Showing posts with label FIFRA. Show all posts
Showing posts with label FIFRA. Show all posts

Thursday, July 29, 2010

EPA Panel Still Looking at Ways to Regulate NanoSilver Products (Including Colloidal Silver)…

Radical environmentalists claim nanosilver is a “new invention” with “unique attributes” that are potentially toxic to the environment. They claim it needs to be taken off the market until it can be further studied in relation its effects on the environment, and that if allowed to be sold commercially, it should be heavily regulated by the EPA as a “toxic environmental pesticide.”


But is nanosilver really a “new invention”? Does it have “unique attributes” that are potentially toxic to the environment? Or are these claims simply exaggerated junk science attempts by neo-Luddite environmentalists to have this potentially life-saving substance re-categorized as an environmental toxin and regulated into oblivion?

As most readers of the Colloidal Silver Secrets blog are aware, there’s now a lot going on behind the scenes at the EPA in regards to the potential regulation of products containing silver nanoparticles -- including colloidal silver.

After the debacle last year in which a handful of radical environmental groups were soundly trounced in their efforts to force the EPA to pull nanosilver products off the market and begin to regulate them as “toxic environmental pesticides,” the EPA then established a Nanosilver Scientific Advisory Panel to further study the issues raised by the environmentalists, and come up with regulatory proposals in line with current science.

This new EPA Panel then held a meeting in Arlington, VA on November 3-5, 2009 to get the ball rolling. (You can see the transcript of that meeting -- apparently with some omissions --here.)

Does Nanosilver Meet the Criteria for More Stringent Regulation?

Fortunately, representatives of the Silver Institute’s newly formed Silver Nanotechnology Working Group (SNWG) attended the meeting. And in a presentation given by SNWG’s Dr. Murray J. Height, it was correctly emphasized that nanosilver simply does not meet the EPA’s two main criteria for a commercial product thought to be in need of more stringent regulation, which is to say, it is not a new invention and it does not have characteristically unique functional attributes.

Indeed, as Dr. Height pointed out to Panel attendees, nanosilver products have now been registered with federal agencies for over six decades, and have been manufactured for over 100 years. In fact, the first nanosilver product to be federally registered -- Silver Algaedyn, a product designed to control algae buildup in swimming pools – was registered under the FIFRA Act in 1954…a full 16 years before the official establishment of the EPA!

In other words, some federally registered commercial products containing silver nanoparticles actually pre-date the establishment of EPA itself.

So, contrary to the shrill cries of the radical environmentalists who have labeled nanosilver as a “new invention,” and have been pushing EPA to re-categorize nanosilver as an “environmental toxin” and regulate it into oblivion, the truth is that nanosilver is not “new” by any stretch of the imagination. It has a long history of use in registered commercial products going back well over 60 years, with no significant environmental repercussions whatsoever in all of that time. And therefore it does not meet the first and most important criteria for the consideration of additional regulatory oversight.

What’s more, SNWG representatives pointed out that all registered products containing silver nanoparticles – whether historical products or newly introduced -- work basically the same way: They release silver ions in order to inactivate potentially harmful microbes. As emphasized by the SNWG’s Dr. Rosalind Volpe in a recent letter to the EPA’s Scientific Advisory Panel:

Antimicrobial functionality is achieved via release of silver ions (Ag+) – a mechanism entirely identical to all EPA-registered silver products including silver salts, silver glasses and silver zeolites. The functionality of nanosilver is NOT unique.”

In short, nanosilver does not meet the second major criteria of a nanomaterial in need of additional study and regulation. It is not characteristically unique in its function. Silver nanoparticles work the same way today as they did 100 years ago. And once again, unlike many other EPA registered products, their well-known documented function has not caused any significant environmental repercussions in all of these years.

Clearly, the ridiculously wild claims of the radical environmentalist groups who have been working to force the EPA to re-categorize nanosilver as a potentially dangerous “environmental toxin” over the past two years are completely bogus.

Old Tactics that Didn’t Work the First Time Around

By claiming products containing nanosilver are “new” and “unique” the radical environmentalists behind the push to have the EPA regulate (read: ban) nanosilver products are attempting to circumvent the stumbling block the FDA originally came up against during their decade-long attempts to ban colloidal silver products in the 1990’s.

