202-547-9429

**Maureen McLain**

, ,

January 18, 2009 10:14 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am truly disturbed by the ease of which manufacturer can introduce
chemicals into our products, that have not been fully tested for safety
or use. STOP ALLOWING WE AMERICANS TO BE THE GUINEA PIGS FOR THE
CORPORATIONS!

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Maureen McLain

202-547-9429

**Howard Cohen**

3272 Cowper Street , Palo Alto, CA 94306

January 18, 2009 9:17 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Howard Cohen

3272 Cowper Street

Palo Alto, CA 94306

202-547-9429

**Carol Davis**

, ,

January 15, 2009 3:14 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Carol Davis

Sincerely,

Carol Davis

202-547-9429

**richard @ adelia lawless**

161 cedar road , southport, CT 06890

January 15, 2009 9:48 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

PLEASE THINK OF YOUR CHILDREN AND GRANDCHILD AS YOU CONSIDER THIS
REQUEST.

Thank you for taking OUR views under consideration.

Sincerely,

richard @ adelia lawless

161 cedar road

southport, CT 06890

202-547-9429

**Miss Karen Lund**

294 Oldfield Street , Staten Island, NY 10306

January 14, 2009 5:14 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Miss Karen Lund

294 Oldfield Street

Staten Island, NY 10306

202-547-9429

**Charity Derman**

17625 N 8th Ave , phoenix, AZ 85023

January 13, 2009 2:55 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We do not need to add any more toxins into our bodies or the
environment! The same property that makes these nanomaterials lucrative
to manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for your time.

Sincerely,

Charity Derman

17625 N 8th Ave

phoenix, AZ 85023

202-547-9429

**Pat Arnone**

3604 Lorne St SE , Tumwater, WA 98501

January 12, 2009 5:12 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

\*Please conduct proper, sound, scientific tests before putting the
American public at risk as is happening with genetically modified food
stuffs. At the very least, mandate accurate labeling on all items that
have been genetically altered. I deserve the option of knowing what and
how the items I buy have been made.\*

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Pat Arnone

3604 Lorne St SE

Tumwater, WA 98501

202-547-9429

**diane powers**

, ,

January 11, 2009 9:31 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

As a healthcare worker, I see the damaging effects of \"super bugs\"
first hand;patients are dying from common, once easily treatable
conditions such as urosepsis due mostly in part to antibiotic resistant
bacteria. This same bacteria was, until recently, killed off effectively
by the usual barage of antibiotics. The wide spread use of nano-silver
products for children have the potential to spread these super bugs into
the pediatric realm.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanom

Sincerely,

diane powers

202-547-9429

**Ann Albrecht**

14 Virginia Ave , Staunton, VA 24401

January 11, 2009 5:28 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Ann Albrecht

14 Virginia Ave

Staunton, VA 24401

202-547-9429

**Jeanne Sable**

, ,

January 11, 2009 5:03 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We, the public, do not wish to be exposed to yet another unlabeled,
under-tested technology that could have profound consequences on the
health or ourselves, our children, and the environment. I am referring
to nano-silver and other nano-products that are currently coming on the
market.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Jeanne Sable

202-547-9429

**Colin Meginnis**

333 58th Street , Des Moines, IA 50312

January 11, 2009 2:05 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Colin Meginnis

333 58th Street

Des Moines, IA 50312

202-547-9429

**Janice Ross**

, ,

January 11, 2009 1:52 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials so lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of these products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Janice Ross

202-547-9429

**Janet Gerske**

, Chicago, IL 60657

January 11, 2009 9:52 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Moreover, these nano particles are so small that they can penetrate
blood vessels and may breach the blood-brain barrier.

Haven\'t we done enough already to destroy our precious environment??

If for no other reason, these unprecedented materials must be regulated
as pesticides because of their germ-killing use. The agency should GRANT
the legal petition it has pending.

Thank you for taking my views under consideration.

Sincerely,

Janet Gerske

Chicago, IL 60657

202-547-9429

**Jon Sakata**

1394 11th ave , san francisco, CA 94122

January 10, 2009 10:54 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. Nano-silver can harm fish and aquatic ecosystems and
potentially interfere with beneficial bacteria in our bodies and the
environment.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Jon Sakata

1394 11th ave

san francisco, CA 94122

202-547-9429

**Shellee Davis**

8844 Cypress Ave. , Cotati, CA 94931

January 10, 2009 10:17 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Shellee Davis

8844 Cypress Ave.

Cotati, CA 94931

202-547-9429

**Louis Alvarez**

, ,

January 10, 2009 9:27 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

The EPA should carry out its primary purpose -to protect the public from
anvironmental hazards. To allow untested products on the market without
safety testing is contrary to that mission. If the business community
does not have any concern other than profit, then the EPA should force
the proper ethical action

Thank you for taking my views under consideration.

Sincerely, Louis Alvarez 1441 Willowbroo

Sincerely,

Louis Alvarez

202-547-9429

**Mary Miller**

2512 Freeland Court , Naperville, IL 60564

January 10, 2009 9:21 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Mary Miller

2512 Freeland Court

Naperville, IL 60564

202-547-9429

**Edlyn Clevenger**

P.O. Box 1011 , Maple Falls, WA 98266

January 10, 2009 5:13 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

All products should be labeled with what is in them and what is included
in their processing, period. We as consumers have a right to know with
reasonable ease (honest labeling being a good example of reasonable
ease) what is in the products we consume. Simple as that. Please, as our
representative, help keep us all well informed as to what products
contain

Sincerely,

Edlyn Clevenger

P.O. Box 1011

Maple Falls, WA 98266

202-547-9429

**Liz Dyer**

2161 Woodlawn Ave , Virginia Beach, VA 23455

January 10, 2009 11:36 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nano-materials attractive to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns.

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 wide range of products already available is creating broad and
intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways.

A 2005 study found that nano-silver is approximately 45 times more toxic
than standard silver. A 2008 study showed that washing nano-silver socks
releases substantial amounts of the nano-silver into the laundry
discharge water, which will ultimately reach natural waterways and
potentially poison fish and other aquatic organisms. Another 2008 study
found that releases of nano-silver can destroy benign bacteria used in
wastewater treatment.

These materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That requires current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Liz Dyer

2161 Woodlawn Ave

Virginia Beach, VA 23455

202-547-9429

**Joyce DuBois**

, ,

January 10, 2009 11:28 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Joyce DuBois

202-547-9429

**Juana Celia Djelal**

2446 Hickory Hill Drive , State College, PA 16803

January 10, 2009 9:59 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. Please be aware that nano-silver can harm fish and aquatic
ecosystems, can potentially interfere with beneficial bacteria in our
bodies and the environment, can encourage the development of more
virulent harmful bacteria. The wide range of products already available
is creating broad and intrusive exposures to the public and the
environment. Many of the products are meant for children (baby bottles,
toys, stuffed animals, and clothing) or otherwise create high human
exposures (cutlery, food containers, paints, bedding and personal care
products) despite very little study of nano-silver\'s potential human
health impacts. Nano-silver infused products may well be contaminating
the next generation, creating unheard of diseases.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

Such novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Juana Celia Djelal

2446 Hickory Hill Drive

State College, PA 16803

202-547-9429

**Oleta Shaw**

1Barndoor Hills Rd. , Granby, CT 6035

January 10, 2009 9:23 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

It is very upsetting to me to find that these nanomaterials are being
marketed to the public unlabeled. Persons who wish to avoid these
materials have no way of knowing if products contain them.

Thank you for taking my views under consideration.

Sincerely,

Oleta Shaw

1Barndoor Hills Rd.

Granby, CT 6035

202-547-9429

**Ellen Perchonock**

3300 Darby Rd. , Haverford, PA 19041

January 10, 2009 12:54 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns.

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 wide
range of products already available is creating broad and intrusive
exposures to the public and the environment.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

Thank you for taking my views under consideration.

Sincerely,

Ellen Perchonock

3300 Darby Rd.

Haverford, PA 19041

202-547-9429

**Lezlie Dalton**

12 East 22nd Street #12C, New York, NY 10010

January 9, 2009 10:08 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am concerned because the same property that makes these nanomaterials
lucrative to manufacturers\--their highly enhanced germ-killing
action\--can be highly destructive to the environment and raise serious
human health concerns.

Please be aware that Nano-silver can harm fish and aquatic ecosystems.
It can potentially interfere with beneficial bacteria in our bodies and
the environment. This will encourage the development of more virulent
harmful bacteria. The wide range of products already available is
creating broad and intrusive exposures to the public and the
environment. Many of the products are meant for children (baby bottles,
toys, stuffed animals, and clothing) or otherwise create high human
exposures (cutlery, food containers, paints, bedding and personal care
products) despite that fact that there has been very little study of
nano-silver\'s potential human health impacts.

Silver is known to be toxic to fish and aquatic organisms, and recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. In 2005, study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

In conclusion I want to say that the corporations/manufacturers that
create these technologies MUST BE REIGNED IN. This is an era in which
the pursuit of corporate profit has become the font of so many human and
planetary ills that it becomes almost unbelievable. It is simply hard to
grasp that there are those among

Sincerely,

Lezlie Dalton

12 East 22nd Street

#12C

New York, NY 10010

202-547-9429

**Susan Morris**

PO Box 10 , Jasper, AR 72641

January 9, 2009 5:11 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I have been batteling cancer and an auto-immune disorder for two years
now. All of my doctors have told me to live in as clean an environent as
possible. They were specifically referring to toxins like metal fumes,
paint fumes, solvents and household cleaning chemicals. Nano-particles
DO NOT fit into the plan for my health issues. PLEASE REGULATE
nanomaterials as pesticides and CLEARLY LABEL ALL PRODUCTS INCLUDING
CLOTHING as containing nanomaterials.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk asses

Sincerely,

Susan Morris

PO Box 10

Jasper, AR 72641

202-547-9429

**C. Schuett**

910 5TH St Ne. , Little Falls, MN 56345

January 9, 2009 4:38 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending.

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

C. Schuett

910 5TH St Ne.

Little Falls, MN 56345

202-547-9429

**Carrie Sedotto**

, ,

January 9, 2009 9:00 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

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.

Many of the products are meant for children (baby bottles, toys, stuffed
animals, and clothing) or otherwise create high human exposures
(cutlery, food containers, paints, bedding and personal care products)
despite very little study of nano-silver\'s potential human health
impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Carrie Sedotto

202-547-9429

**Cecilia Brown**

, ,

January 9, 2009 7:54 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Why do we always allow things that we do not fully understand only to
later find that they have a negative impact on the environment and
humans and wildlife. Humans have a history of this. Then it is too late
or costs way to much to fix it. We should put an end to this cycle of
stupidity. Nonomaterials are an untested new technology that should be
tested before being allowed to be used in products. I go to great
lengths to ensure the health and safety of products for my family.
Shouldn\'t the EPA feal the same about Americans?

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Cecilia Brown

202-547-9429

**Anne Pyciak**

4619 Hatherly Place , Sterling Heights, MI 48310

January 8, 2009 11:21 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Why in the U.S.A. do we have to tell you to run safety checks on thinks
, ?

Thank you for taking my views under consideration.

Sincerely,

Anne Pyciak

4619 Hatherly Place

Sterling Heights, MI 48310

202-547-9429

**Mr & Mrs Terry and Jana Carlson**

402 SE 3rd Avenue , Cook, MN 557239726

January 8, 2009 6:48 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns.

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 wide
range of products already available is creating broad and intrusive
exposures to the public and the environment.

Shockingly, many of the products are meant for children (baby bottles,
toys, stuffed animals, and clothing) or otherwise create high human
exposures (cutlery, food containers, paints, bedding and personal care
products) despite very little study of nano-silver\'s potential human
health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways.

A 2005 study found that nano-silver is approximately 45 times more toxic
than standard silver. A 2008 study showed that washing nano-silver socks
releases substantial amounts of the nano-silver into the laundry
discharge water, which will ultimately reach natural waterways and
potentially poison fish and other aquatic organisms. Another 2008 study
found that releases of nano-silver can destroy benign bacteria used in
wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you.

Sincerely,

Mr %pa_first_name% Mrs Terry and Jana Carlson

402 SE 3rd Avenue

Cook, MN 55723-9726

202-547-9429

**Maia Maia**

332 Ellwood Beach Drive , Goleta, CA 93117

January 8, 2009 6:39 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Nano-silver\'s enhanced germ-killing action can be highly destructive to
the environment and raises serious human health concerns.

Nano-silver can harm fish and aquatic ecosystems, potentially
interfering with beneficial bacteria in our bodies and the environment,
and encouraging the development of harmful bacteria.

Products already available are creating involuntary exposures to the
public and the environment despite very little study of nano-silver\'s
potential human health impacts.

Please GRANT the legal petition now pending which would include the
following:

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* Current and future nano-silver products must undergo mandatory EPA
pre-market approval.

\* Current products will be removed until and unless they received EPA
approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment and human health

Thank you.

Sincerely,

Maia Maia

332 Ellwood Beach Drive

Goleta, CA 93117

202-547-9429

**Carole Plumb**

17 Bald Rock Rd , Wayland, MA 01778

January 8, 2009 6:19 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--could be
highly destructive to the environment and raise serious human health
concerns. Despite few serious studies of nano-silver\'s potential human
health impacts, a wide range of products have already been made
available to the public and entered into the environment.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Carole Plumb

17 Bald Rock Rd

Wayland, MA 01778

202-547-9429

**Lois Drummer**

7028 Westmoreland Drive , Fairfield, AL 35064

January 8, 2009 5:56 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I agree whole-heartedly that the EPA must regulate nano-silver as
pesticides. Consumers who purchase items containing this product are as
much as paying to inherit a health DISASTER then paying to be cured.
What the Hell\'s happening to this nation? This is an outrage!!! The
same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for considering my views.

