Yogi Berra said it best: It's like déjà vu, all over again.
The Environmental Protection Agency is again giving a nanosilver pesticide product a conditional registration, despite not having all the toxicity data it needs to assess its potential harm to humans and the environment. So NRDC is again bringing a lawsuit to block this pesticide from the market.
This time, EPA has granted the company Nanosilva a conditional registration for its nanosilver pesticide product to be used in plastics and textiles to suppress the growth of bacteria. However, the concerns about the health and environmental impacts from exposure to nanosilver remain, and EPA's attempts to address them fall flat.
Furthermore, EPA's continued reliance on the conditional registration process to allow pesticides onto the market is problematic. Conditional registrations are meant to be used sparingly, for pesticides that will not cause unreasonable adverse impacts on human health and the environment and are in the public interest.
Data show that nanosilver can penetrate cell membranes and deliver toxic silver ions directly inside of cells. Because of their very small "nano" size, laboratory rodent studies report that the pesticide particles can penetrate organs and tissues in the body that larger forms of silver cannot reach, including crossing the blood-brain barrier, the testicular barrier, and the placental barrier. As a result, the nano particles have access to the brain, testes, and fetal circulation. Once there, these particles are expected to continue to release toxic ions that can kill cells.
At the same time, there are no data to prove that this nanosilver product provides any actual consumer benefit. EPA relies on conjecture to argue that allowing this unproven material on the market would be in the public interest.
EPA is supposed to be in the business of protecting the public health and keeping dangerous pesticides off the market. But EPA's repeated approval of untested nanosilver products is grossly inconsistent with its mission.