Friday, January 23, 2009

Special Update on the Battle to Save Colloidal Silver From Regulation By the EPA

Special Update on the Battle to Save Colloidal Silver From Regulation By the EPA

I have some good news and some bad news regarding the petition by extremist environmentalists and other special interest groups to have silver nanoparticles (read: colloidal silver) regulated by the EPA as a "pesticide," which would ultimately result in a ban on the sale of colloidal silver products.

First the good news:

I’ve just been to the EPA web site and discovered that whereas public comments about the petition had been running ten to one in favor of it during the month of December when only the extremist environmental groups who sponsored it knew about it, the comments have been running a hundred to one against it ever since the colloidal silver and natural health communities have caught wind of this insidious plot.

That’s phenomenal. Obviously, the colloidal silver community and the natural health community have pulled together as one, standing in unison against this onerous and heavy-handed petition to regulate “silver nanoparticles.”

We are grateful to have been able to play a key role in alerting the colloidal silver and natural health communities to this stealth campaign to have the EPA regulate, and eventually ban, colloidal silver.

The outpouring of opposition to the petition has allowed the colloidal silver and natural health communities to overcome the advantage held by the extremist environmental groups like ICTA and Friends of the Earth who had been quietly stacking the EPA online comments system with “canned” comments from their members in favor of their own petition. They solicited these comments through slick email campaigns designed to scare their members into believing that “silver nanoparticles” pose an imminent and dire threat to the environment and need to be immediately regulated as "pesticides."

If you helped in this campaign by posting your comments against the ICTA petition to have the EPA regulate silver particles as "pesticides" through the EPA online comment system, or by sending emails or faxes to the EPA Administrator Stephen Johnson as we requested (see below), then please take a moment and give yourself a nice, big pat on the back. You are helping turn the tide in favor of colloidal silver by taking such an active part in this battle to stop the impending EPA regulation of so-called “silver nanoparticles.”

Now, here's the bad news:

Back in December, several of the extremist environmental organizations sponsoring this petition -- including ICTA and Friends of the Earth -- had formally requested the EPA to extend the comments deadline, so they could buy more time to muster up additional aid and support from the membership rosters of other like-minded environmental groups.

But as of early January, the EPA had basically ignored this request. After all, there was simply no reason to extend the comments deadline when the comments were already running ten to one in favor of the petition. It looked like a slam-dunk sure-thing that the EPA would easily be able to approve the petition, and begin regulating silver nanoparticles out of existence for all but the largest of corporate financial interests who could afford the millions of dollars worth of environmental impact reports required by EPA in order to sell products containing silver nanoparticles.

Then, thanks largely to our efforts to alert the colloidal silver community and the natural health community to this plot, the tide of public sentiment turned dramatically against the petition. Suddenly public comments on the EPA web site were running over 100 to one against the petition. And the EPA saw their slam-dunk sure-thing disappearing right before their eyes. After all, without broad public support, it would be very difficult for the EPA to approve the petition giving the agency the broad new powers to regulate silver particles.

So within a matter of just a few short days after hundreds of new comments starting pouring in against the petition, the EPA rapidly switched gears and approved the earlier request by ICTA and Friends of the Earth to extend the comments deadline.

Why?

It is obvious that the EPA had witnessed how the colloidal silver and natural health communities have pulled together in a massive show of opposition to the petition to have silver nanoparticles regulated as a "pesticide."

EPA knew that with public comments suddenly running more than 100 to one against the petition, they were going to have to give their environmentalist cronies more time to reach multitudes of like-minded environmentalists worldwide, so they could come to the EPA web site to comment in favor of the petition. After all, what the EPA wants is to become the sole arbitrator of who gets to sell products containing silver particles, and who doesn’t.

Unfortunately, if the rabid environmentalists are allowed to regain the upper hand by soliciting tons of additional comments in favor of the petition from their fellow environmental groups worldwide, it will be a disaster for anyone who wants widespread availability of colloidal silver to continue.

Why Freedom of Consumer Choice Will Be a Distant Memory

Indeed, freedom of consumer choice will be all but a distant memory in regards to colloidal silver products. After all, once EPA begins regulating silver nanoparticles as a "pesticide," their next step will be to require colloidal silver manufacturers to prove that their product cannot harm “ecologically sensitive microbes” in the environment, as documented on this web page.