Sincerely,

Lois Drummer

7028 Westmoreland Drive

Fairfield, AL 35064

202-547-9429

**Phyl Morello**

984 Harrison Ferry , White Pine, TN 37890

January 8, 2009 4:44 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Please stop the big companies from ruling the way you vote. Stop
protecting big business. Protect the US citizen.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Phyl Morello

984 Harrison Ferry

White Pine, TN 37890

202-547-9429

**joseph lawson**

, ,

January 8, 2009 4:44 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

\*

Thank you for taking my views under consideration.

Sincerely,

joseph lawson

202-547-9429

**Michelle Angelroth**

2521 N Downer Ave Apt D , Milwaukee, WI 53211

January 8, 2009 3:12 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

While I understand the desire to push forward with new technologies, it
is not fair to the American consumer to use nanomaterials in common
household products without their knowledge. Complete and accurate
labeling of goods and their contents is essential to a market economy so
that consumers can make fully informed decisions.

Furthermore, the general public does not yet know enough about
nanomaterials to make informed decisions. We depend on our regulatory
agencies to do extensive studies before allowing manufacturers to put
things in our goods that could be harmful to our selves and/or our
environment. Without thorough evaluation and regulation of ALL new
materials, there is no purpose to having regulatory agencies. Please
offer the American people more than a false sense of security!

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Michelle Angelroth

2521 N Downer Ave Apt D

Milwaukee, WI 53211

202-547-9429

**Sheryl Warren**

371 Harding Road , Willilamsville, NY 14221

January 8, 2009 2:55 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

We, as a nation, have already done irreparable damage to ourselves and
our environment all in the name of \"progress\". There is not yet
sufficient information available to make informed decisions regarding
nano-silver. What we do not know can not only hurt us, it can kill us.

Thank you for taking my views under consideration.

Sincerely,

Sheryl Warren

371 Harding Road

Willilamsville, NY 14221

202-547-9429

**Karen Campbell**

, ,

January 8, 2009 1:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. How could this \"stuff\" become a part of our environment so
quickly and no one has really heard about it? If there wasn\'t a problem
manufacturers would be shouting about how great it is from the roof
tops. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration. We need less
pesticides in our environment, not more. We don\'t fully understand what
has been around for decades and this pesticide isn\'t something we
can\'t

Sincerely,

Karen Campbell

202-547-9429

**Hjordis Rickert**

, ,

January 8, 2009 12:12 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely, Hjordis Rickert

Sincerely,

Hjordis Rickert

202-547-9429

**diana Mackin**

486 N Kellogg St , Galesburg, IL 614013725

January 8, 2009 11:53 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

My personal preference would be to follow the Precautionary Principle
\-- do not release any product until and unless it has been
safety-tested for years and proven clearly to be safe and effective! To
do less is foolish, probably ultimately deadly, and not likely to be
considered, therefore I offer the following:

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
dangerously destructive to the environment and raise serious human
health concerns. 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 wide range of products already available is creating broad
and intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

diana Mackin

486 N Kellogg St

Galesburg, IL 61401-3725

202-547-9429

**Patricia Grames**

4251 W Camino Pintoresco , Tucson, AZ 85745

January 8, 2009 11:53 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We already have too many food safety and environmental problems caused
by not understanding consequences of new technology. We don\'t need
more!

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Patricia Grames

4251 W Camino Pintoresco

Tucson, AZ 85745

202-547-9429

**Augustin Parker**

36 Arthur Avenue , Marblehead, MA 019451108

January 8, 2009 10:44 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.
Probably all products that claim to kill germs should be assessed for
risk to the environment.

Thank you for taking my views under consideration.

Sincerely,

Augustin Parker

36 Arthur Avenue

Marblehead, MA 01945-1108

202-547-9429

**Mel Dickerson**

611 W. Chicgo Blvd. , Tecumseh, MI 49286

January 8, 2009 10:29 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

As a biologist I appreciate the potential good presented by nanoparticle
technology . However, even old technology can be very dangerous as is
plainly evident to everyone but policy makers and govt. regulators. Case
in point is the uncontrolled use of antibiotics in the livestock
industry a situation that gets worse and more dangerous every day.
100,000 people die each year in the US due to infections caused by
polyantimicrobial resistant organisms. Nanoparticle technology by
comparison is a totally unexplored domain whose negative impact on
organisms could dwarf the effects of antibiotics. It is time for the FDA
to act like a science driven organization and begin corporation financed
testing of the hundreds of products already being tested directly on the
human population. It\'s time to fulfill your mandate to protect the
health of Americans.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed d

Sincerely,

Mel Dickerson

611 W. Chicgo Blvd.

Tecumseh, MI 49286

202-547-9429

**Kathy Meyer**

218 N. Campbell Street , Pleasant Hill, MO 64080

January 8, 2009 9:28 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Kathy Meyer

218 N. Campbell Street

Pleasant Hill, MO 64080

202-547-9429

**Nuntanit Bumrungsap**

335, Praram 9 Soi 49, Seri 6 Road, Suanluang , Bangkok, 10250 Thailand

January 8, 2009 4:14 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for your time and consideration on this crucial matter.

Sincerely,

Nuntanit Bumrungsap

335, Praram 9 Soi 49, Seri 6 Road, Suanluang

Bangkok 10250

202-547-9429

**Wayne Graham**

, ,

January 8, 2009 2:59 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Thank God you sell your own children out for a buck.

Thank God there is a judgement.

Wayne Graham

Sincerely,

Wayne Graham

202-547-9429

**Mandy Reinhold**

, ,

January 8, 2009 2:37 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Mandy Reinhold

202-547-9429

**Mary Anne Cole**

131 Tenbury Rd. , Lutherville, MD 21093

January 8, 2009 2:07 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Mary Anne Cole

131 Tenbury Rd.

Lutherville, MD 21093

202-547-9429

**Debbi Emerson**

4701 Cody Ave , Springdale, AR 72762

January 8, 2009 12:33 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am agreeing with the information from the ICTA unless the EPA AND
another source does further research that can disprove the current
facts. (Allowing this to go unregulated is the same as allowing \"food
supplements\" to be allowed to make claims about the health benefits
available from whatever supplement they are selling.)

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views, along with all the others you will
receive, under c

Sincerely,

Debbi Emerson

4701 Cody Ave

Springdale, AR 72762

202-547-9429

**Sharon Grimes**

, ,

January 8, 2009 12:17 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We need to know more about how these materials work before unleasing
them into the environment.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Sharon Grimes

202-547-9429

**Tierra Dulce**

673 65th St , Oakland, CA 94609

January 7, 2009 11:14 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Hello. Wake up. Humans are part of the web of life and will undoubtedly
suffer from the introduction of a material that is so destructive to
bacteria. Stop the folly now!!

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Tierra Dulce

673 65th St

Oakland, CA 94609

202-547-9429

**Judith Plantz**

6575 Wagner Court , E. Lansing, MI 48823

January 7, 2009 9:50 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

C\'mon people. You\'re killing us!! Let\'s quit the nonsense and stop
propping up big agra business and big Pharma.

We need better health decisions and better control over what is in our
food. Look at the current rise is diabetes cases. Do you suppose high
fructose corn syrup might be to blame? Or other additives?

Most of us can\'t afford to buy organic foods, so we depend on the FDA
to take care of the food supply. So far, FDA is failing in its job.

We need your help to protect us from the chemical industry.

Sincerely,

Judith Plantz

6575 Wagner Court

E. Lansing, MI 48823

202-547-9429

**dionne dupre**

738 herald st , new orleans, LA 70131

January 7, 2009 9:19 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Please, please, do the job you have been entrusted to do and that is to
PROTECT!!!

At the very least, I would like to see nano-silver and other nano
products labeled as such so that I, a consumer in the Great United
States of America, can make an INFORMED CHOICE.

Thank you for taking my views under consideration.

Sincerely,

dionne dupre

738 herald st

new orleans, LA 70131

202-547-9429

**Phoebe Perry**

6102 Providence Ct. , Fredericksburg, VA 22407

January 7, 2009 7:59 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

It is frightening! The same property that makes these nanomaterials
lucrative to manufacturers\--their highly enhanced germ-killing
action\--can be highly destructive to the environment and raise serious
human health concerns. 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 wide range of products already available is creating broad
and intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts. Please
put a stop to what may be irreversable damage!

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Phoebe Perry

6102 Providence Ct.

Fredericksburg, VA 22407

202-547-9429

**Lynda Marin**

440 Ben\'s Way , Watsonville, CA 950760434

January 7, 2009 7:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am very concerned about the inclusion of nono-silver into our
household products.

Altough nano-silvers render these products more germ free, they may
causing enormous destruction to our environment and raise serious human
health concerns. 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 wide range of products already available is creating broad
and intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Lynda Marin

440 Ben\'s Way

Watsonville, CA 95076-0434

202-547-9429

**eva mostoufi**

1173 north rd , carlisle, MA 01741

January 7, 2009 6:49 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We need EPA to protect the consumer it may be too late to step in years
later after the damage has already have been done to people or the
environment. I am perfectly happy cleaning more often without taking
risks. I want to be able to make the choices on what I am buying I want
to hear that the product contains nano materials. I will make the
decision what I buy with my money.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my vi

Sincerely,

eva mostoufi

1173 north rd

carlisle, MA 01741

202-547-9429

**Daniel Williams**

201 SW Mildred Court , Lake City, FL 32024

January 7, 2009 5:57 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I urge you to take caution with this issue, as with any new technology
we simply don\'t know enough about. History has shown us that ignorance
can be catastrophic.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Daniel Williams

201 SW Mildred Court

Lake City, FL 32024

202-547-9429

**Necia Refes**

341 Lafayette #4144 , New York, NY 10012

January 7, 2009 5:27 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Haven\'t we learned anything about unintended consiquences? We need to
put the brakes on here!!!! With out studying the impact to our
environment and to our health this is a dangerous step. Once things are
let out of the bottle - it\'s impossible to stop the flow of
consequences that follow. We must put this nano-material under analysis.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Necia Refes

341 Lafayette #4144

New York, NY 10012

202-547-9429

**Carole Benner**

P. O. Box 19126 , Jean, NV 89019

January 7, 2009 5:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment. And after all the fuss made over
colloidal silver - a product that has been in use for a long time with a
track record - I am unable to understand why nano silver would be
allowed into the environment without serious examination.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. We should not even allow it into the environment. I am
against using it even as a pesticide.

I live in a closed water basin. Everyone here has an well, and obtains
their water from the ground right under us. If our basin becomes
contaminated with nano silver that is released into the septic tank via
the washing machine, we may be poisoned by the very water we depend on
to drink and wash in.

Please seriously consider the consequences of allowing the use of nano
silver and support the petitions against its use.

Thank you, Carole Benner P. O. Box 19126 Jean, NV 89019

Sincerely,

Carole Benner

P. O. Box 19126

Jean, NV 89019

202-547-9429

**Lauran Emerson**

157 Latham Works Lane , White River Junction, VT 05001

January 7, 2009 5:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Please use the Precautionary Principle in your decisions on this
technology: require full studies on environmental impacts before any
approval.

Sincerely,

Lauran Emerson

157 Latham Works Lane

White River Junction, VT 05001

202-547-9429

**erinn hennessy**

, , FL 33469

January 7, 2009 4:59 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We must pat attention to the choices we are responsible for making. It
is up to only us. To not consider the many impacts of these choices is
detrimental. The same property that makes these nanomaterials lucrative
to manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

erinn hennessy

FL 33469

202-547-9429

**Peggy Malnati**

35935 W. 14 Mile Rd. , Farmington Hills, MI 48331

January 7, 2009 4:43 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I have worked in the nanotechnology area since the mid-1990s. While
nanotechnology has very interesting potential, just like genetically
modified organisms, it is being commercialized too rapidly without
having had little long-term study about potential adverse effects.
Relying on the manufacturer to do this proactively in such a highly
competitive global market is unrealistic. And history conforms for us
that if no one is LOOKING for potential adverse issues with a
technology, none will be found until it is too late!

The same properties that makes nanosilver lucrative to
manufacturers\--its highly enhanced germ-killing action at very low
dosing levels and its ability to be patented for a market
advantage\--can be highly destructive to the environment and raise
serious human health concerns while also making it hard to learn what
has caused the problem (since manufacturers do not have to disclose
their formulations). Just like GMO foods, if a wide-scale outbreak
erupts, it will be hard to identify the cause.

Because this technology is literally \"nano\" scale, it can easily pass
the blood/brain barrier. Recent research has shown that carbon nanotubes
\-- on the market since the late 1980s \-- can cause massive brain
hemorrhage in fish. There is equal concern about workers being exposed
to dust from machined plastic parts containing nanotubes and nanoclays
due to potential allergenic & respiratory problems.

An earlier precursor to nanosilver \-- colloidal silver additives (used
in rubber and plastic parts for close to a decade to impart
antimicrobial properties) \-- have the advantage that no bacteria have
ever been found that can mutate against it. Such is its effectiveness in
quashing bacteria and molds. If nanosilver shows the same level of
effectiveness, how long will it be before it begins to interfere with
beneficial bacteria in our bodies, in wastewater treatment plants, and
the environment. The wide range of products already available is
creating broad and intrusive exposures to the public and the
environment.

We\'ve reformulated many products previously dosed with triclosan, a
very harmful antimicrobial chemical used in handsoaps that DOES NOT
break down, but rather bio-accumulates in waterways. It has actually
found its way into human breast milk. Triclosan was made widely
available without studying its effect on the environment with health
claims purporting that it killed germs on hands on contact \-- it
doesn\'t kill on contact, requiring at least 3 minutes of exposure to be
effective. Now we\'re taking the same steps to reformulate products
again with nanosilver and making them widely available without testing
them thoroughly. Do we never learn?