You see, the FDA was stopped cold by two facts: First, the FDA could not deny the fact that colloidal silver products had been widely commercially available since the substance was first produced in the late 1800’s. There was nothing new or original about them. And secondly, the FDA could not deny the fact that the overall historical safety record of colloidal silver over that 12 decade period had been far more admirable than, say, most federally regulated prescription drugs.

Faced with those hard facts, the FDA finally relented in 1999 and allowed colloidal silver to stay on the market, albeit with a few restrictions on its labeling and advertising.

We can only hope the EPA will exercise the same common sense the FDA was forced to exercise in 1999, and not add any additional regulatory burden on nanosilver-based products. Acting otherwise would be flying in the face of the known facts: Nanosilver has a long history of safe, environmentally friendly commercial usage, and its characteristic attributes are the same today as they were over 100 years ago.

The radical environmentalists are simply crying wolf, when there is no wolf in sight. According to some published sources, their entire campaign is agenda driven, and that’s why there is not the slightest semblance of rationality or balance to it.

Get the Facts

You can view a PDF copy of the Silver Nanotechnology Working Group’s excellent presentation in defense of nanosilver products to the FDA Nanosilver Scientific Advisory Panel here.

And here you can view a copy of the very informative follow-up letter from Dr. Rosalind Volpe of the Silver Nanotechnology Working Group to the EPA Acting Director of the Office of Pesticide Programs Dr. Stephen Bradbury.

Will These Irrefutable Facts Stop the Radical Environmentalists?

Don’t expect these simple, irrefutable facts to stop the radical environmentalists from actively pursuing their drive to have the EPA re-categorize nanosilver as a “toxic environmental pesticide.”

After all, they’ve been factually challenged on this issue from the start.

Even now, the radical environmentalists are capitalizing on the release of a new study from fellow environmentalists at Purdue University who have determined that – gasp! – if you overdose flathead minnows on high concentrations of commercially produced powdered silver nanoparticles in an artificial test tube laboratory environment, they will show signs of toxicity. (See this post for more information.)

The lengths these environmentalists will go to in order to have nanosilver regulated into oblivion as an “environmental toxin” are apparently boundless – including conducting agenda-driven studies that throw all principles of honest science and scholarship out the window.

That’s what makes the radical environmentalists so dangerous. They don’t care how they achieve their goals. The ends apparently justify the means.

One Final Thought…

Keep in mind that for all intents and purposes, nanosilver is colloidal silver.

That’s precisely why the radical environmentalist groups included the top four brands of colloidal silver in their original 2008/2009 petition to have the EPA pull all nanosilver products off the market.

Therefore it is critical that the colloidal silver community come together with the nanosilver industry on this issue and help support efforts to educate the EPA about the historical environmental safety of nanosilver products and their long history of usage.

One simple way of doing so is to support the great work of the Silver Institute and their newly formed Silver Nanotechnology Working Group (SNWG).

Helpful Links:


Tuesday, October 20, 2009

Act Quickly -- Tell the EPA to Keep Their Hands Off Colloidal Silver

A new EPA meeting on nanosilver is coming up. But EPA’s requested comment period has already passed. However…you should send your comments in anyway! Here’s why…

I’ve just found out that the EPA is going to have a 4-day “consultation meeting” of the FIFRA Scientific Advisory Panel, on the topic of regulating nanosilver, starting November 3 and running through November 6.


The specific purpose of the meeting, according to the EPA press release that was just brought to my attention, is to “review a set of scientific issues related to the assessment of hazard and exposure associated with nanosilver and other nanometal pesticide products.


In other words, the EPA appears to be moving forward on the formulation of plans to regulate the use of products containing nanosilver for “pesticidal” purposes.


How FIFRA Regs Could Cover Colloidal Silver Products


If you’ve followed this blog for any length of time, you no doubt know that the EPA has essentially ruled that bacteria, fungi and other microbes are now classified as “pests” under their newly revised FIFRA (i.e., Federal Insecticide, Fungicide and Rodenticide Act) regulations.


And you likely also know that “nanosilver” (i.e., extremely tiny particles of silver), when used for anti-microbial purposes, has now been classified under the FIFRA regulations as a “pesticidal” product.