There are probably only a small handful of colloidal silver manufacturer on the face of the earth – if any – who can afford the millions of dollars in testing and environmental impact reports the EPA will require. So without a doubt, your favorite brand of colloidal silver will probably be gone forever if the EPA approves this petition and begins regulating silver nanoparticles as “pesticides.”

Here’s the key to understanding this whole scheme: If this petition is granted by the EPA, only the wealthiest corporate interests that are willing to kow-tow to EPA regulatory demands and spend millions of dollars on “environmental impact” reports will be able to sell products that contain silver nanoparticles.

Do you think these big corporate interests will sell colloidal silver? Not on your life. Once safe, natural and relatively inexpensive colloidal silver is taken off the market by the EPA, the big corporate interests will patent products containing engineered silver nanoparticles, and you will only be able to get therapeutic silver products by doctor’s prescription.

Exactly What The EPA Wants

This is exactly what the EPA wants, i.e., to transfer control of the sale of silver nanoparticles from the hundreds of colloidal silver vendors in existence today, to a small handful of big corporate interests.

And, of course, the EPA will become the sole arbitrator over who can sell products containing silver nanoparticles and who can't. Public access to safe, natural colloidal silver will be a thing of the past. It's that simple. That's their game-plan.

So What’s Happening Right Now?

Right now the extremist environmental and special interest groups like ICTA and Friends of the Earth are gearing up to have their like-minded environmental groups begin pouring their support behind the petition to have EPA regulate silver as an environmentally “dangerous pesticide.” They are claiming that if silver isn't immediately regulated by EPA as a "pesticide" the ecology and the environment as a whole will face irreparable and permanent damage.

That is of course a total crock. Anyone with an ounce of common sense knows that silver nanoparticles can’t harm the ecology when returned to the environment. Why? Because the tiny silver particles rapidly bond with other natural elements in the environment, such as minerals, mineral salts and other substances. This bonding, also known as “agglomeration,” destroys the nano-scale properties of the tiny silver particles and renders them essentially inert.

In other words, the silver simply returns to the environment it originally came from as another harmless mineral substance. The idea that it can somehow "harm the environment" or poses an “imminent threat to the environment” is ludicrous at face value. It is the worst kind of junk science imaginable. But like most junk science, it serves Big Corporate interests very well.

Nasty Tactics?

Worse yet, the EPA has apparently resorted to using some nasty tactics in order to stop the tide of public comments coming in against the petition to regulate silver as a “pesticide.”

While theEPA has indeed extended the public comments deadline on the petition to March 20 at the behest of the environmental groups behind it, they have simultaneously disabled the direct link to allow comments on the EPA web site – a link which we had discovered and were instrumental in having posted on numerous colloidal silver and natural health web sites during the first week of January after we began alerting the colloidal silver community and the natural health community to this insidious plot to regulate silver nanoparticles as a “pesticide.”

By disabling the direct link to the EPA comments section for this petition, hundreds if not thousands of new public comments from the colloidal silver community and natural health community have effectively been prevented from being posted.

Meanwhile, the rabid environmental groups are busy collecting additional public comments in favor of the petition. They are using a slick email and web site-based campaign that allows them to collect and hold onto the comments for later dispersal.

Our best guess is that once the public comments link on the EPA web site is restored, probably sometime just before the new deadline of March 20, these nutcase environmentalists intend to bombard the EPA comments system with a massive new barrage of comments they've collected in favor of the petition to regulate silver particles as “pesticides.”

Their goal is to turn the tide of comments back in favor of the petition. And then the EPA can legitimately say that they have fairly and carefully weighed public opinion, and have decided to regulate silver nanoparticles as “pesticides.” That will be the beginning of the end for the public commercial sale of colloidal silver.

What We’re Doing and What YOU Can Do to Help Right Now…

First, we are demanding that the EPA restore access to the public link that allows everyone to post comments on the EPA web site RIGHT NOW, rather than waiting until the rabid environmental groups gather enough new comments to stack the deck in favor of the petition once again, just as they did in the beginning.

Second, we are requesting that everyone in the colloidal silver and natural health communities continue to put massive pressure on the EPA through every means possible with polite and respectful comments letting them know that you are not happy about the petition to regulate silver particles as “pesticides,” and would like them to reject it.

How to Call The EPA to Help Get the Public Comments Link Restored

If you would like to help us in demanding that the public link be restored for comments on the EPA web site, you can call the toll-free EPA “Help Line” at 1-877-378-5457, and politely and respectfully request that they restore the comments link for Docket #EPA-HQ-OPP-2008-0650, also known as the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”

Special request: Please, as soon as anyone reading this article finds out that a public link to the EPA comments system for this petition has been restored, or that a brand new link has been instituted, let us know by emailing us the specific link at info@TheSilverEdge.com. That way, we can get the word out to the rest of the colloidal silver community and natural health community that a new public comments link is available.