Of even greater concern, many of the products containing nanosilver are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nanosilver\'s potential human or environmental health impacts.

While elemental silver is known to be toxic to fish and aquatic
organisms, recent

Sincerely,

Peggy Malnati

35935 W. 14 Mile Rd.

Farmington Hills, MI 48331

202-547-9429

**Carol Kenny**

, ,

January 7, 2009 3:18 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

I am so tired of receiving phone calls that loved ones have some form of
cancer. And I can\'t help but believe that is from all the chemicals we
put into our body.

Thank you for taking my views under consideration.

Sincerely, Carol Kenny 1148 Pea Pond Road North Bellmore, NY 11710

Sincerely,

Carol Kenny

202-547-9429

**Gayle Spencer**

2603 Alpine Road , Menlo Park, CA 94025

January 7, 2009 2:45 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

These nano products and in particular nano-silver are extremely
worrisome. There definitely need to be control and study of these
products - before we ruin our health and environment.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Gayle Spencer

2603 Alpine Road

Menlo Park, CA 94025

202-547-9429

**elhame hoxha**

, ,

January 7, 2009 2:12 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

My suport for the ICTA/CFS legal petition.

I am concerned about the speed of nanotech and the products we are
probebly eatting now that contain nano particles which are not regulated
and not even leabled. I have done a research paper on nanothechnology
and the information i found are shocking. Governments all around the
glob, UK,UN, Japan and so and so are taking precautions and regulating
nanotech eccept US.It makes sence. We are the leading producers and EPA
and FDA, is not duing enough to stop this.

YaleEnviornment360 writtan by Carla Bass is a clear and non biest
article on how clules the goernment is on this aspect. They themselves
are in shock. We urge the EPA to push and solve this crises we are
facing so are kids are not going to be the victim of this fast and
dengerous technology.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to co

Sincerely,

elhame hoxha

202-547-9429

**Mary Knott**

205 River Road , Platteville, CO 80651

January 7, 2009 2:05 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Mary Knott Colorado

Sincerely,

Mary Knott

205 River Road

Platteville, CO 80651

202-547-9429

**Karah Stokes**

706 Hambrick Avenue , Lexington, KY 40508

January 7, 2009 2:05 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

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.

Many of the products are meant for children (baby bottles, toys, stuffed
animals, and clothing) or otherwise create high human exposures
(cutlery, food containers, paints, bedding and personal care products)
despite very little study of nano-silver\'s potential human health
impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Karah Stokes

706 Hambrick Avenue

Lexington, KY 40508

202-547-9429

**Dawn Abbey**

1660 N 59th Street , Mesa, AZ 85205

January 7, 2009 1:53 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Any man-made or bio-engineered products should be confined and carefully
tested before introducing them to the environment and especially to
consumer products. Give inventors longer patent protection so they are
not so eager to cash in on products that may someday come back to haunt
us.

Thank you

Dawn Abbey.

Sincerely,

Dawn Abbey

1660 N 59th Street

Mesa, AZ 85205

202-547-9429

**Michael Letendre**

92 Cass St. #1 , Portsmouth, NH 03801

January 7, 2009 1:53 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Please don\'t use the public as guinea pigs. Err on the side of caution
and do the studies first. Don\'t assume it\'s safe.

Thank you for taking my views under consideration.

Sincerely,

Michael Letendre

92 Cass St. #1

Portsmouth, NH 03801

202-547-9429

**thomas aldridge**

296 s 13 st , san jose, CA 95112

January 7, 2009 1:43 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Has Dr STRANGELOVE taken over the EPA????It appears that Stephen Johnson
needs the services of a professional EXORCIST!!!!The same property that
makes these nanomaterials lucrative to manufacturers\--their highly
enhanced germ-killing action\--can be highly destructive to the
environment and raise serious human health concerns. 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 wide range of
products already available is creating broad and intrusive exposures to
the public and the environment. Many of the products are meant for
children (baby bottles, toys, stuffed animals, and clothing) or
otherwise create high human exposures (cutlery, food containers, paints,
bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

thomas aldridge

296 s 13 st

san jose, CA 95112

202-547-9429

**Mary E. Piper**

, Hamburg, NJ 07419

January 7, 2009 1:33 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Introducing new materials into products without proper testing to
promote the marketplace is reckless and extremely dangerous. Once these
products are on the market, it is very difficult to attribute \"cause\"
to any negative impact if it is slow to show itself, causing much pain
and suffering to untold numbers of people, Please have these new
nanomaterials well researched before allowing them to flood the market.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide pro

Sincerely,

Mary E. Piper

Hamburg, NJ 07419

202-547-9429

**anne marie havel**

59 saw mill hill , wells, VT 05774

January 7, 2009 12:37 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

As a consumer and American citizen i am extremely upset that so much
enters our environment with woefully inadequate testing. I cannoto help
but feel like a human guinea pig. It is time that EPA uses its mandate
for the public good. Thank you for taking my views under consideration.

Sincerely,

anne marie havel

59 saw mill hill

wells, VT 05774

202-547-9429

**Dorothy Davis**

5227 Mercedes Ave , Dallas, TX 75206

January 7, 2009 12:22 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I use a dietary stable form of Colloid of Silver due to my family\'s
inability to use antibiotics without side effects, mainly \"A Plastic
Anemia\". I would not like to confuse that product with the nano silver
particles showing up in all sorts of products with no research or
regulation.

We have an abundance of toxic materials in our food and water without
adding more to the mix. Industrial pharmaceuticals have taken their toll
on the human and animal species.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific d

Sincerely,

Dorothy Davis

5227 Mercedes Ave

Dallas, TX 75206

202-547-9429

**ANA MARIA OBRIST**

, ,

January 7, 2009 12:13 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely, ANA MARIA OBRIST CHILE

Sincerely,

ANA MARIA OBRIST

202-547-9429

**Jillian Greenriver**

, , OH

January 7, 2009 11:40 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you very much!

Sincerely,

Jillian Greenriver

OH

202-547-9429

**Adam Mizicko**

4575 La Madera Road , Sandia Park, NM 87047

January 7, 2009 11:40 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

If nanomaterials such as nanosilver are so toxic to germs, how can we
release them willy-nilly into our environment without some sort of
testing? The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Adam Mizicko

4575 La Madera Road

Sandia Park, NM 87047

202-547-9429

**beth helm**

, ,

January 7, 2009 11:00 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts. really tired of all the
washington crap..it\'s always money & greed.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

beth helm

202-547-9429

**bj hedahl**

3019 NE 95th , seattle, WA 98115

January 7, 2009 10:53 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

MORALS or MONEY; what runs this country and YOUR life??

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

bj hedahl

3019 NE 95th

seattle, WA 98115

202-547-9429

**David Campbell**

, ,

January 7, 2009 10:41 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Please keep your nano-silver out of my body!

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

David Campbell

202-547-9429

**Daphne T Stevens**

15 Arnold Rd , Fiskdale, MA 01518

January 7, 2009 10:20 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Urgent, Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver
products as new pesticides

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.

Because our planet is in serious trouble, because we are all part of an
interdependent web of life, I urge you to study this product very
carefully. The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

You have the power to make a difference. ACT NOW.

Thank you for taking my views under consideration.

Sincerely,

Daphne T Stevens

15 Arnold Rd

Fiskdale, MA 01518

202-547-9429

**Mark Feldman**

137 Winchester Drive , Santa Rosa, CA 95401

January 7, 2009 10:15 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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 wide range of products already available is creating broad and
INTRUSIVE EXPOSURES to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Mark Feldman

137 Winchester Drive

Santa Rosa, CA 95401

202-547-9429

**Greg Carter**

, ,

January 7, 2009 10:15 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

There needs to be a significant undertaking to better understand the
benefits and particularly the risks of nanoparticles that are used in
consumer products. As anyone who has any knowledge of the natural
sciences understands, life as we know it cannot exist without beneficial
microbes. I have complete confidence that nanoparticles are not smart
enough to distiguish between beneficial and harmful. As someone who has
researched cancer causing agents for the National Toxicology Program,
what I have been most concerned about are the consumer products and
drugs that have been approved for use that have ultimately been proven
to be carcinogenic. I have complete faith that down the road we will
realize, well after there has been substantial damage caused, that
nanoparticles have dire consequences on microenvironments, both good and
bad, including those that we as humans need.

Sincerely,

Greg Carter

202-547-9429

**Mark May**

2151 NW 73 Ave , Sunrise, FL 333133849

January 7, 2009 10:05 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Mark May

Sincerely,

Mark May

2151 NW 73 Ave

Sunrise, FL 33313-3849

202-547-9429

**Amy Seyfried**

3215 Ashwood Lane , Carmichael, CA 95608-3203

January 7, 2009 9:28 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Amy Seyfried

Sincerely,

Amy Seyfried

3215 Ashwood Lane

Carmichael, CA 95608-3203

202-547-9429

**April Koning**

11116-98th St. , Fort St. John, BC v1j3w5 Canada

January 7, 2009 9:26 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

April Koning British Columbia, Canada

Sincerely,

April Koning

11116-98th St.

Fort St. John, BC v1j3w5

202-547-9429

**Deb Kovacs**

4318 Fox Creek Drive , CRYSTAL LAKE, IL 60012

January 7, 2009 7:19 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. To me, this is absurd until more testing can be conducted!!
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. Nice, huh?
The wide range of products already available is creating broad and
intrusive exposures to the public and the environment. Why? Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts. I believe
it is time for the EPA to stop looking the other way and conduct their
investigations!

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. Unbelievable!! A
2008 study showed that washing nano-silver socks releases substantial
amounts of the nano-silver into the laundry discharge water, which will
ultimately reach natural waterways and potentially poison fish and other
aquatic organisms. (Not to mention what it might do to the human
laundry!)Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending, without a doubt! As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
MANDATORY EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval, immediately!

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment. Time to get busy!

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments. This DOES
need to be assessed!

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling, at the very least!

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration and please l

Sincerely,

Deb Kovacs

4318 Fox Creek Drive

CRYSTAL LAKE, IL 60012

202-547-9429

**elizabeth foster**

elifoster@hotmail.com , ,

January 7, 2009 7:04 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration. THESE STATEMENTS SEEM
LOGICAL TO ME. ALTHOUGH I DO NOT HAVE A SCIENTIFIC BACKGROUND, IT
APPEARS TO MAKE SENSE THAT ALL PRODUCTS USED ON FOODS AND ITEMS FOR
CONSUMER USE SHOULD BE TESTED TO THE HIGHEST LEVEL, FOR SAFTY AND
ENVIRONMENTAL IMPACT.

SINCERELY, ELIZABETH FOSTER NAPLES, FLORIDA

Sincerely,

elizabeth foster

elifoster@hotmail.com

202-547-9429

**Jim Hunt**

324 Chestnut Hill Avenue #9, Brighton, MA 021356023

January 7, 2009 6:22 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should grant the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* This would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Jim Hunt

324 Chestnut Hill Avenue

#9

Brighton, MA 02135-6023

202-547-9429

**steve sharp**

, ,

January 7, 2009 5:15 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Nano-silver is safe - leave it alone

Sincerely,

steve sharp

202-547-9429

**Virginia Schulman**

358 South St. , Northampton, MA 01060-4120

January 7, 2009 4:53 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Please consider adopting \"the precautionary principle,\" which puts on
innovators the \*reasonable\* task of assessing and ameliorating the bad
effects of their supposedly good ideas.

Remember arsenic-treated lumber? That\'s an example of why the
precautionary principle is not just an idealistic, goo-goo principle
that hampers creativity in the marketplace.

Remember asbestos in insulation? Ditto, ditto.

Don\'t ignore these ghosts from recent history; learn from them and
revise your thinking about the bad effects often inherent in otherwise
good ideas!

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and appr

Sincerely,

Virginia Schulman

358 South St.

Northampton, MA 01060-4120

202-547-9429

**Charles Rinehart**

240 N. Constitution Ave. , New Freedom, PA 17349-9014

January 7, 2009 3:57 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials so lucrative to
manufacturers, i.e., highly enhanced germ-killing action, can be
intensely destructive to our environment. Questions concerning critical
human health concerns need to be addressed.

Nano-silver poses a likely danger to fish and aquatic ecosystems,
potentially interfere with beneficial bacteria in our bodies and our
mileau, and encourage the development of more virulent harmful bacteria.
The wide bevy of products now in the marketplace is creating broad,
intrusive exposures to the public and our environment. Numerous products
are meant for children (baby bottles, toys, stuffed animals, and
clothing) or otherwise create high human exposures (food containers,
paints, bedding, personal care products and cutlery) despite a spartan
study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have demonstrated that nano-silver is much more toxic
than had been realized, and can cause irreparable damage in new ways.
One 2005 study found that nano-silver is approximately 45 times MORE
TOXIC than standard silver. And a 2008 study showed that washing
nano-silver socks releases substantial amounts of the nano-silver into
the laundry discharge water, which will ultimately reach natural
waterways and potentially kill (poison) fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Contemporary products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, especially on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

I thank you and await your consideration.

Sincerely,

Charles Rinehart

240 N. Constitution Ave.

New Freedom, PA 17349-9014

202-547-9429

**Jacques Bargiel**

1054 Kainui Dr. , Kailua, HI 96734

January 7, 2009 3:56 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration and your support.
Aloha.

