EPA Field Activities Relating to Nanoscale Materials
Bradley R. Grams, Environmental ScientistChemicals Management Branch
Land and Chemicals Division, EPA Region 5
About Regions: Roles, Approaches &
General Activities
Regional RolesEPA Regions are “implementers of program”
Implement EPA programs through research, programs, outreach and/or enforcement Program Development (e.g., Pollution Prevention, Stewardship,
etc.) Compliance Assistance, Compliance Monitoring & Enforcement Chemical Monitoring & Surveillance
Work with State and local governments to address their specific needs State & local government assistance, support and outreach Government Access assistance (e.g., finding the right resource) Community engagement (through Environmental Justice,
CARE, etc.) Facility oversight (e.g., addressing non-compliance)
General ApproachNanoscale Materials are still covered under
many Federal statutes and regulationsEPA regional efforts have focused on using
current authorities (e.g., FIFRA, CWA, RCRA, etc.) at the Federal level to address nanoscale material concerns as they arise
Where applicable or possible, State or local authorities are utilized to supplement Federal actions (e.g., to go beyond federal requirements, address a specific local issue, etc.)
General ActivitiesRegion 5 has scientists, engineers and
analysts who work with all EPA Headquarters Offices on nanotechnology
Cover nanotechnology in different ways (through voluntary, stewardship or regulatory mechanisms):Discharges & Water Treatment (CWA & SDWA)Nano-pesticides (FIFRA), particularly nano-
silver (nAg)Lifecycle and Waste Management (RCRA)Industrial Nanomaterials (TSCA)Field Monitoring, Surveillance & Research
Nanotechnology Definitions
Nanotechnology DefinitionsGenerally, EPA (Offices and Regions) utilizes the NNI
three-part definition in defining nanotechnology or its nanoscale materials, considering:Size: Approximately 1 – 100 nm in any one dimensionProperties: The intermediate size generates unique
phenomena and novel propertiesControl: Ability to understand, control, and/or manipulate
matter at this scale Nanoscale material activities at the regional level are most
times determined by local, State and Regional needs (e.g., State concerns, community concerns, site issues, etc.)
Definitions of nanotechnology can be unclear at timesClarity is essential in determining where action is requiredAt times it can be easier to treat nanotechnology more
generally due to material/product/waste ambiguity
Nanotechnology Field & Program
Activities
Nanotechnology Concerns in the FieldWhen people think of nanotechnology
regulation, the EPA TSCA program likely comes to mind
However, nanoscale materials are also addressed through many other EPA and non-EPA activities:EPA Examples: Pesticides, Devices, Releases,
Wastes, Industrial Production, ResearchNon-EPA Examples: Foods/Food Products,
Personal Care Products (PCPs), Worker Safety (OSHA), certain consumer products
Field Work & Activity Examples - WaterNanoscale Materials in Water Treatment
Evaluating claims of water treatment efficacy for homeland security purposes (e.g., temporary hospital utilization)
Evaluation of chemical-specific water treatment methods and effects including nanoscale materials
Nanoscale Materials in Water DischargeChemical Monitoring & Surveillance of Great Lakes
through the Great Lakes National Program OfficeConsolidation and coordination of POTW/WWTP data
on nanoscale material monitoring & surveillanceAssisting WWTPs and POTWs in source identification
Field Work & Activity Examples- LandNanoscale Materials in Pesticides
Compliance Monitoring and Enforcement for Unregistered nano-pesticides and/or devices Nano-pesticides with inappropriate labeling/pesticidal claimsBoth activities with the Wisconsin Department of Agriculture,
Trade and Consumer Protection under the FIFRA program
Nanoscale Materials in Site RemediationThe Superfund program has implemented limited site
remediation with nanoscale materials (nZVI) for in situ chemical treatment
Nanoscale materials have been gaining traction as an in situ treatment alternative, particularly for halogenated solvent contamination
Field Work & Activity Examples - Land (continued)
Nanoscale Material Lifecycle AssessmentUsing an integrated approach, evaluating nanoscale
materials’ life cycle, for material and waste management
Through the Pollution Prevention (P2), RCRA and TSCA programs, promoting enhanced risk management of materials, particularly at end-of-life
Assisting companies in waste and materials management These activities have been completed with the Wisconsin Department of Natural Resources under the RCRA program, through e-Waste and other materials stewardship programs.
Field Work & Activity Examples- Land (continued)
Nanoscale Material Manufacturer/Industrial Production Chemical ReportingProviding Compliance Assistance to entities in
reporting Nanoscale Materials under TSCA Pre-Manufacture Notices Health & Safety Information Testing
Assisting entities in acquiring/providing chemical information
Compliance Monitoring and Enforcement under TSCA
NanotechnologyResearch Activities
Research SupportIn addition to field and program activities,
the Region 5 Laboratory also provides research and laboratory support:Support for Research and Development
Supplemental Research Capacity Building
Field Operation Support (Sampling and Collection)
Data collection and interpretationMethod Development
Findings & Program Directions
FindingsNanoscale materials and nanotechnology
issues have required significant monitoring & surveillanceMany information and research gaps still existOverall material definitions are unclearLarge-scale sources tend to be very discrete
and place-based (e.g., difficult for frameworks)Lifecycle concerns have not matured to the
point at which full analyses may be providedMore chemical information is needed
Findings(continued)
As a result of these issues and gaps, emphases have focused on:Enhanced research and laboratory capacity, Increased chemical monitoring and
surveillanceUsing current authorities to address nanoscale
material concerns where necessaryIncreasing interagency collaboration
Future DirectionEPA Region 5 will continue to provide
assistance to State and local Partners as nanoscale material concerns ariseEmphasis on State and local government
assistance and coordinationSector-based, Place-based or community-based
initiativesImproving access to chemical information
Sample State Program Considerations
Within Region 5The State of Minnesota is currently implementing the “Toxic
Free Kids Act” (Minn. Stat. 2009 116.9401 – 116.9407)Through the Minnesota Department of Health and Minnesota
Pollution Control AgencyThis legislation requires the Minnesota Department of Health
(MDH) to create two lists of chemicals: one list called “Chemicals of High Concern” and one called “Priority Chemicals.”
In addition, the Minnesota Pollution Control Agency (MPCA) is required to make recommendations about mechanisms to reduce and phase out the use of priority chemicals in children’s products and to promote the use of safer alternatives.
Considers chemical risk in the context of childrenWhile this legislation is not nanotechnology/nanoscale material
specific, the program could be utilized as a framework for nanoscale materials
NationallyCalifornia EPA’s (Cal/EPA’s) Department of Toxics Control
(DTSC) chemical programs:Cal/EPA DTSC Data Call-in for Carbon Nanotubes
Data Collection for Carbon Nanotubes Information/Responses publicly available
Green Chemistry Program Alternatives Analyses/Assessment
Cal/EPA Library Acquiring Chemical Information
The States of Maine, Michigan, Oregon and Washington, have also begun implementing various types of chemical legislation or executive orders that could regulate or lead to regulation of nanoscale material use/management through other mechanisms
Contacts
Contact
Bradley R. Grams, Environmental ScientistChemicals Management BranchLand and Chemicals Division, EPA Region [email protected] (312) 886-7747 phone(312) 697-2527 fax