Also, if you call the EPA “Help Line” number above and find out that the comments link has already been restored, or that a new link has been put up, be sure to thank them. Then start posting comments on the EPA web site right away, as well as following through with the three crucial steps outlined below. It is absolutely essential that we act decisively and yes, even relentlessly at this point. We must make sure the EPA knows that the public is against this petition to regulate silver particles as “pesticides.”

How to Help Us Continue Putting Pressure on the EPA to Reject the Petition

In the meantime, while we are continuing to put pressure on the EPA to restore the public comments link on their web site for the petition, you can help us put additional pressure on the EPA to reject the petition by taking the following three simple but vital steps:

First, email EPA Administrator Stephen Johnson with your comments against the petition to have silver regulated as a “pesticide.” His email address is: johnson.stephen@epa.gov

If you have already emailed him in the recent past, please do so again. And tell all of your like-minded friends to do so, too. This is critical.

Secondly, fax your comments to EPA Administrator Stephen Johnson, at his Washington DC fax number: (202)-501-1450. Again, if you have already faxed him, do so again. And again. And again. We need a flood of emails and faxes going to this man, telling him politely but in no uncertain terms that he needs to reject the petition to regulate silver particles as “pesticides.”

Third, send a letter to the Washington DC office of EPA Administrator Stephen Johnson. His address is as follows:

Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P)
ATTN: Administrator Stephen Johnson
Environmental Protection Agency
1200 Pennsylvania Ave, NW
Washington, DC 20460-0001

Don’t Forget To Include the Following Vital Information:

All comments to the EPA – whether you make them by email, fax, snail mail or through the public comments section of their web site once it is restored -- must reference the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides,” and must also reference Docket # EPA-HQ-OPP-2008-0650.

What to Do If You Don’t Know What to Say…

If you don’t know what to say in your comments, here’s some suggested text:

Dear EPA Administrator Stephen Johnson:

I am writing in reference to Docket # EPA-HQ-OPP-2008-0650, also known as the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides”

I respectfully request that you reject this petition, for the following three reasons:

One: There is no documented evidence of any harm having ever been caused to the environment from silver nanoparticles

Two: Several valid studies by reputable science-based organizations have already documented that no harm to the environment from silver nanoparticles can occur at present or projected future levels (1,2)

Three: ICTA’s entire case for the petition is based upon nothing more than raw and sensationalistic speculation extrapolated from a few spotty laboratory studies whose data was apparently skewed to produce the results they wanted.

Since only lab studies have been used to justify ICTA’s flimsy position that silver nanoparticles are harming the environment, and since no true environmental studies have demonstrated such alleged harm, there is simply no reason to allow ICTA and their cohorts to continue this charade against products containing silver nanoparticles.

As the recent study by Dr. George Maass has demonstrated (3), silver nanoparticles simply cannot harm the ecology when returned to the environment because the tiny particles rapidly bond with other elements in the environment. This in turn destroys their nano-scale properties, rendering them inert. In short, silver nanoparticles simply return to the environment as another harmless mineral substance.

Since EPA is supposed to be an evidence-based agency and there is no evidence whatsoever to demonstrate the erroneous and shrill claims of ICTA and its counterparts against products containing nanosilver, please reject and dismiss this petition and stop wasting taxpayer monies on this issue.

EPA already has sufficient authority under FIFRA to regulate substances demonstrated to cause harm to the environment. This additional proposed regulation is superfluous and unnecessary, and a complete waste of taxpayer funds.

Regards,
(sign your own name and include the below cross-reference numbers)

References:

1.) Environ Sci Technol. 2008 Jun 1;42(11):4133-9.
2.) Environ Sci Technol. 2008 Jun 15;42(12):4447-53.
3.)
http://www.silver-colloids.com/Papers/SilverNoThreat.pdf

Saying It In Your Own Words Is Always Best

Of course, comments in your own words are always better than “canned” comments like the one above. So please express yourself in your own words if time permits and you have the unction to do so. Otherwise, be sure to send the above comment, with your own signature. Or feel free to derive your own comments from the above letter.