Sincerely,

Jacques Bargiel

1054 Kainui Dr.

Kailua, HI 96734

202-547-9429

**Amanda Reynolds**

3200 Payne Ave. #64 , San Jose, CA 95117

January 7, 2009 3:08 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Bottom line: nano-silver is used as a pesticide; please classify it as
such.

Thank you for taking my views under consideration.

Sincerely,

Amanda Reynolds

3200 Payne Ave. #64

San Jose, CA 95117

202-547-9429

**Judy Terry**

2995 Malaga Alcoa Hwy , Malaga, WA 98828

January 7, 2009 2:00 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should

Thank you for taking my views under consideration.

Sincerely,

Judy Terry

2995 Malaga Alcoa Hwy

Malaga, WA 98828

202-547-9429

**kerin gould**

4735 Cowell Blvd , \"Davis, CA\", CA 95616

January 7, 2009 1:54 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Businesses that invest in developing chemicals and substances to sell
are in a hurry to get a return on their investments. Many have been
known to under-report or spin away grave health concerns in the
interests of making money. America trusts agencies like the EPA or the
FDA to protect them from such recklessness and greed with hard, thorough
science. There are too many unknown factors in nano-technology to set it
loose on the world with no safety interventions. Please do your jobs and
protect our environment and our health.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also

Sincerely,

kerin gould

4735 Cowell Blvd

\"Davis, CA\", CA 95616

202-547-9429

**Patrick Coulson**

89256 Leeward Ln. , Bandon, OR 97411-8368

January 7, 2009 1:33 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for your time and consideration.

Sincerely,

Patrick Coulson

89256 Leeward Ln.

Bandon, OR 97411-8368

202-547-9429

**Charlene Woodcock**

2355 Virginia St. , Berkeley, CA 94709

January 7, 2009 1:13 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

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 wide
range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Charlene Woodcock

2355 Virginia St.

Berkeley, CA 94709

202-547-9429

**Courtney Albert**

8300 E Yale Ave 8106, Denver, CO 80231

January 7, 2009 12:52 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely, Courtney Albert Denver, Co

Sincerely,

Courtney Albert

8300 E Yale Ave

8106

Denver, CO 80231

202-547-9429

**Jean Leigh**

47 Flintlock Court , Basking Ridge, NJ 07920

January 7, 2009 12:00 AM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

This issue is very, very crucial.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

This serious issue must be handled with extreme care.

Thank you for taking my views under consideration.

Sincerely,

Jean Leigh

47 Flintlock Court

Basking Ridge, NJ 07920

202-547-9429

**William Nolan**

9889 Gary Dr. , Browns Valley, CA 95918

January 6, 2009 11:50 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

I DON\'T WANT TO BE A GUINEA PIG!

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

William Nolan

9889 Gary Dr.

Browns Valley, CA 95918

202-547-9429

**Bobbie Flowers**

418 West 17th Street Apt 22A, New York, NY 10011

January 6, 2009 11:39 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. Many of the products are meant for children (baby bottles,
toys, stuffed animals, and clothing) or otherwise create high human
exposures (cutlery, food containers, paints, bedding and personal care
products) despite very little study of nano-silver\'s potential human
health impacts.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Bobbie Flowers

418 West 17th Street

Apt 22A

New York, NY 10011

202-547-9429

**lisa ryan**

, ,

January 6, 2009 11:29 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Why can\'t you people leave well enough alone?! I am tired of wasting my
valuable time writing to government regulatory agencies that are
supposed to be there to protect my safety, health and well-being. I
don\'t want to buy products with added chemicals that will alter
anything in my body. I don\'t want pens that are antimicrobal; I don\'t
want scissors that kill the germs on my hands; I don\'t want countertops
that are coated in carcinogenic anti-microbal solvents. I want my germs;
I want the microbes that land on my hands and on my face. I couldn\'t
believe it when I went to a home-improvement store and saw that a
countertop line was now coated in chemical anti-microbal solvent. Now I
feel I\'m going to have to investigate every purchase I make to ensure
I\'m not putting something into my body that doesn\'t need to be there.
Why are you allowing corporations to take us further and further away
from nature, from what is natural? I can\'t believe that companies
don\'t have anything better to do with their money than increase the
manufacturing process by adding ridiculous chemicals and altering their
materials with unnecessary technology. There is an epidemic of cancer
and neurological disorders in proportions unheard of by my parents\'
generation and it angers me that I don\'t have the same chance of living
to 70 or 80 without getting cancer because agencies like you continually
try to take away my chance to be healthy. Please stop messing with our
stuff and start doing your job by protecting our health instead of
corporate profit.

I will NEVER buy anything altered with nanotechnology and it is my right
as a consumer to see clear labels if an item has been altered.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

Thank you for taking my views under consideration.

Sincerely,

lisa ryan

202-547-9429

**Cecilia Culverhouse**

315 Bleecker St Box 115, New York, NY 10014

January 6, 2009 11:26 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Cecilia Culverhouse

315 Bleecker St

Box 115

New York, NY 10014

202-547-9429

**Olav Nordemann**

, ,

January 6, 2009 11:18 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns.? 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment.? Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.? While silver is known to
be toxic to fish and aquatic organisms, recent scientific studies have
shown that nano-silver is much more toxic and can cause damage in new
ways.? A 2005 study found that nano-silver is approximately 45 times
more toxic than standard silver.? A 2008 study showed that washing
nano-silver socks releases substantial amounts of the nano-silver into
the laundry discharge water, which will ultimately reach natural
waterways and potentially poison fish and other aquatic organisms.?
Another 2008 study found that releases of nano-silver can destroy benign
bacteria used in wastewater treatment.These novel materials must be
regulated as pesticides because of their germ-killing use.? The agency
should GRANT the legal petition it has pending.? As a result, \*
Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.? \* That would require current and
future nano-silver products to undergo mandatory EPA pre-market
approval.? \* Current products would have to be removed until and unless
they received EPA approval.? \* Approval would only occur if the agency
found the products did not create an unreasonable risk to the
environment. ?\* EPA would also assess nano-silver?s potential impacts
on human health, particularly on children and infants, and on the
environment, particularly on endangered species and their habitat.?\*
EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments. \* If any
of the nano-silver products were approved and registered as pesticides,
their use would be conditioned as necessary to protect the environment
and human health, including the use of warning and approved labeling.?\*
EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.Thank
you for taking my views under consideration.

Sincerely Olav Nordemann 12 Woods Hill Drive Saint Charles MO 63303

Sincerely,

Olav Nordemann

202-547-9429

**Barbara Dively**

2275 Glenview Dr. , Lansdale, PA 19446

January 6, 2009 11:13 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

I bought and started to use a mouthwash before realizing that it
contained nano-silver. I have stopped using it. I am sure that the
health effects are not good in the long run.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Barbara Dively

2275 Glenview Dr.

Lansdale, PA 19446

202-547-9429

**Gail Caswell**

, ,

January 6, 2009 11:09 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

These nanomaterials\' highly enhanced germ-killing action can be
extremely destructive to the environment and raises serious human health
concerns. Nano-silver can harm fish and aquatic ecosystems, may
interfere with beneficial bacteria in our bodies and the environment,
and encourages the development of more virulent harmful bacteria. The
wide range of nano-silver products already available is creating broad
and intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products), despite minimal
study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* Current and future nano-silver products woud be rrequired to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only be granted if the agency found the products did
not create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health (particularly on children and infants) and on the environment
(particularly on endangered species and their habitats).

\* EPA would require manufacturers to submit any necessary data about
the nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for considering my views.

Sincerely,

Gail Caswell

202-547-9429

**Linda Hevener**

201 Walkers Cove Dr , Colonial Heights, VA 23834

January 6, 2009 11:03 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. (It SHOULD have been done before, but since the Republicans
would not act on behalf of the people, I am asking the Democrats to do
so.) As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Linda Hevener

201 Walkers Cove Dr

Colonial Heights, VA 23834

202-547-9429

**Tina Wall**

, ,

January 6, 2009 10:36 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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. This
are concerns that should be tested before their are any more products
with Nano technology released to the public consumer. The wide range of
products already available is creating broad and intrusive exposures to
the public and the environment. Many of the products are meant for
children (baby bottles, toys, stuffed animals, and clothing) or
otherwise create high human exposures (cutlery, food containers, paints,
bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts. Those products containing
nano-silver should be taken off the market in effort to protect both our
health and the environment.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment. The potential
damage that could be done by nano-silver is very alarming and it\'s risk
factors must be taken into account; on a more serious level.

These materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for tak

Sincerely,

Tina Wall

202-547-9429

**nancy poer**

5595 White Feather way , placerville, CA 95667

January 6, 2009 10:31 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am astounded that we are using our babies and children in this giant
experiment of undetermined consequences. Any thing that takes life at
the germ level is capable of destruction to the very vitality that gives
life.

We must be PROTECTED from this type of experimentation for the profit of
the few. That is the responsibility of our government that is elected
and paid by the public for the protections of their welfare.The same
property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticid

Sincerely,

nancy poer

5595 White Feather way

placerville, CA 95667

202-547-9429

**Kathy Simmons**

90 Strong St. , Easthampton, MA 01027

January 6, 2009 10:28 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The way the world is working today, we need more information before
jumping ahead with any new product. We have to be careful not to let the
lethal genie out of the bottle. Toxic chemicals are nothing to fool
with. More research is needed before we allow nano-silver to enter our
world.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Kathy Simmons

90 Strong St.

Easthampton, MA 01027

202-547-9429

**Lulu Volckhausen**

P.O. Box 111 1003 3rd Street, Paonia, CO 81428

January 6, 2009 10:25 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely Lulu Volckhausen

Sincerely,

Lulu Volckhausen

P.O. Box 111

1003 3rd Street

Paonia, CO 81428

202-547-9429

**Kriste Garman**

1105 Timber Trail Rd. , Baltimore, MD 21286

January 6, 2009 10:15 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Kriste Garman

1105 Timber Trail Rd.

Baltimore, MD 21286

202-547-9429

**William Ames**

6708 Waldo Ave. , El Cerrito, CA 94530

January 6, 2009 10:06 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

It is shocking that commercial products containing nanomaterials have
been widely introduced without adequate testing of their health and
environmental effects.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

William Ames

6708 Waldo Ave.

El Cerrito, CA 94530

202-547-9429

**Kayleen W. Clute, CRNP-Pediatrics**

37 Cedar Rd , Severna Park, MD 21146

January 6, 2009 9:56 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

\*WE NEED DO NO HARM LEGISLATION! LEGISLATION THAT REQUIRES PRODUCTS
WILL DO NO HARM BEFORE THEY ARE PRODUCED AND USED IN THE US!!!! OUR
CHILDREN WILL END UP FUNDING, TRYING TO CLEAN-UP OR SUFFERING, AS MANY
ALREADY ARE FROM OUR ENVIRONMENTAL MISUSE! WE HAVE TO BE RESPONSIBLE IN
SAVING THIS WORLD FOR OUR CHILDREN!

Thank you for taking my views under consideration.

Sincerely,

Kayleen W. Clute, CRNP-Pediatrics

37 Cedar Rd

Severna Park, MD 21146

202-547-9429

**Jeffery Garcia**

PO Box 1166 , Mendocino CA, CA 95460

January 6, 2009 9:56 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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.

A 2005 study found that nano-silver is approximately 45 times more toxic
than standard silver. A 2008 study showed that washing nano-silver socks
releases substantial amounts of the nano-silver into the laundry
discharge water, which will ultimately reach natural waterways and
potentially poison fish and other aquatic organisms. Another 2008 study
found that releases of nano-silver can destroy benign bacteria used in
wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Jeffery Garcia

PO Box 1166

Mendocino CA, CA 95460

202-547-9429

**Dana Silvernale**

730 1/2 Third Avenue , Blue Lake, CA 955251373

January 6, 2009 9:43 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Dana Silvernale

730 1/2 Third Avenue

Blue Lake, CA 95525-1373

202-547-9429

**Jenny O\'Neil**

Eddy County , Carlsbad, NM 88220

January 6, 2009 9:39 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Nano-Silver

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Jenny O\'Neil

Eddy County

Carlsbad, NM 88220

202-547-9429

**Judith Duckhorn-McNally**

, ,

January 6, 2009 9:13 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can, of
course, be highly destructive to the environment. and should raise
serious human health concerns. It is a fact aht 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 wide range of
products already available is creating broad and intrusive exposures to
the public and the environment. Many of the products are meant for
children (baby bottles, toys, stuffed animals, and clothing) or
otherwise create high human exposures (cutlery, food containers, paints,
bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Judith Duckhorn-McNally

202-547-9429

**Jeffrey Schultz M.T.S.**

P.O. Box 151 , Gualala, CA 95445

January 6, 2009 8:49 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

What the heck is going on here?

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Jeffrey Schultz M.T.S.

P.O. Box 151

Gualala, CA 95445

202-547-9429

**Katherine Crist**

300 Preston Oaks Lane , Cary, NC 27513

January 6, 2009 8:18 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

It is time to start working for the people of this country, not
corporate interests.

Thank you for taking my views under consideration.

Sincerely,

Katherine Crist

300 Preston Oaks Lane

Cary, NC 27513

202-547-9429

**Gregory Marsella**

, ,

January 6, 2009 8:15 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650 is a threat to our natural
environment!