These revisions to the FIFRA regulations, of course, were specifically designed to give EPA authority to regulate all products containing nanosilver.


Many observers sounded the alarm last year after EPA first ruled that nanosilver had been classified under FIFRA as a “pesticidal” product, warning that this new classification could have extremely detrimental consequences for the colloidal silver community.


But it wasn’t until January of this year that the colloidal silver community finally sat up and took notice. This, after a consortium of extremist environmental groups including the Center for Technology Assessment and Friends of the Earth filed a legal petition to force the EPA to stringently enforce FIFRA regulations against all products containing nanosilver, including colloidal silver products, if those products made “pesticidal” claims.


Does Your Favorite Brand of Colloidal Silver Contain Nanosilver and Make “Pesticidal” Claims?


In other words, if your favorite brand of colloidal silver contains tiny nano-sized silver particles (most brands do), and if it is used chiefly for its powerful antimicrobial qualities (most brands are), then according to the environmental groups, your favorite brand of colloidal silver should be interpreted to be a “perticidal” product under FIFRA, and would have to meet the EPA’s stringent regulations for pesticidal products.


What’s more, these extremist environmental groups apparently want the EPA to force nanosilver product manufacturers to remove their products from the market and prove to the EPA that these products cannot “harm the environment” before they can once again be sold to the public.


This of course means colloidal silver manufacturers along with the manufacturers of other products containing nano-sized particles of silver would have to file expensive environmental impact reports with the EPA, costing hundreds of thousands or even millions of dollars.


Backdoor Method of Banning Colloidal Silver


Ever since the environmental groups first filed their legal petition with the EPA in late 2008, many thousands of colloidal silver users have protested to the EPA that the entire scheme smacked of a backdoor method of regulating colloidal silver into oblivion.


After all, few if any colloidal silver manufacturers could afford to comply with the added regulatory burden of having to prove to the EPA that their products won’t “harm the environment.” If the environmentalists had their way, and these types of regulations were instituted, most colloidal silver manufacturers would simply have to quit manufacturing their products.


Of course, forcing colloidal silver manufacturers to prove that their products won’t harm the environment is ludicrous at face value. Why? Because silver comes from the environment in the first place. And secondly, because there is no evidence whatsoever that commercial colloidal silver products have ever caused even a scintilla of harm to the environment.


For these reasons, and many more (including questionable “charitable contributions” to the environmental groups from foundations linked to Big Pharma) colloidal silver manufacturers, vendors and users have been extremely suspicious of EPA’s intentions in classifying nanosilver as a “pesticidal” product under their FIFRA regulations, and of the role of the environmental groups such as Center for Technology Assessment and Friends of the Earth in acting in attempting to force EPA to more stringently regulate products containing nanosilver.


(As an aside, you may remember that only this past June, the environmental group Friends of the Earth issued a white paper calling on the EPA to ban all colloidal silver products.)


Emergency Action Needed Immediately!


The bottom line is that the upcoming November 3-6 meeting of the FIFRA Scientific Advisory Panel represents both crisis and opportunity for colloidal silver manufacturers, vendors and users.


Crisis, in that you can rest assured representatives of the major anti-nanosilver environmental groups will be in attendance, and will be pressing the EPA to adopt their radical anti-silver regulatory agenda.


And a very slim window of opportunity, in that the EPA has once again requested public comments on this critical issue, both in the form of written comments from the public at large, and well as oral comments from those who might be able to attend the FIFRA meeting in Arlington VA.


Written Public Comments Need to Be Submitted Quickly


Let’s deal with the written comments first:


Unfortunately, the EPA has requested that all written comments on this issue be submitted by October 20, 2009. This date has already passed. We were not made aware of it until it was already too late.


However, here’s what the EPA stated regarding written comments in their undated press release announcing the meeting:


“The agency encourages that written comments be submitted by October 20, 2009…”


In other words, it is apparently not a hard-and-fast deadline. Obviously, comments need to get to the EPA well before the FIFRA meeting which starts on November 3 and runs through Nov. 6. So the quicker you act, the more likely your comments will make an impact at the November 3-6 FIFRA meeting.


