Catching up with my email after a long day off the net, I see that a group of Non Government Organizations (NGOs) are urging EPA not to allow the use of an alleged nanotechnology-based dispersant in the Gulf of Mexico.  The letter from thirteen organizations was covered in a piece by Andrew Schneider on AOL Online earlier today – which had considerable pickup on the web from what I can tell.

Sadly, a combination of limited information from the company – Green Earth Technologies – and poor understanding by others – seems to have led to the situation being dominated by misunderstanding and misinformation.

Green Earth Technologies has been lobbying hard to get their product G-MARINE™ Fuel Spill Clean-UP! used in the Gulf of Mexico for some days now.  According to the company

G-MARINE Fuel Spill Clean-UP! is a unique blend of plant derived, water based and ultimate biodegradable ingredients specifically formulated to quickly emulsify and encapsulate fuel and oil spills. These plant derived ingredients are processed to form a colloidal micelle whose small particle size (1-4 nanometers) enables it to penetrate and breakdown long chain hydrocarbons bonds in oils and grease and holds them in a colloidal suspension when mixed with water. Once oil has been suspended in a nano-colloidal suspension, there is no reverse emulsion; the oil becomes water soluble allowing it to be consumed by resident bacteria in the water. This dispersant formula is protected by trade secrets pursuant to Occupational Safety and Health Agency (OSHA) Standard CFR-1910 1200. The ingredient list has been reviewed by the US EPA and contains no ingredients considered hazardous by OSHA.

Is seems to have been the “nano” in the above description – leading to the substance being dubbed a “nano-dispersant” – that has raised eyebrows.

The nano here is very small micelles – “particles” of molecules formed from molecules with one end that is attracted to water, and one which repels water.  I place particles in inverted commas as these really very small bubbles of one liquid in another – hardly like particles at all.  And like bubbles, they probably don’t last that long.

Reading the company’s Materials Safety Data Sheet (MSDS), it’s possible to get a good idea what is in the micelles – mainly natural oils, mild detergents and surfactants.  But the MSDS doesn’t go as far as being specific about the physical nature of the micelles.  This is not too surprising perhaps as micelles are commonly used in products, as well as occurring naturally.  They are also transient – they fall apart reasonably fast, just like bubbles.

Now to the letter from the NGOs.  It starts out

It has come to our attention that Green Earth Technologies (GET), Inc. is seeking approval from the EPA to disperse a large quantity of manufactured nanoparticles in the Gulf of Mexico, stating that the dispersal would remedy the oil spill recently suffered by the region. The for-profit company claiming to sell “totally green” products created from nanotechnology, wishes to scatter on land and in water its G- Marine Fuel Spill Clean-UP! (NANO Emulsion Technology) Oil Dispersant in areas affected by the BP rig collapse in the Gulf of Mexico.

The undersigned public-interest organizations respectfully urge the EPA to deny approval of this and similar projects that seek to release nanoscale chemicals or chemicals measuring less than 300 nanometers into the environment. In this case the company claims their product is composed of particles measuring 1-4nm. Manufactured nanoparticles have been shown to be toxic to humans, mammals, and aquatic life.

The argument made is that G-MARINE Fuel Spill Clean-UP! contains a nanoscale component, that nanoscale components have been shown to be toxic, therefore the dispersant should not be used.  The letter goes on to say:

We are not aware at this time of the exact nanoscale particles used in this ‘nano emulsion technology’ because this information is considered a trade secret by the company. Yet, we do know that most chemicals manufactured at the nanoscale hold unique and potentially toxic properties. While some new properties from the nanoscale may seem desirable, materials at this scale can also pose new toxicological risks. Nanoparticles have a very large surface area which typically results in greater chemical reactivity, biological activity and catalytic behavior compared to larger particles of the same chemical composition. Unfortunately, the greater chemical reactivity and bioavailability of nanomaterials may also result in greater toxicity of nanoparticles compared to the same unit of mass of larger particles. Other properties of manufactured nanomaterials that influence toxicity include: chemical composition, shape, surface structure, surface charge, catalytic behavior, extent of particle aggregation or disaggregation, and the presence or absence of other groups of chemicals attached to the nanomaterials.

Unfortunately, the letter falls into the all too common trap of mistaking a relatively unstable cluster of small molecules as a “nanoparticle,” and prejudicially tagging it with properties associated with very specific nanoparticles – many of which are unlikely to have any relevance here.

This is a serious mistake to make, as it undermines any science-based discussion of safety and risk by claiming the ingredient in question is something it is not, then inferring properties on it which it is unlikely to have.  And the danger here is that as soon as the science is taken out of the equation, the real likelihood of harm being caused becomes extremely difficult to address.