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Gregory Marsella

202-547-9429

**Myra Williams**

734 E. 20th St. #14 , Oakland, CA 94606

January 6, 2009 8:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I, as a consumer am quite concerned about the use of nano materials in
consumer products that I buy unknowingly. I know they can penetrate and
perhaps harm my body. There need to be test done to protect us from any
possible harm before being allowed in the products we buy. That is not
to much to ask from my government.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Myra Williams Oakl

Sincerely,

Myra Williams

734 E. 20th St. #14

Oakland, CA 94606

202-547-9429

**Judy Landon**

, ,

January 6, 2009 8:03 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Judy Landon

202-547-9429

**Bridget Rosandich**

206 Newman street , Durand, IL 61026

January 6, 2009 7:57 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.I
would like to add,it is truely unknown what kind of an enviromental
effect this could have.It is already suspected certain metals have a
negative effect with people and disease.It is even suspected they can
cause diseases in the nuerological area,like M.S.,muscular
dystrophy,ect.Please reconsider the use of nano-silver in pestiside,or
any other application.Please ,the enviroment is already in trouble;so
are we.D

Sincerely,

Bridget Rosandich

206 Newman street

Durand, IL 61026

202-547-9429

**frances strege**

1322 winding way , anderson, IN 46011

January 6, 2009 7:38 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration. CAUTION IS THE BETTER
PART OF WISDOM. LIFE AND HEALTH ARE PRECIOUS AND WE SHOULDN\'T GAMBLE
WITH IT.

Sincerely,

frances strege

1322 winding way

anderson, IN 46011

202-547-9429

**aj gibbs**

7321 Brockway Dr. , Boulder, CO 80303

January 6, 2009 7:14 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns.

A 2005 study found that nano-silver is approximately 45 times more toxic
than standard silver. A 2008 study showed that washing nano-silver socks
releases substantial amounts of the nano-silver into the laundry
discharge water, which will ultimately reach natural waterways and
potentially poison fish and other aquatic organisms. Another 2008 study
found that releases of nano-silver can destroy benign bacteria used in
wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

aj gibbs

7321 Brockway Dr.

Boulder, CO 80303

202-547-9429

**Judy W. Soffler**

8 Termakay Drive , New City, NY 10956-6434

January 6, 2009 7:11 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding, and personal care products) despite very little study
of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Sincerely,

Judy W. Soffler

8 Termakay Drive

New City, NY 10956-6434

202-547-9429

**Dee Whittaker**

, ,

January 6, 2009 6:58 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

THIS IS NOT A FORM LETTER. PLEASE READ

It is mind boggling to me that the US government regulatory agencies
continually condon products that may have long-term devastating effects
on Americans\' individual and collective health without PROPER testing.
I say proper because I debate scientists who take the tack that if it
isn\'t proven, then it isn\'t true. The bacteria in our bodies that is
destroyed by this product is vital to bodily functions.

Because of it\'s ability to destroy human health and aquatic life, nano
silter should be regulated like any toxin and products containing them
should be banned until such time that they are labeled Generally
Recognized as Safe (GRAS) to humans and the environment, which, quite
frankly, I don\'t think will happen because I don\'t see how they
possibly could be. If they kill intestinal bacteria, they will kill us.
Slowly possibly, but just the same.

Thank you

Sincerely Deborah Whitaker 3011 South Krameria Denver, CO 80222

Sincerely,

Dee Whittaker

202-547-9429

**John Mayew**

8 Annes Way , Landenberg, PA 19350

January 6, 2009 6:51 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

This is another attempt to cause serious risks to our health so that the
pharmeceutical industry can sell more drugs. You are destroying the
Earth allowing these pesticides to be used.

Thank you for taking my views under consideration.

Sincerely,

John Mayew

8 Annes Way

Landenberg, PA 19350

202-547-9429

**Erica Corr**

, , Australia

January 6, 2009 6:43 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Erica Corr

202-547-9429

**Dianne Wilkins**

30 Ledgewood #5 , Falmouth, ME 04105

January 6, 2009 6:43 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Please help. We really don\'t need yet another toxic material to hurt
our health and environment. Thank you for taking my views under
consideration.

Sincerely,

Dianne Wilkins

30 Ledgewood #5

Falmouth, ME 04105

202-547-9429

**Lana Zwygart**

3837 DURANGO Street , Chino, CA 91710

January 6, 2009 6:30 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Lana Zwygart

3837 DURANGO Street

Chino, CA 91710

202-547-9429

**Robert Lassiter and Family**

1 Excelsior Ct. , Oakland, CA 94610

January 6, 2009 6:30 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Are you exempt from the hazards of these products or are the kickbacks
you receive just too good to turn down?

How much did you get for your soul when you sold it?

Sincerely,

Robert Lassiter and Family

1 Excelsior Ct.

Oakland, CA 94610

202-547-9429

**Nan Schweiger**

178 Echo Avenue, #13 , Campbell, CA 95008

January 6, 2009 6:00 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns at the very least.

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 wide
range of products already available is creating broad and intrusive
exposures to the public and the environment.

Many of the products are meant for children (baby bottles, toys, stuffed
animals, and clothing) or otherwise create high human exposures
(cutlery, food containers, paints, bedding and personal care products)
despite very little study of nano-silver\'s potential human health
impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides \-- and even
better than pesticides are regulated \-- because of their germ-killing
use. The agency should GRANT the legal petition it has pending. As a
result:

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Nan Schweiger

178 Echo Avenue, #13

Campbell, CA 95008

202-547-9429

**Cliff DeVries**

2543 Makaulii Place , Honolulu, HI 96816

January 6, 2009 5:48 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Nano products are extremely small and can pass through normal barriers
that exist in the body, like the skin, designed to keep out toxic
materials. These products are very dangerous and the EPA should
carefully look at them to determine exactly how toxic they are
especially to children.

Thank you for taking my views under consideration.

Sincerely,

Cliff DeVries

2543 Makaulii Place

Honolulu, HI 96816

202-547-9429

**Natalie Houghton**

775 Angelita Dr , Prescott, AZ 86303

January 6, 2009 5:43 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Natalie Houghton

775 Angelita Dr

Prescott, AZ 86303

202-547-9429

**Sharon Simpson**

11381 New Biddinger Rd , Harrison, OH 45030

January 6, 2009 5:37 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Sharon Simpson

11381 New Biddinger Rd

Harrison, OH 45030

202-547-9429

**Ann O\'Neil**

65 Upham St. , Lowell, MA 01851

January 6, 2009 5:36 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

As a mother of three young children, I am exhausted from just trying to
protect them from everyday harmful chemicals that we already know of.
Please help parents out by looking out for the long-term health of our
children and environment.

Thank you for taking my views under consideration.

Sincerely,

Ann O\'Neil

65 Upham St.

Lowell, MA 01851

202-547-9429

**Geoffrey Doman**

13900 Cohasset Street , Van Nuys, CA 91405

January 6, 2009 5:28 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The quality that makes these nanomaterials lucrative to manufacturers,
highly enhanced germ-killing action, can be highly destructive to the
environment and raise serious human sickness concerns. 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 wide range of
products already available is creating broad and intrusive exposures to
the public and the environment. Many of the products are meant for
children (baby bottles, toys, stuffed animals, and clothing) or
otherwise create high human exposures (cutlery, food containers, paints,
bedding and personal care products) despite very little study of
nano-silver\'s potential human illness impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways.

A 2005 study found that nano-silver is approximately 45 times more toxic
than standard silver. A 2008 study showed that washing nano-silver socks
releases substantial amounts of the nano-silver into the laundry
discharge water, which will ultimately reach natural waterways and
potentially poison fish and other aquatic organisms. Another 2008 study
found that releases of nano-silver can destroy benign bacteria used in
wastewater treatment.

These new materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Sincerely,

Geoffrey Doman

13900 Cohasset Street

Van Nuys, CA 91405

202-547-9429

**Janet Braun**

, ,

January 6, 2009 5:25 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am very concerned about the untested release of products containing
nano-silver to the public. First, safety testing must be done to prove
beyond any doubt the long-term safety of nano-silver and any products it
might be put into, for their effects on humans and on all aspects of our
environment that will ultimately be affected by their use. All such
products must be taken off of the market immediately until such testing
is completed. If testing cannot prove safety, then there is no reason to
use this technology. We may be creating new disease forms; what will it
be after cancer? If testing shows safety to humans and all other
species, only then should it be marketed, and only with very clear
labeling so consumers may decide for ourselves if we want our families
to be exposed to these new materials.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current

Sincerely,

Janet Braun

202-547-9429

**Dave Rich**

P.O. Box 3923 , Durango, CO 81302

January 6, 2009 5:23 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Dave Rich

P.O. Box 3923

Durango, CO 81302

202-547-9429

**CJ Miles**

8322 E Koralee Pl , Tucson, AZ 85710

January 6, 2009 5:23 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

There is more than one way to look at this.

The sooner we kill each other as we have done our bee population, the
sooner we are euthanized by our fellow money hungry men and women.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

CJ Miles

8322 E Koralee Pl

Tucson, AZ 85710

202-547-9429

**Hugh Lehman**

22550 LaRochelle Dr. , SANTA CLARITA, CA 91350

January 6, 2009 5:18 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Human beings, pet animals, etc. may be adversely affected by inhaling or
ingesting these particles. We need to understand the interactions of
these particles well enough so that when Americans or others report
symptoms to their doctors or show up in emergency rooms, the attending
physicians can recognize harms associated with nanomaterials. Until such
information is scientifically documented, in my judgement, people in our
country should not be exposed to them.

The idea that we can spread these materials around the environment and
then investigate whether they are causing injury or illness is
fundamentally disrespectful of our people. Our citizens or others should
not be used as experimental animals.

Further, nano-silver or other nano materials may be released into
drinking water or sewage systems. If it turns out that nano-silver
damages the water intake systems on which people are dependent for their
water supply then who will pay the costs of undoing the damage? Who will
pay the costs of other environmental damages that require repair?

We cannot assume that because in the 19th or 20th centuries new
technologies were tried out without safety assessments that it is
morally acceptable to continue to do that. The power of the new
technologies to infest ecosystems on a large scale means that safety
assessments must be conducted prior to their release into our
environment.

Thank you for taking my views under consideration.

Sincerely,

Hugh Lehman

22550 LaRochelle Dr.

SANTA CLARITA, CA 91350

202-547-9429

**Deborah Filipelli, Ph.D.**

p\. o. box 341 , the sea ranch, CA 95497

January 6, 2009 5:13 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The following represents my position.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Deborah Filipelli, Ph.D.

p\. o. box 341

the sea ranch, CA 95497

202-547-9429

**Joan May**

25 Essex Hills Dr. , Essex, CT 06426

January 6, 2009 5:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

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. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

Silver is known to be toxic to fish and aquatic organisms, and recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending so that:

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Joan May

25 Essex Hills Dr.

Essex, CT 06426

202-547-9429

**Karen Haley**

36205 Main Rd. , Orient, NY 11957

January 6, 2009 5:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. This is completely unacceptable. I do not want nanomaterials
in my body or in my child\'s body. 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 wide range of products already available is
creating broad and intrusive exposures to the public and the
environment. Many of the products are meant for children (baby bottles,
toys, stuffed animals, and clothing) or otherwise create high human
exposures (cutlery, food containers, paints, bedding and personal care
products) despite very little study of nano-silver\'s potential human
health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Karen Haley

36205 Main Rd.

Orient, NY 11957

202-547-9429

**Emelie Olson**

1327 4th St. , Las Vegas, NM 87701

January 6, 2009 5:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am deeply concerned about the use of non-silver in products without
adequate research on their effects. Early research suggests they may
have side-effects similar to asbestos in the lungs. There will
undoubtedly be other effects. Thus, we need far more research over the
long-term before we should consider their use.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Emelie Olson

1327 4th St.

Las Vegas, NM 87701

202-547-9429

**William Bailey**

2161 Puna St. , Honolulu, HI 96817

January 6, 2009 4:53 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The lack of understanding, openness and oversight that we find in the
field of nanotechnology could lead to tragic consequences. We are just
learning of the toxic effects of nano-silver. While we recognize that
there are therapeutic uses for some forms of silver, and use colloidal
silver ourselves, nano-silver is in a completely different category,
with much greater toxicity than other forms. We therefore urge the EPA
to take the following steps:

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

William Bailey

2161 Puna St.

Honolulu, HI 96817

202-547-9429

**Mary S Reed**

962 Darrow Road , Duanesburg, NY 120564108

January 6, 2009 4:51 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health and on the environment, particularly on endangered species and
their habitat.EPA should also regulate the manufacture and proper
disposal of nano materials.

\* EPA would require manufacturers to submit any needed data about the
nano materials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Mary S Reed

962 Darrow Road

Duanesburg, NY 12056-4108

202-547-9429

**Virginia Pepper**

4 rosewood dr , ipswich, MA 01938

January 6, 2009 4:46 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products now available create broad and intrusive
exposures to the public and our environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

Silver is toxic to fish and aquatic organisms, recent scientific studies
have shown that nano-silver is much more toxic and can cause damage in
new ways. A 2005 study found that nano-silver is approximately 45 times
more toxic than standard silver. A 2008 study showed that washing
nano-silver socks releases substantial amounts of the nano-silver into
discharge water, this will ultimately reach natural waterways and
potentially poison fish and other aquatic organisms. Another 2008 study
found that releases of nano-silver destroy benign bacteria used in
wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Virginia Pepper

4 rosewood dr

ipswich, MA 01938

202-547-9429

**Greg Gille**

16802 NE 6th Place , Bellevue, WA 98008

January 6, 2009 4:46 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise SERIOUS HUMAN HEALTH
CONCERNS. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Greg Gille

16802 NE 6th Place

Bellevue, WA 98008

202-547-9429

**Jeanne Boeke**

2265 Avalon Ave , Dayton, OH 45409

January 6, 2009 4:36 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

I think it is important that we have an idea what we are doing before
introducing new substances into our environment.

Thank you for taking my views under consideration.