By the way, if you own a company or belong to a natural health-related organization, please be sure to make your comments in your own name as well as in the name of your company or organization. Adding your company or organization name to your comments gives credibility to your response. And that will help offset some of the comments from the "heavy hitter" organizations the environmentalist groups are currently lining up in support of this disastrous petition to have silver nanoparticles regulated as “pesticides.”

It’s Up to You…

The ball is in your court. Whether or not colloidal silver will be regulated into oblivion at the behest of rabid environmentalists who want the world to believe that silver particles represent some kind of imminent threat to the environment is in your hands.

Please do your part and help us flood the EPA over the next few weeks -- in fact, all of the way up to March 20 -- with an even greater barrage of comments against this petition than we managed to generate during the first few weeks of January before the EPA so suddenly and unexpectedly extended the comments deadline at the behest of their environmentalist cronies.

If we fail to continue to act at this point, it will give EPA and the environmental groups exactly what they have want, i.e., enough time to stack the public comments with additional requests to have the EPA regulate silver particles as “pesticides.”

We must continue to act quickly and decisively. This is how health freedom battles are won.

I won’t kid you. It’s not going to be an easy battle, because the organizations we are up against are large and well-organized, and have huge membership bases. And the EPA already favors them, and has purposely given them more time to solicit comments favorable to their own petition to have the EPA regulate silver particles as "pesticides.

But we have already shown that we can shake them to the core with a barrage of our own public comments. And just as little David slew Goliath with a single smooth stone, we too can take down the environmentalist “Goliaths’ with our individual comments against the petition to regulate silver as a “pesticide.”

We simply must continue to act in unison and with deliberation and determination, straight through to the new deadline of March 20th. To help, just follow the simple steps outlined above.

Finally, be sure to pass this information along to your like-minded friends and colleagues, so they can help, too.

Regards,
S. Spencer Jones,
http://www.lifeandhealthresearchgroup.com/
http://www.thesilveredge.com/

P.S. While I truly believe we can win this battle, please keep in mind that once you own the means of colloidal silver production, no one can ever take your colloidal silver away from you, no matter how many onerous regulations they pass.

That’s why I strongly urge you to purchase a Micro-Particle Home Colloidal Silver Generator as quickly as possible. With your own colloidal silver generator, which is smaller than a coffee pot and easier to use, you can make all of the safe, natural colloidal silver you want, any time you want, in the comfort, privacy and security of your own home, for about 36 cents a quart.

Read more about the new Micro-Particle Colloidal Silver Generator at: http://www.TheSilverEdge.com/, or at http://www.MicroParticleGenerator.com/.

If you are new to colloidal silver usage, you may want to further educate yourself. There are dozens of extremely helpful articles about colloidal silver usage on this very blog site (i.e., http://www.ColloidalSilverSecrets.blogspot.com/). And it’s all FREE. So dig in and start reading today.

Or, for additional in-depth information on colloidal silver usage, you can purchase an inexpensive copy of our brand new 60-minute, studio-quality Colloidal Silver Secrets video at http://www.ColloidalSilverSecretsVideo.com/.

Finally, for colloidal silver usage information that is absolutely encyclopedic in scope and content, learn more about our newly updated 547-page book, The Ultimate Colloidal Silver Manual, at http://www.UltimateColloidalSilverManual.com/


Important Links:

http://www.ColloidalSilverSecretsVideo.com
http://www.UltimateColloidalSilverManual.com
http://www.TheSilverEdge.com
http://www.MicroParticleGenerator.com
http://www.ColloidalSilverCuresMRSA.com
http://www.LifeandHealthResearchGroup.com

1 comment:

Vitamin Lawyer Health Freedom Blog said...

When I spoke to the Help Desk at www.regulations.gov yesterday they did confirm that the comment period was extended to 03/20/09 but there is a new extension on the Docket No. that needs to be used to reach the comment page on Regulations.gov. That is #EPA-HQ-OPP-2008-0650-0506 (an additional 4 digits, 0506 at the end).

The revised direct comment page is at:

http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=090000648081edc9

Or you can use the Action Item we've set up through www.HealthFreedomUSA.org -

http://salsa.democracyinaction.org/o/568/t/1128/campaign.jsp?campaign_KEY=26405

Keep up the great work!

Ralph Fucetola JD
Natural Solutions Foundation Trustee

PS - I've blogged about this issue at:

http://vitaminlawyerhealthfreedom.blogspot.com/2009/01/defending-nano-silver.html

And we've posted more information at:

http://www.healthfreedomusa.org/?p=1773