With that in mind, I strongly urge all colloidal silver users to immediately post a brief comment on the EPA Federal eRulemaking Portal at this web address: http://www.regulations.gov


Simply click on the above link, or type it into your web site address bar. Once the page comes up type the following docket # (i.e., EPA-HQ-OPP-2008-0683) into the bar that says “Enter Keyword or ID”, and then click on “Submit a Comment.”


Once that page comes up, scroll to the bottom right side and look for the “Actions” column. In that column click on the link titled “Submit a Comment.” That should bring up the public comments page, in which you can write and submit your comment.


[If you’re really lucky, you might be able to bypass the above rigamarole and go straight to the public comments page by clicking this link. Sometimes it works, sometimes it doesn’t. The EPA doesn’t make it easy to figure out how to post public comments on their web site. I’m doing the best I can to get you there! -- Spencer]


Once you’ve reached the comments page, in your own words, simply say something to the effect of this:


In regards to docket ID #EPA-HQ-OPP-2009-0683, I respectfully request that you do NOT lump colloidal silver products containing nanosilver in with other commercial nanosilver products you may be considering regulating under FIFRA.


Colloidal silver is an oral nutritional supplement product, and as such is already regulated under the Food & Drug Administration (FDA) regulations.


Despite assertions to the contrary by environmental groups such as Center for Technology Assessment and Friends of the Earth, oral colloidal silver nutritional supplements containing nanosilver have never been demonstrated to pose any threat to the environment whatsoever.


Additional regulation by the EPA of a product already amply regulated by the FDA would be redundant at best. It is also an affront to taxpayers, particularly considering the fact that there is no evidence whatsoever of environmental harm from these nutritional supplement products.


What’s more, regulating colloidal silver products under FIFRA further unnecessarily stretches thin the EPA’s already overburdened regulatory mechanisms.


Please say “No” to regulating colloidal silver nutritional supplement products under FIFRA, and in fact, please take steps to fully exempt colloidal silver nutritional supplement products from FIFRA regulation.


Thank you,

(your name)


If you don’t want to take the time to write it in your own words, simply highlight and copy the above comment and paste it into the comments section on the EPA web site as directed above.


But I strongly suggest you write the letter in your own words. Your comment doesn’t have to be a long one. Just let the EPA know in no uncertain terms that you don’t want the EPA to regulate colloidal silver products under their FIFRA “pesticide” regulations.


[If by the time you get this notice the EPA public comments page for this particular issue is no longer working, simply print out and mail your comment to the following address as quickly as possible: Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001.]


Attending the Meeting and Delivering Oral Comments


If you’re a colloidal silver manufacturer or vendor, or just an articulate advocate of colloidal silver, you might want to consider attending the upcoming November 3-6 meeting of the FIFRA Scientific Advisory Panel to be held in Arlington, VA, and delivering oral comments to the panel.


But be aware: You must request in writing to deliver oral comments at the meeting. And the deadline for requesting to deliver oral comments at the meeting is October 27th.


That gives you less than a week from the date of this blog post to get your request to the EPA.


If you’re interested in doing so, I suggest drafting your request to deliver oral comments immediately, and then post it to the EPA public comments page. Or better still, Federal Express your request to the following EPA address: Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001.


You can always follow up with the EPA representative whose contact information appears directly below in the reproduction of the EPA press release we just received.


The Original EPA Press Release


Directly below I have reproduced the press release from the EPA regarding this meeting. It gives the address to send your written comments to, as well as to send a request to deliver oral comments at the meeting if you can attend in person.


Here it is:


There will be a 4-day consultation meeting of the Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel (FIFRA SAP) to consider and review a set of scientific issues related to the assessment of hazard and exposure associated with nanosilver and other nanometal pesticide products.


DATES: The consultation meeting will be held on November 3 - 6, 2009, from approximately 8:30 a.m. to 5:00 p.m. The consultation meeting will be held at the Environmental Protection Agency, Conference Center, Lobby Level, One Potomac Yard (South Bldg.), 2777 S. Crystal Dr., Arlington, VA 22202.


Comments: The Agency encourages that written comments be submitted by October 20, 2009 and requests for oral comments be submitted by October 27, 2009.


Submit your comments, identified by docket identification (ID) number EPA-HQ-OPP-2009-0683, by one of the following methods:


• Federal eRulemaking Portal: http://www.regulations.gov. Follow the on-line instructions for submitting comments.