Sincerely,

Jeanne Boeke

2265 Avalon Ave

Dayton, OH 45409

202-547-9429

**Stewart Hartsfield**

4862 SW Indian Creek Ct. , Lake Oswego, OR 97035

January 6, 2009 4:34 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

We\'ve been over-confident about our understandings in the past and now
live in a chemical soup for this folly. We\'ve needed to regulate the
innovations brought about by business & industry as they apply to
chemicals, and nanotechnology demands the same careful oversight if we
are to avoid the unforseen consequences that may lurk behind its
indiscriminate & poorly rsearched introduction.

Thank you for taking

Sincerely,

Stewart Hartsfield

4862 SW Indian Creek Ct.

Lake Oswego, OR 97035

202-547-9429

**Lia Hutton**

, ,

January 6, 2009 4:32 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. Nano-silver can harm aquatic ecosystems, potentially interfere
with beneficial bacteria in our bodies and the environment, and
encourage the development of more virulent harmful bacteria. The wide
range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Lia Hutton

202-547-9429

**Carol Hutton**

5038 Round Tower Place , Columbia, MD 210443122

January 6, 2009 4:32 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We must be very careful in dealing with these materials. Our lives and
our environment are more important than profits.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Carol Hutton

5038 Round Tower Place

Columbia, MD 21044-3122

202-547-9429

**Virginia and James Wagner**

4897 East Walnut Street , Westerville, OH 43081

January 6, 2009 4:27 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns.

Nano-silver can:

\* harm fish and aquatic ecosystems, \* interfere with beneficial
bacteria in our bodies and the environment, and \* encourage the
development of more virulent harmful bacteria.

Wife Virginia and I am alarmed by the wide range of products already
available that are now creating broad and intrusive exposures to the
public and the environment.

On top of that, many of the products are meant for children (baby
bottles, toys, stuffed animals, and clothing) or otherwise create high
human exposures (cutlery, food containers, paints, bedding and personal
care products) despite there being very little study of nano-silver\'s
potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways.

\* A 2005 study found that nano-silver is approximately 45 times more
toxic than standard silver.

\* A 2008 study showed that washing nano-silver socks releases
substantial amounts of the nano-silver into the laundry discharge water,
which will ultimately reach natural waterways and potentially poison
fish and other aquatic organisms.

\* Another 2008 study found that releases of nano-silver can destroy
benign bacteria used in wastewater treatment.

These novel materials MUST be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking our views under consideration.

Sincerely,

Virginia and James Wagner

4897 East Walnut Street

Westerville, OH 43081

202-547-9429

**Fred Jakobcic**

1025 N. Third Street , Marquette, MI 49855

January 6, 2009 4:21 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

Please test this stuff and be honest about the test and their results.
Over the years of the bush administratin I have grown increasingly
distrustful of the EPA and its approval of most anything because of its
close ties with industry and lack of integrity I have seen creep into it
because of the bush administratin. Approved by the EPA no longer carries
a guarrantee of trust to be trusted.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for tak

Sincerely,

Fred Jakobcic

1025 N. Third Street

Marquette, MI 49855

202-547-9429

**Rob Nebel**

260 MT PLEASANT RD , HAUPPAUGE, NY 11788

January 6, 2009 4:14 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Yet again the cart is in front of the horse. The use of products in
foods or anything that can be ingested without proper safety guidelines
is just wrong! I realize that the EPA has less money to test than the
amount of \"new stuff\" that is flooded onto the market yearly. But,
there needs to be some kind of protocol with foodstuffs and food
additives, containers, that will protect our children from the potential
diseases in the future. It has become painfully obvious that the meat
industry does not care that BSE (mad cow) can jump the species barrier.
The government actually prohibits testing of animals. This nano-silver
is a time bomb. If there is no testing by an objective source. According
to the letter below\--fish populations and ecosystems of fresh water
creatures are in trouble due to this nano-silver. Why is nothing being
done? Why must I read about the lack of overseeing what goes into our
food and around the food? It is time to make those responsible for the
havoc wreaked resposible for the fallout. I certainly do not want to
bury my child because of food claimed to be healthy or healthier than
the rest when nothing could farther from the truth.

Robert Nebel Hauppauge NY

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver classified as a new substance, & products regulated as
new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* EPA would also assess nano-silver?s potent

Sincerely,

Rob Nebel

260 MT PLEASANT RD

HAUPPAUGE, NY 11788

202-547-9429

**Hendrik Bos**

, , Netherlands

January 6, 2009 4:14 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
Brita waterfilter, paints, bedding and personal care products) despite
very little study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Hendrik Bos

202-547-9429

**John D\'Ambra**

74 High Street , Butler, NJ 074051108

January 6, 2009 4:11 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. MANY OF THE PRODUCTS ARE
MEANT FOR CHILDREN(baby bottles, toys, stuffed animals, and clothing) or
otherwise create high human exposures (cutlery, food containers, paints,
bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 TIMES MORE TOXIC THAN STANDAR. A 2008 study showed that
washing nano-silver socks releases substantial amounts of the
nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency SHOULD GRANT the legal petition it has
pending. AS A RESULT:

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
MANDATORY EPA pre-market APPROVAL.

\* CURRENT PRODUCTS WOULD HAVE TO BE REMOVED until and unless they
received EPA approval.

\* Approval would ONLY OCCUR if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, PARTICULARLY ON INFANTS AND CHILDREN, and on the environment,
particularly on endangered species and their habitat.

\* EPA WOULD REQUIRE MANUFACTURERS to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you

Sincerely,

John D\'Ambra

74 High Street

Butler, NJ 07405-1108

202-547-9429

**Diane Human**

3911 Knollwood Drive , Chattanooga, TN 37415

January 6, 2009 4:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration. It is a shame what
obviously dangerous ingredients end up in consumer products all for the
sake of dollars to commercial manufacturers

Sincerely,

Diane Human

3911 Knollwood Drive

Chattanooga, TN 37415

202-547-9429

**Cheri Leslie**

607 Palms Blvd , Venice, CA 90291

January 6, 2009 4:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Cheri Leslie

607 Palms Blvd

Venice, CA 90291

202-547-9429

**Kristine Mattis**

, ,

January 6, 2009 4:01 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

As a scientist, I question the introduction of these new materials
without adequate safety studies on human health and the environment.
With technologies such as this, as well as many biotechnologies like
genetic engineering, it would be wise for the U.S. to adopt the
precautionary principle to demonstrate that we care more about the
health and saftey of our population than about the interests of
industry.

Sincerely,

Kristine Mattis

202-547-9429

**Ryan Platte**

118 W Hazel St , West Chicago, IL 60185

January 6, 2009 4:01 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Ryan Platte

118 W Hazel St

West Chicago, IL 60185

202-547-9429

**Sandra J. Carrubba**

200 East Hazeltine Ave , Buffalo, NY 14217

January 6, 2009 4:01 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. I am nervoius about the lack of regulation and or study about
this substance. 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 wide range of products already available is creating broad
and intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Sandra J. Carrubba

200 East Hazeltine Ave

Buffalo, NY 14217

202-547-9429

**Brittany Allison**

, ,

January 6, 2009 3:58 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Brittany Allison

202-547-9429

**Karen Winans**

7426 E. 29th St , Tulsa, OK 74129

January 6, 2009 3:56 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Please take action on this matter!!

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Karen Winans

7426 E. 29th St

Tulsa, OK 74129

202-547-9429

**Alicia Batson**

4712 Lickton Pike , Whites Creek, TN 37189

January 6, 2009 3:49 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I just can\'t believe that the EPA keeps approving biologically-active
substances that have no proven health record. We can\'t even get control
of GMO products and the myriad carcinogens that you have approved
exposure to, and now you are throwing nano-tecnology at us without our
consent. You people at the EPA are absolutely irresponsible and
short-sighted. I have no confidence in your authority. You have lost
public trust. You are killing us and destroying our environment. I\'m
disgusted. Who are you to decide what my risk-benefit exposure ratio is
? Who do you think you are to make that decision for me or our future
generations?

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect th

Sincerely,

Alicia Batson

4712 Lickton Pike

Whites Creek, TN 37189

202-547-9429

**Faith Gagne**

18 Bass River Road , South Yarmouth, MA 02664

January 6, 2009 3:49 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Dear Center for Food Safety(?):

Again, I do not think you know what you are talking about with
\'nano-silver\'. Many people use \'silver\' to great positive advantage.
Silver users do not get the flu anymore. You obviously need to better
educate yourself on the use and advantages of silver. You are way off
base here. Manufacturers have to call the silver they are marketing
\'nano-silver\' to be able to market it at all because silver is a
common substance and cannot be patented. Your claims are absolutely
ridiculous. You probably hate hydrogen peroxide also, right?

You haggle on and on about this and you are wrong.

I strongly suggest you read a wonderful and enlightening book entitled
\"The Body Electric, by Dr. Robert Becker. In this book Dr. Becker
recognized a correlation between low silver levels and sickness. He said
the silver deficiency was responsible for the improper functioning of
the immune system. Dr. Becker\'s experiments conclude that silver works
on the full spectrum of pathogens without any side effects or damage to
any part of the body. He also states that the silver was doing something
more than killing disease organisms. It was also causing major growth
stimulation of injured tissues. Burn patients and elderly patients
noticed more rapid healing. He discovered that all cancer cells change
back to normal cells. All strains of pathogens resistant to other
antibiotics are killed by colloidal silver. Yet at that time he
couldn\'t find a silver supplement on the market. I am very pleased that
things are changing today.

Faith Gagne

Sincerely,

Faith Gagne

18 Bass River Road

South Yarmouth, MA 02664

202-547-9429

**Kathleen VanderHeijden**

, ,

January 6, 2009 3:27 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

If you are already aware of this research, I implore EPA to use good
judgment and grant the legal petition you have pending. If you are not
fully informed, then please start by reading the rest of this letter.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Kathleen VanderHeijden

202-547-9429

**Cheryl Vallone**

10 Ivy Lane , Ashland, MA 017211020

January 6, 2009 3:24 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for your consideration and for accepting these comments.

Sincerely,

Cheryl Vallone

10 Ivy Lane

Ashland, MA 01721-1020

202-547-9429

**Anne Wolf**

1452 Townview Ave , santa rosa, CA 95405

January 6, 2009 3:06 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The nanomaterials and their highly enhanced germ-killing action can be
highly destructive to the environment and human health. Any pesticide
whether it is nano-silver or any other product needs to be researched by
an independent agency as to the risk it can cause. To put this product
in at least 300 items that are used in homes and around children is
outrages. Pesticides can accumulate in the body and environment and have
long term effects long after exposure. It would not be immediately
apparent that someone\'s disability was caused by the product. The
product can potentially interfere with beneficial bacteria in our bodies
and the environment, and encourage the development of more virulent
harmful bacteria. We are already seeing the development of super
bacteria with the over use of antibiotics in humans and animals. We do
not need to develop more harmful ones. EPA needs to take a stand and
protect our citizens.

The wide range of products already available is creating broad and
intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

Silver is known to be toxic to fish and aquatic organisms. Recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its reg

Sincerely,

Anne Wolf

1452 Townview Ave

santa rosa, CA 95405

202-547-9429

**joanne miller**

2 ash ave. #6, Kentfield, CA 94904

January 6, 2009 3:06 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Once again, market greed is rushing ahead of good sense. We have the
planet to think of, not just lining someone\'s pockets.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

joanne miller

2 ash ave.

#6

Kentfield, CA 94904

202-547-9429

**maria matthews**

, ,

January 6, 2009 3:04 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

If this is not that case? PLease give me FACTS that prove otherewise.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration. If this is not
factual or bearing merrit? Please send me the FACTS as you see them
supported by factual studies? I am very interested and invested as a
human on the planet trying to survive and wanting to see young people
thrive.

Sincerely, Mary Matthews marylizma@aol.com

Sincerely,

maria matthews

202-547-9429

**ken keegan**

709 modesto ave , santa cruz, CA 95060

January 6, 2009 3:04 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Hello. My name is Ken Keegan. I would like to request that all
nano-silver products be regulated before they are released to the
public. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

ken keegan

709 modesto ave

santa cruz, CA 95060

202-547-9429

**john furlong**

, , CT

January 6, 2009 2:58 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Do NOT allow further release of these and other nanomaterials into the
environment. They absolutely MUST be held to different and more
stringent testing before they are released. Similar to GMO crops, once
used in the non-lab environment, they cannot be \'recalled\'.

Thank you for consideration of my views.

John H. Furlong, N.D.

Sincerely,

john furlong

CT

202-547-9429

**Susan R McCray**

, ,

January 6, 2009 2:57 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

As a grandmother of four lovely granddaughters, I speak out on their
behalf. Please consider honoring this request to regulate nano-silver
and require the EPA to develop further safety testing and hazard
labeling. Having recently seen the results of the melamine crisis in
China, I implore you to take steps to keep these products restricted
from common usage until further testing show them to be safe.

Thank

Sincerely,

Susan R McCray

202-547-9429

**Lacie Wycoff**

23110 Mulholland Drive , Woodland Hills, CA 913643744

January 6, 2009 2:51 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I know you get thousands of form letters. So let\'s be short and sweet.
Stop allowing the general public to be guninea pigs. Please be
responsible citizens regarding our health and safety. Why should we need
special coatings on everything we touch? Just because there\'s money in
doing something doesn\'t mean it\'s the right thing to do. Please take
future generations into account.

Thank you for taking my views under consideration.