Then there is the AOL piece.

In the main, the piece is straight reporting of the situation – albeit with an emphasis on the nano-safety issue.  But one section in particular jumps out:

The report of the possible use of nano-dispersants has outraged Harbut, who heads the Environmental Cancer Initiative at Michigan’s Karmanos Cancer Institute.

“A decision to use nanoparticle-based dispersants in the gulf is less an engineering or environmental decision, but more a public health and individual patient care issue. As does asbestos, nanoparticles have been shown to cause an aggressive cancer called mesothelioma,” he said.

And like asbestos in its early usage, human health effects of exposure, ingestion or breathing of nanoparticles have been rarely observed, let alone studied.

“To dump tons of nanoparticles into the food and respiratory cycle in this manner is irresponsible,” Harbut told AOL News

Here, the conflation between nanoscale micelles, nanoparticles and mesothelioma is wrong and it is irresponsible.  Nanoparticles in general have not been shown to cause mesothelioma, neither is there any theory to suggest that they might – this is pie in the sky speculation.  Carbon nanotubes – a specific form of nanomaterial – might possibly be associated with the disease under some conditions, but this is still uncertain.  But carbon nanotubes are not what may would recognize as nanoparticles, and are certainly not the same as micelles.

Then there is the conflation between micelles and nanoparticles again.  Okay so technically a micelle might be likened to a nanoparticle – but in the same way a soap bubble might be likened to a soccer ball!

So where does this leave us?

The root of the problem here seems to have been Green Earth Technologies’ use of the term “nano” – if they had just talked about micelles, no red flags would have been raised and it’s unlikely that the NGO letter would have found its way to EPA.  This term clearly term led to some confusion amongst organizations sensitized to the word.

Nevertheless, it would be irresponsible to throw the safety concerns out simply because of a definitional technicality.

Nanoscale materials do raise new safety questions – including nanoscale micelles.  But often, these questions can be addressed to a reasonable degree.  I’m not going to defend the safety evaluations that have been made by Green Earth Technologies as I don’t have the data.  In fact the company possibly shoots itself in the foot by being rather optimistic about the safety of their product.  This appeared today in an open letter from the company for instance:

Does G-MARINE OSC-1809 Oil & Fuel Spill Clean-UP! have any adverse affects on humans / animals or the environment?

None whatsoever. G-MARINE OSC-1809 Oil & Fuel Spill Clean-UP! has shown absolutely no adverse effect on humans or animals. All of our Marine products are manufactured from ingredient LISTED ON THE EPA CLEAN INGREDIENTS (1) List. It has a zero OHSA hazard rating and in Lab Tests (2) it has been shown to have no adverse affects whatsoever to nose (inhalation), mouth (ingestion), ears, skin, or eyes. Even if the person is subjected to a concentrated overdose, there has been no noticeable adverse affect. The Micelles BECAUSE of the EXTREMELY SMALL SIZE do NOT persist in the environment and Bio-degrade into harmless elements in 10 days as per EPA guideline in the CLEAN INGREDIENTS list.

“None whatsoever” is a dangerous assertion to make on adverse effects, as it implies every possible test has been done, and every conceivable eventuality accounted for.  And people tend to be suspicious of such absolute statements – better to be honest and admit the bounds of current knowledge.  Yet it is reasonable to assume that small micelles made up of well-evaluated ingredients are unlikely to have long-term environmental impacts that go beyond that of these ingredients – mainly because the micelles will break up and release their constituent components reasonably rapidly.

Could they get to places where they can cause harm in the short term because of their size?  It’s possible – and I would hope that toxicity tests would at least indicate whether this is an issue.  But there is a danger of making up potential yet implausible harm scenarios here because of a misunderstanding of the differences between micelles and other forms of nanomaterials.

And this is perhaps the most important message to come out of this situation.  In the case of the Gulf oil spill, inaction is not an option – but informed action must be based on the best possible information rather than questionable speculation.  This places the onus on companies to get the safety testing on their products right, even if it means going above and beyond what they consider necessary (especially if they decide to use a loaded term like “nano”).  It means that regulators need to ready to move fast when questions like this are asked – delayed action or misinformed action both have the potential to lead to adverse consequences.  And it also means that organizations and individuals influencing the debate and the decisions made must make sure they get the science right – speculative fear can only be divisive.

Making wise choices on the dispersants used in the Gulf of Mexico is vitally important, and bad choices could have lasting consequences.  And it is right and proper that questions should be asked over the use of one product over another.  But if the spill is to be dealt with effectively, these choices must be science-informed – otherwise no-ones interests are served in the long run.

Andrew Maynard