thanks for a very interesting post. While I agree EPA's more prominent clarification of its policy is welcome, I am dismayed by EPA's lax approach to enforcement of what is a basic violation of federal law. As you note, EPA has been stating for years that carbon nanotubes (CNTs) are new chemicals under TSCA requiring notification. EPA has also been alluding to there being considerable non-compliance with such requirements. Yet even this latest Federal Register notice merely says that in March 2009, EPA "anticipates" it will once again look at whether there is better compliance. If EPA was serious about ensuring compliance, all it would need to do would be to bring and publicize a single enforcement action, and I'd predict this issue would be resolved in a heartbeat! I've just added a post to our own blog ( http://www.edf.org/nanoblog ) that highlights yet more evidence of the ability of carbon nanotubes to pose risks to human health, which makes it all the more essential that EPA know who is producing or importing such materials. Andrew: Thanks for a very interesting post. While I agree EPA’s more prominent clarification of its policy is welcome, I am dismayed by EPA’s lax approach to enforcement of what is a basic violation of federal law. As you note, EPA has been stating for years that carbon nanotubes (CNTs) are new chemicals under TSCA requiring notification. EPA has also been alluding to there being considerable non-compliance with such requirements.

Yet even this latest Federal Register notice merely says that in March 2009, EPA “anticipates” it will once again look at whether there is better compliance.

If EPA was serious about ensuring compliance, all it would need to do would be to bring and publicize a single enforcement action,
and I’d predict this issue would be resolved in a heartbeat!

I’ve just added a post to our own blog ( http://www.edf.org/nanoblog ) that highlights yet more evidence of the ability of carbon nanotubes to pose risks to human health, which makes it all the more essential that EPA know who is producing or importing such materials.

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