Sincerely,

Lacie Wycoff

23110 Mulholland Drive

Woodland Hills, CA 91364-3744

202-547-9429

**Audrey Smith**

PO Box 196 , Wilson, WY 83014

January 6, 2009 2:46 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

There is no question that nano-technology needs to be researched further
to find out the effects on our environment and humans. It is the duty of
the EPA to serve and protect the people of the United States. There is
absolutely no reason that this technology should be rushed to market!!
The EPA\'s primary responsibility is to the environment, and to the
public, not to corporations! As a population, we, the people, and our
regulating powers, such as the EPA, need to change the way we perceive
the environment. Rather than looking at it as a commodity to be used and
stripped into parts, abused with chemicals and technologies that wreak
havoc on our delicate ecosystems, we need to nourish and nurture that
which sustains us.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were ap

Sincerely,

Audrey Smith

PO Box 196

Wilson, WY 83014

202-547-9429

**David & Carol Shelton**

329 Grady McNeilly Rd , casar, NC 28020

January 6, 2009 2:46 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Must our federal agencies continue to kowtow to market forces at the
expense of human health and the environment?

We agree with the sentiments expressed in this message. -D&CS

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

David %pa_first_name% Carol Shelton

329 Grady McNeilly Rd

casar, NC 28020

202-547-9429

**Michael Adler**

22287 Mulholland Hwy. #203, Calabasas, CA 91302

January 6, 2009 2:37 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--may be
dangerous for humans and destructive to the environment. 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 wide range of
products already available is creating broad and intrusive exposures to
the public and the environment. Many of the products are meant for
children (baby bottles, toys, stuffed animals, and clothing) or
otherwise create high human exposures (cutlery, food containers, paints,
bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Michael Adler

22287 Mulholland Hwy.

#203

Calabasas, CA 91302

202-547-9429

**patricia harriss**

, ,

January 6, 2009 2:35 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We are being poisoned from every direction. We thought the EPA and FDA
were protecting us but evidently neither one is doing their job.
Consequently, now one in 150 children are diagnosed with autism instead
of one in 10,000 like back in the 70\'s. Something is terribly wrong and
somebody has got to do something. Please get tough and do your job!

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

patricia harriss

202-547-9429

**Erin Lamb**

12 Brandywyne , Wayland, MA 01778

January 6, 2009 2:27 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Erin Lamb

12 Brandywyne

Wayland, MA 01778

202-547-9429

**Derek Gendvil**

9030 W. Sahara Ave. #360 , Las vegas, NV 89117

January 6, 2009 2:27 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely, Derek Gendvil 9030 W. Sahara Ave. #360 Las vegas, NV 89117

Sincerely,

Derek Gendvil

9030 W. Sahara Ave. #360

Las vegas, NV 89117

202-547-9429

**Kirk Taylor**

12525 Morris Rd , Yelm, WA 98597

January 6, 2009 2:25 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Deregulation has caused the biggest problem in 50 years.

Lack of regulation caused the last fiasco.

I beleive that all new products should be safety tested and regulated
until such testing (by impartial labs) is satisfactorily completed.

The very nature of nano materials necessitates this, since all we do
know about them is that they can be very, very invasive, both physically
and biologically.

This new technology shows great promise, but being what it is, should be
considered Biologically dangerous until proven otherwise.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* these products should be classified as new substancees and
nano-silver products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Kirk Taylor

12525 Morris Rd

Yelm, WA 98597

202-547-9429

**Andrew Butz**

3735 SE 9th , Portland, OR 97202

January 6, 2009 2:25 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver as new
pesticide

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Andrew Butz

3735 SE 9th

Portland, OR 97202

202-547-9429

**Mark Peterson**

3 Higgins Ave. , Clementon, NJ 08021

January 6, 2009 2:20 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Mark Peterson

3 Higgins Ave.

Clementon, NJ 08021

202-547-9429

**Joshua Asarian**

1614 West Avenue , Eureka, CA 95501

January 6, 2009 2:15 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Joshua Asarian

1614 West Avenue

Eureka, CA 95501

202-547-9429

**Julian McNamara**

203 Rivington St , New York, NY 10002

January 6, 2009 2:14 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Everyone concerned with human and environmental health also understands
the need for a balance between the introduction of new products,their
regulation by organizations with the ability to draw on the available
scientific information and the business needs of those entities creating
them. I feel there is inadequate scientific information available to
make that assessment and urge you to support the ICTA/CFS petition.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Julian McNamara

203 Rivington St

New York, NY 10002

202-547-9429

**Ellen Bryant**

3545 M St , Eureka, CA 955035463

January 6, 2009 2:13 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

ABSOLUTELY! I\'VE SUFFERED TERRIBLY FROM THESE PRODUCTS (LIKE THE
ANTI-BACTERIAL LAUNDRY SOAP \"ALL CLEAR\").. I ITCHED/SCRATCHED UNTIL MY
SKIN BLED FOR ALMOST A YEAR UNTIL I FOUND OUT ABOUT THE BLASTED SOAP (NO
THANKS TO MY DERMATOLOGIST!) I FEEL REAL SORRY FOR BABIES AND CHILDREN
THAT CAN\'T GET AWAY FROM THESE HAZARDOUS PRODUCTS THAT HARM AND PERHAPS
KILL IN THE NAME OF PROFIT.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views

Sincerely,

Ellen Bryant

3545 M St

Eureka, CA 95503-5463

202-547-9429

**Teri Meadows**

456 Oak Manor Drive , Fairfax, CA 94930

January 6, 2009 2:08 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

As a consumer and a mother of two, I try to avoid any product that is
not completely natural and earth-friendly.

I am find it outrageous that people are willing to risk the lives of
children, the lives of adults and the health of the entire environment
in order to make a profit.

We are at a point in human civilization when we are advancing
scientifically at extraordinary rates and we need to monitor ourselves
cautiously before we unleash something harmful that will mutate the
world as we know it.

Nano materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Teri Meadows

456 Oak Manor Drive

Fairfax, CA 94930

202-547-9429

**Anne Eldridge**

4682 HWY 66 , ASHLAND, OR 97520

January 6, 2009 1:57 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Please don\'t put profit above the health of your children, food, and
environment.

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Anne Eldridge

4682 HWY 66

ASHLAND, OR 97520

202-547-9429

**Mary Thoma**

, ,

January 6, 2009 1:56 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Profiting from ignorance is cruel fact of life, there are few who\'s
integrity will disallow it. It is up to our local, state and federal
regulatory agencies imbued with the public trust to be our guardians.
Don\'t let your people, who rely on your caution and conscience, down!

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Mary Thoma

202-547-9429

**J. Capozzelli**

315 W. 90 St. , New York, NY 10024

January 6, 2009 1:54 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers, their highly enhanced germ-killing action, can be highly
destructive to the environment and raise serious human health concerns.
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 wide range of products already available is creating broad and
intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

I have read that while silver is known to be toxic to fish and aquatic
organisms, recent scientific studies have shown that nano-silver is much
more toxic and can cause damage in ne w ways. A 2005 study found that
nano-silver is approximately 45 times more toxic than standard silver. A
2008 study showed that washing nano-silver socks releases substantial
amounts of the nano-silver into the laundry discharge water, which will
ultimately reach natural waterways and potentially poison fish and other
aquatic organisms.

Another 2008 study found that releases of nano-silver can destroy benign
bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use.

I urgently ask that the agency should GRANT the legal petition it has
pending so that:

\- Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\- That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\- Current products would have to be removed until and unless they
received EPA approval.

\- Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\- The EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\- The EPA would require manufacturers to submit any needed data about
the nanomaterials and current unknowns to conduct its assessments.

\- If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\- The EPA would also amend its regulations to require nano-specific
data, testing, and risk assessments for nanomaterial pesticide products.

Thank you for your consideration of this urgent matter.

Sincerely,

J. Capozzelli

315 W. 90 St.

New York, NY 10024

202-547-9429

**Venetia Pimley**

1101 Calle del Ranchero NE , Albuquerque, NM 87108

January 6, 2009 1:50 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Many people are being exposed to these particles, but they raise serious
human health concerns.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Venetia Pimley

1101 Calle del Ranchero NE

Albuquerque, NM 87108

202-547-9429

**Joel Gagnon**

, ,

January 6, 2009 1:39 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment, with implications
not only for municipal waste water treatment plants, but also for rural
septic systems.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
especially endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Joel Gagnon

202-547-9429

**Barb Dyjak**

16 Kingsport Dr , Howell, NJ 07731

January 6, 2009 1:39 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

It is my fervent hope that you take your responsibility seriously, to
protect the environment, and especially, the citizens of this country.

Thank you for taking my views under consideration.

Sincerely,

Barb Dyjak

16 Kingsport Dr

Howell, NJ 07731

202-547-9429

**Jean A. Autrey**

3449 Golden Rain Rd. #4 , Walnut Creek, CA 94595

January 6, 2009 1:36 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Jean A. Autrey

3449 Golden Rain Rd. #4

Walnut Creek, CA 94595

202-547-9429

**Sara Perron-Almasri**

38148 Beecher Drive , Sterling Heights, MI 48312

January 6, 2009 1:34 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I think we\'re putting the cart before the horse in approving use of
nano-sliver before we determine if it\'s truly beneficial or a health
hazard when used indiscriminately.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Sara Perron-Almasri

38148 Beecher Drive

Sterling Heights, MI 48312

202-547-9429

**Eric Tanafon**

61 Walnut St. , Manchester, NH 03104

January 6, 2009 1:34 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The highly enhanced germ-killing action of these nano-materials may be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Eric Tanafon

61 Walnut St.

Manchester, NH 03104

202-547-9429

**Anne Lazarus**

524 E. 20h St. , New York, NY 10009

January 6, 2009 1:34 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.
Colloidal silver can be used to fight infections, but nano-silver is
unnatural and dangerous. The corporations are using an important natural
anti-infectious agent and turning it into a profitable destructive
patented product, as usual. Respectfully, Anne Lazarus, 524 East 20th
St. New York, N. Y. 10009

Thank you for taking my views under consideration.

Sincerely,

Anne Lazarus

524 E. 20h St.

New York, NY 10009

202-547-9429

**Anna Jacus**

1106-B N. Stiles St. , Linden, NJ 07036

January 6, 2009 1:29 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Only one of every ten cells in our bodies is human. Isn\'t that a
staggering fact?! The rest are symbiotic bacteria. We could not survive
without them. In fact, we are interwoven with these beings. To harm them
is to endanger our own lives.

The same property that makes nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Anna Jacus

1106-B N. Stiles St.

Linden, NJ 07036

202-547-9429

**Christine Rodgers**

1204 S. Kenosha , Tulsa, OK 74120

January 6, 2009 1:27 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

This would NOT be the first time that humans have blundered ahead with
an idea that seemed good at the time but proved to have far reaching
consequences. Don\'t forget that the world is home to millions of
bacteria, fungus and viruses, many of which have VERY IMPORTANT jobs in
the ecosystem, such as the bacteria in our own intestines that help with
human nutrician or the ones in a cows gut that digest cellulose. Some
one celled organisms in the ocean use carbon for shells and take it to
the bottom of the ocean. Not to mention all these tiny creatures that
recycle every dead organism and keep our planet from being covered by
dead plants and animals. THINK ABOUT IT! Most microorganisms are very
neccessary and do NOT cause disease!

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver prod

Sincerely,

Christine Rodgers

1204 S. Kenosha

Tulsa, OK 74120

202-547-9429

**Jude Lyon**

, ,

January 6, 2009 1:27 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The following actions should be taken:

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

While nano-technology will likely have many positive attributes for our
future, it MUST be dealt with cautiously and judiciously. To let this
technology into mainstream markets without careful consideration at
every step poses huge threats to mankind and nature as we presently know
it. Stop this behavior that is more inclined to capitalism and greed
than the health and well being of people and our planet.

Thank you for taking my views under consideration.

Sincerely,

Jude Lyon

202-547-9429

**toni bowman**

, ,

January 6, 2009 1:24 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

\* Products should be labeled.

Thank you for taking my views under consideration.

Sincerely,

toni bowman

202-547-9429

**Melissa Shapcott**

, ,

January 6, 2009 1:24 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Melissa Shapcott

202-547-9429

**Zi Pinsley**

1610 Cabo Lucero Rd , Las Vegas, NM 87701

January 6, 2009 1:20 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

While I am very interested in the potential for good that may eventually
be recognized with the use of nano-tech, I feel the products are being
brought to market without adequate testing. In effect, by this
permissive behavior, the EPA sanctions the use of our world and our
bodies as their laboratory\... a very frightening possibility!

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Zi Pinsley

1610 Cabo Lucero Rd

Las Vegas, NM 87701

202-547-9429

**Carol Slater**

, ,

January 6, 2009 1:19 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Please require testing of nano-silver, which is putting our safety at
trememdous risk to benefit only a few\--those who make money on it. The
same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. The use of nano-silver is harmful to fish and aquatic
ecosystems, potentially interferes with beneficial bacteria in our
bodies and the environment, and encourages the development of more
virulent harmful bacteria. I am concerned that the wide range of
products already available is creating broad and intrusive exposures to
the public and the environment. The fact is that many of the products
are meant for children (baby bottles, toys, stuffed animals, and
clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver! A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment. We could well be
creating a deadly environmental monster here.

Not all \"germs\" are bad; some are indispensable to our health and
functioning. These novel materials must be regulated as pesticides
because of their germ-killing use. The agency has an obligation to the
public to GRANT the legal petition it has pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Carol Slater

202-547-9429

**Passin Threu**

homeless , Newport, OR 97365

January 6, 2009 1:19 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I find this sad as it seems that few have any concern to the future of
there children and the world left to them\...Please read this and think
\...

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Passin Threu

homeless

Newport, OR 97365

202-547-9429

**Tara Kamath**

1959 Cloverfield Blvd Apt 118 , Santa Monica, CA 90404

January 6, 2009 1:19 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

I appreciate the opportunity to express my views.