• Mail to: Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001.

FOR FURTHER INFORMATION CONTACT: Joseph E. Bailey, DFO, Office of Science Coordination and Policy (7201M), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001; telephone number: (202) 564-2045; fax number: (202) 564-8382; e-mail address: bailey.joseph@epa.gov.


EPA source: http://www.FederalRegister.com


Finally…


The fact that the EPA is apparently moving forward on their agenda to regulate nanosilver products simply heightens my long-time recommendation that every family should own the means of colloidal silver production.


By that, I mean you should own a high-quality colloidal silver generator, such as the new Micro-Particle Colloidal Silver Generator from our good friends at The Silver Edge.


Once you own the means of colloidal silver production, no one can take away your right to use colloidal silver whenever you want to.


What’s more, by owning a high-quality Micro-Particle Colloidal Silver Generator from The Silver Edge, you’ll be able to make all of the high-quality micro-particle colloidal silver you could ever want, for the extraordinarily low cost of about 36 cents a quart.


Yes, I said 36 cents a quart!


Compare that with the $20 to $30 price tag on a tiny 4 ounce bottle of colloidal silver at most health food stores, and you’ll see that with a high-quality Micro-Particle Colloidal Silver Generator from The Silver Edge, you can literally afford to bathe in colloidal silver if you want.


In fact, many Micro-Particle Generator owners report to us that they do just that. Once a week or so, they pour a quart jar of colloidal silver directly into their bathwater, and enjoy the soothing, healing effect colloidal silver has on the skin. After all, when you are only paying 36 cents a quart to make high-quality micro-particle colloidal silver, your uses for this phenomenal healing product are virtually unlimited.


What’s more, the set of pure .999 fine silver wire that comes with your new Micro-Particle Colloidal Silver Generator will allow you to make over $24,000 worth of high-quality micro-particle colloidal silver in the comfort and privacy of your own home!


And you can purchase additional sets of the pure silver wire for only about $25 apiece (each set lasts about a year under normal usage). And yes, each set allows you to make another $24,000 worth of high-quality micro-particle colloidal silver.


I know this all sounds astonishing, to say the least. But every word of it is absolutely true.


Perhaps the best part is that your very first one-quart batch of high-quality micro-particle colloidal silver literally pays for the entire cost of your new Micro-Particle Colloidal Silver Generator, when compared to the price you would have paid for the same amount of colloidal silver in a health food store. Just do the math…it’s absolutely amazing!


So I urge you to pay a visit to The Silver Edge at http://www.thesilveredge.com/ and click through on the links, paying particular attention to the link titled “How to Make High-quality Micro-Particle Colloidal Silver for Less Than 36 Cents a Quart!” and the link titled “Make $24,000 Worth of Colloidal Silver from a $20 Set of Silver Wire.”


See for yourself that what I’m telling you is true.


Then, order a high-quality Micro-Particle Colloidal Silver Generator from The Silver Edge, before the environmental groups and the EPA finally have their way, and begin regulating commercial colloidal silver products into oblivion.


Once you own the means of colloidal silver production, you’ll be able to make all of the colloidal silver you could ever want, any time you want, in the comfort and privacy of your own home. And the good news is, as long as you act before they institute new regulations, there’s not a thing the environmentalists or the bureaucrats can do about it.


Helpful Links:


Make your own high-quality colloidal silver:

http://www.thesilveredge.com/


Learn more about colloidal silver:

http://www.lifeandhealthresearchgroup.com/


The Colloidal Silver Secrets Video:

http://www.ColloidalSilverSecretsVideo.com


The Ultimate Colloidal Silver Manual:

http://www.ultimatecolloidalsilvermanual.com/


Colloidal Silver Cures MRSA:

http://www.colloidalsilvercuresmrsa.com/


Colloidal Silver Kills Viruses:

http://www.colloidalsilverkillsviruses.com/


The New Micro-Particle Colloidal Silver Generator:

http://www.microparticlegenerator.com/


The Colloidal Silver Secrets blog:

http://www.colloidalsilversecrets.blogspot.com/


The Secrets of Natural Healing blog:

http://www.secretsofnaturalhealing.blogspot.com/

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