Sincerely,

Tara Kamath

1959 Cloverfield Blvd Apt 118

Santa Monica, CA 90404

202-547-9429

**D Den Beste**

, ,

January 6, 2009 1:13 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

There are no silver bullets. We live in a system and I understand the
need to continually expand our knowledge of the system and our ability
to work, grow and expand within the system. The system will recover from
our mistakes. It just may recover without us.

Sincerely,

D Den Beste

202-547-9429

**michael caniglia**

11423 t circle , omaha, NE 68137

January 6, 2009 1:13 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

NO TO NANO\...The same property that makes these nanomaterials lucrative
to manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

michael caniglia

11423 t circle

omaha, NE 68137

202-547-9429

**John Nord**

306 Winthrop St #136, Taunton, MA 02780

January 6, 2009 1:11 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am the father of a child who is disabled. Why? Only God knows. Yet the
\"run-wild\" industrial model (without proven, scientific safeguards for
future consequences) is a possible cause. Whether, the \"junk\" left
behind ends up in the air, water, or land, it is dangerous to people and
the earth we live in. The same property that makes these nanomaterials
lucrative to manufacturers\--their highly enhanced germ-killing
action\--can be highly destructive to the environment and raise serious
human health concerns. 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 wide range of products already available is creating broad
and intrusive exposures to the public and the environment. Many of the
products are meant for children (baby bottles, toys, stuffed animals,
and clothing) or otherwise create high human exposures (cutlery, food
containers, paints, bedding and personal care products) despite very
little study of nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

John Nord

306 Winthrop St

#136

Taunton, MA 02780

202-547-9429

**suzan ozel**

8301 larch lane , evansville, IN 47710

January 6, 2009 1:11 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Please act in the long term health interests of humans and the entire
eco-system.

Thank you for taking my views under consideration.

Sincerely, Suzan Ozel 8301 Larch Lane Evansville, IN 47710

Sincerely,

suzan ozel

8301 larch lane

evansville, IN 47710

202-547-9429

**Pamela Anne Lowry**

, ,

January 6, 2009 1:10 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Already, studies have shown that nano-silver can harm fish and aquatic
ecosystems, as well as potentially interfere with beneficial bacteria in
our bodies and the environment. And, like many \"anti-bacterial\" agents
before them, they actually encourage the development of more virulent
harmful bacteria.

Recent scientific studies have also shown that nano-silver is much more
toxic and can cause damage in new ways. A 2005 study found that
nano-silver is approximately 45 times more toxic than standard silver. A
2008 study showed that washing nano-silver socks releases substantial
amounts of the nano-silver into the laundry discharge water, which of
course ultimately reach natural waterways, again endangering fish and
acquatic ecosystems. Also worrying is another 2008 study which found
that releases of nano-silver can destroy benign bacteria used in
wastewater treatment.

These materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Pamela Anne Lowry

202-547-9429

**Mona Dube**

9 Warner Place , Newport, RI 2840

January 6, 2009 1:10 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. I am most concerned about the health of our CHILDREN!
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 wide
range of products already available (unknown to most of the population)
is creating broad and intrusive exposures to the public and the
environment. Many of the products are meant for children (baby bottles,
toys, stuffed animals, and clothing) or otherwise create high human
exposures (cutlery, food containers, paints, bedding and personal care
products) despite very little study of nano-silver\'s potential human
health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much MORE toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially POISON fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Mona Dube

9 Warner Place

Newport, RI 2840

202-547-9429

**David Gustafson**

, Moline, IL 61265

January 6, 2009 1:07 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.I look forward to your
reply!

Sincerely,

David Gustafson

Moline, IL 61265

202-547-9429

**Danny and Diane Paschal**

621 Joyner St , Greensboro, NC 27403

January 6, 2009 1:05 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts. As a nurse, I cared for
patients exposed to silver nitrate via use for nose bleeds. It\'s now a
well known medical fact that this type of exposure leads to PERMANENT
silver precipitation to the skin. It is no longer used because of these
disasterous results. Nothing is more disfiguring than a person\'s skin,
silver in color from head to toe. In other words, here is a perfect
example of a metal being in body contact 9through mucous membrane0 and
the body not being able to elimenated this substance by ANY process!

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulation

Sincerely,

Danny and Diane Paschal

621 Joyner St

Greensboro, NC 27403

202-547-9429

**Connie Lippert**

216 Redbud St , Seneca, SC 29672

January 6, 2009 1:03 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

I am very concerned about these new nano materials, their effect on the
environment, human bodies, and wildlife. Throrough and complete testing
must be done before they are considered for widespread use.

Thank you for taking my views under consideration.

Sincerely,

Connie Lippert

216 Redbud St

Seneca, SC 29672

202-547-9429

**I Rucker**

2613 Cullum Rd , Bel Air, MD 21015

January 6, 2009 1:03 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We should be very much concerned with the impact on health and the
environment of substances introduced through nanotechnology. All such
substances should be carefully reviewed as to their long term impact on
humans, livestock, produce and our ecosystem. The wide range of products
already available is creating broad and intrusive exposures to the
public and the environment.

For example, while silver is known to be toxic to fish and aquatic
organisms, recent scientific studies have shown that nano-silver is much
more toxic and can cause damage in new ways. A 2005 study found that
nano-silver is approximately 45 times more toxic than standard silver. A
2008 study showed that washing nano-silver socks releases substantial
amounts of the nano-silver into the laundry discharge water, which will
ultimately reach natural waterways and potentially poison fish and other
aquatic organisms. Another 2008 study found that releases of nano-silver
can destroy benign bacteria used in wastewater treatment.

These novel materials must be carefully regulated as pesticides because
of their germ-killing use. The agency should GRANT the legal petition it
has pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human health
and on the environment, particularly on endangered species and their
habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Please take a long-term view when deciding which substances will benefit
human kind rather than do harm.

Thank you.

Sincerely,

I Rucker

2613 Cullum Rd

Bel Air, MD 21015

202-547-9429

**Arnie Welber**

5349 NW 90th Av , Sunrise, FL 33351

January 6, 2009 1:00 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

EPA cooperation is essential.

I remain, At EPA\'s pleasure,

Sincerely,

Arnie Welber

5349 NW 90th Av

Sunrise, FL 33351

202-547-9429

**Alixandra Mullins**

145 Marina , Aptos, CA 95003

January 6, 2009 1:00 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Caution with regards to human health and consumers is vital to the issue
of nano-materials.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Alixandra Mullins

145 Marina

Aptos, CA 95003

202-547-9429

**Lauren Burton**

390 Palo Alto Avenue , Palo Alto, CA 94301

January 6, 2009 1:00 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

Given their potential harmful effects, it is unconscionable to allow
nano-silver products to be sold into the marketplace without
understanding their potential for damage and without regulating their
distribution. These novel materials must be regulated as pesticides
because of their germ-killing use. The agency should GRANT the legal
petition it has pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver\'s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Lauren Burton

390 Palo Alto Avenue

Palo Alto, CA 94301

202-547-9429

**Dianne Miller-Boyle**

514 NW 43 , Okla city, OK 73118

January 6, 2009 12:56 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

We already know that there are too many chemicals used in our
environment that are untested or tested and unsafe. It is time to stop
further releases of unknown substances and start requiring proof of
safety. The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Dianne Miller-Boyle

514 NW 43

Okla city, OK 73118

202-547-9429

**Yvonne Korshak**

1025 Fifth Ave. , NY, NY 10028

January 6, 2009 12:52 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Nanomaterials can be very environmentally destructive, and may cause
serious human health concerns. Nano-silver can harm fish and the aquatic
environment, and in killing some bacteria may cause other more dangerous
bacteria to get a developmental edge. These Nano products are fast
getting to be everywhere so that everyone has exposure to them \-- some
are baby products, and yet, inspite of the potential harm there has been
very little study to examine health effects.

In 2005, a study found that nano-silver is approximately 45 times more
toxic than standard silver. A study in 2008 found that when you wash
nano-silver socks, substantial amounts of the nano-silver is released
via the dirty laundry water \-- and this is going to end up in our
waterways, potentially poisoning fish and other water creatures. Another
study in 2008 found that nano-silver releases can destroy benign and
useful bacteria in wastewater treatment contexts.

I urge that the agency GRANT the legal petition it has pending. This
would mean that:

1\. Nano-silver classified as a new substance & nano-silver products
regulated as new pesticides.

2\. This would require current and future nano-silver products to
undergo mandatory EPA pre-market approval.

3\. Current products would have to be removed until and unless they
received EPA approval.

4\. Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

5\. EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

6\. EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

7\. If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

8\. EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

I appreciate your giving my views on this matter your careful
consideration. Thank you!

Sincerely,

Yvonne Korshak

1025 Fifth Ave.

NY, NY 10028

202-547-9429

**Chris Wrinn**

56 Harborview Ave , Milford, CT 06460

January 6, 2009 12:52 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

People with auto-immune conditions are at high risk of any substances
that don\'t belong in the body. Nanoparticles are indeed risky business.
It is obvious that special interests are involved with this.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Chris Wrinn

56 Harborview Ave

Milford, CT 06460

202-547-9429

**Rachelle Greene**

13042 Clarewood Dr , Houston, TX 770721765

January 6, 2009 12:40 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

Quite honestly, i purchased a set of very expensive \"Fresher-Longer\"
food containers from the now bankrupt Sharper Image, and after doing a
little research on the properties of Nano-silver, i am quite concerned.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Rachelle Greene

13042 Clarewood Dr

Houston, TX 77072-1765

202-547-9429

**Linda Kilgore**

3437 Van Buren Street , Chattanooga, TN 37415

January 6, 2009 12:37 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

We have had many lessons in what happens when we put products on the
market without adequate testing, from medications to pesticides to food
products. Please take the responsible path and put public safety and
environmental protection first.

Thank you for taking my views under consideration.

Sincerely,

Linda Kilgore

3437 Van Buren Street

Chattanooga, TN 37415

202-547-9429

**Ryan Wagner**

753 Chelsea Place , Janesville, WI 53546

January 6, 2009 12:36 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I was a member of a citizen group who educated other citizens about
citizen issues of nanotechnology. While we were generally in favor of
the family of technologies under the \"nanotechnology\" umbrella profit
maximation nor fear of lawsuits is not sufficient enough incentive to
ensure wise use let alone deny very dangerous use.

Nanomaterials need to be openly labeled and there need to be checks in
place.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Sincerely,

Ryan Wagner

753 Chelsea Place

Janesville, WI 53546

202-547-9429

**Catherine Smith**

234 W Main St. , Watertown, TN 37184

January 6, 2009 12:36 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

These nanomaterials can be highly destructive to the environment and
raise serious human health concerns. 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 wide range of products already available
is creating broad and intrusive exposures to the public and the
environment. Many of the products are meant for children (baby bottles,
toys, stuffed animals, and clothing) or otherwise create high human
exposures (cutlery, food containers, paints, bedding and personal care
products) despite very little study of nano-silver\'s potential human
health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Catherine Smith

234 W Main St.

Watertown, TN 37184

202-547-9429

**Frances Renaud**

74 School St. , Westminster, VT 05158

January 6, 2009 12:36 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

Frances Renaud

74 School St.

Westminster, VT 05158

202-547-9429

**L. Duram**

607 Surrey , Carbondale, IL 62901

January 6, 2009 12:36 PM

Docket No. EPA-HQ-OPP-2008-0650

Subject: Docket No. EPA-HQ-OPP-2008-0650: Regulate nano-silver products
as new pesticides

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.

I am perfectly willing to accept nano-technology in our products, but
please be cautious and demand complete, 3rd party, scientific research
before we allow these products.

The same property that makes these nanomaterials lucrative to
manufacturers\--their highly enhanced germ-killing action\--can be
highly destructive to the environment and raise serious human health
concerns. 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
wide range of products already available is creating broad and intrusive
exposures to the public and the environment. Many of the products are
meant for children (baby bottles, toys, stuffed animals, and clothing)
or otherwise create high human exposures (cutlery, food containers,
paints, bedding and personal care products) despite very little study of
nano-silver\'s potential human health impacts.

While silver is known to be toxic to fish and aquatic organisms, recent
scientific studies have shown that nano-silver is much more toxic and
can cause damage in new ways. A 2005 study found that nano-silver is
approximately 45 times more toxic than standard silver. A 2008 study
showed that washing nano-silver socks releases substantial amounts of
the nano-silver into the laundry discharge water, which will ultimately
reach natural waterways and potentially poison fish and other aquatic
organisms. Another 2008 study found that releases of nano-silver can
destroy benign bacteria used in wastewater treatment.

These novel materials must be regulated as pesticides because of their
germ-killing use. The agency should GRANT the legal petition it has
pending. As a result,

\* Nano-silver will be classified as a new substance and nano-silver
products regulated as new pesticides.

\* That would require current and future nano-silver products to undergo
mandatory EPA pre-market approval.

\* Current products would have to be removed until and unless they
received EPA approval.

\* Approval would only occur if the agency found the products did not
create an unreasonable risk to the environment.

\* EPA would also assess nano-silver?s potential impacts on human
health, particularly on children and infants, and on the environment,
particularly on endangered species and their habitat.

\* EPA would require manufacturers to submit any needed data about the
nanomaterials and current unknowns to conduct its assessments.

\* If any of the nano-silver products were approved and registered as
pesticides, their use would be conditioned as necessary to protect the
environment and human health, including the use of warning and approved
labeling.

\* EPA would also amend its regulations to require nano-specific data,
testing, and risk assessments for nanomaterial pesticide products.

Thank you for taking my views under consideration.

Sincerely,

L. Duram

607 Surrey

Carbondale, IL 62901