But the Environmental
Protection Agency (EPA) has thrown roadblock after roadblock into the paths of
companies willing to meet the growing public demand for products that utilize
antimicrobial silver, even to the point of stringently enforcing their strange categorization
of antimicrobial silver as a “pesticide,” and imposing mounds of new
regulations (which we’ll look at in this article) making it more difficult for
companies to bring such products to market.
Worse yet, whenever
a company agrees to jump through the EPA’s regulatory hoops in order to
manufacture a product containing antimicrobial silver, litigious environmental
groups emerge out of the woodwork to file lawsuits against the EPA in order to
prevent the agency from allowing the product to be manufactured and sold to the
American public.
Here’s why
the future of consumer products containing antimicrobial silver is now so bleak,
in spite of massive public demand for such products…
Hi,
Steve Barwick here, for www.TheSilverEdge.com...
A
little more than a decade ago consumers were thrilled to find that common
household products such as computer keyboards, kitchen cutting boards, plastic
food containers or even bathroom towels could be infused with antimicrobial
silver in order to help reduce the spread of pathogens and prevent infections
and disease.
I
was among the first to report on the emergence of such products back in 2000,
in my article, Big Business Moves Into Silver-Based
Antimicrobial Products In a BIG Way, which has since been read by millions
of people worldwide.
However,
about six years after businesses began producing consumer products containing
antimicrobial silver, radical environmental groups sued the EPA, demanding they
more broadly enforce their classification of antimicrobial silver as a
"pesticide" under the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA).
These
environmentalist groups -- some of which have apparently been taking millions
of dollars in “contributions” from charitable foundations set up by Big Pharma -- asserted without any real-life evidence whatsoever
that silver could leach from such products and potentially harm little critters
in the environment.
“Killing the
Planet”
They
sensationalistically claimed in press release after press release, and in
articles planted on dozens of environmentalist news websites, that the use of
silver in consumer products was an “environmental catastrophe waiting to
happen” and would end up “killing the planet.”
They
further asserted that the EPA would be to blame for the impending doomsday
crisis if it didn’t act quickly to ban the use of antimicrobial silver in
consumer products. And using these overblown theatric and sensationalistic tabloid-style
claims, they rallied their legions of unwitting environmentalist members
against the use of antimicrobial silver.
The
EPA, in turn, claimed it was being “forced by public opinion” to more
stringently regulate consumer products containing antimicrobial silver, even to
the point of categorizing products like silver-infused computer keyboards,
plastic food containers or kitchen cutting boards as “pesticides.”
Because
of this, fewer and fewer such silver-based products have been brought to market
because the newly imposed regulatory burdens have become so egregious and
costly, companies are discovering it’s simply not worth the time, money or the
effort to invest in them, in spite of the growing public demand.
Huge Fines
Indeed,
as I’ve pointed out in previous articles, the EPA is now fining companies hundreds of thousands of dollars simply
for failing to register their products as “pesticides” if they contain
antimicrobial silver and advertise its benefits.
Only recently, the EPA fined a company called IOGEAR a whopping $208,000.00 for selling a silver-impregnated computer mouse and failing to properly register it as a “pesticide” with the agency.
Then the EPA fined a company called Kinetic Solutions, Inc., $82,400 for selling an unregistered air purifier which contained a pre-filter incorporating nanosilver into its makeup.
The EPA also fined Samsung Corp. $205,000 for selling a computer keyboard infused with silver nanoparticles.
What’s more, according to news reports, when faced with up to $1 million in fines from the EPA, a retail company called The North Face was forced to stop making claims that its nanosilver footwear products protect against germs.
And finally, the EPA leveled a whopping $206,000 fine against the famous computer peripherals company, Logitech, Inc., for incorporating nanosilver into its computer keyboards without registering it with the EPA as a “pesticide” product!
Do
you understand now why all of those wonderful consumer products infused with
antimicrobial silver are slowly disappearing from the marketplace?
Regulatory
Nightmare…
Last
year, the EPA mandated which types of studies and tests would have to be conducted
by companies wanting to manufacture products containing antimicrobial
silver.
Here’s
just a partial list of these studies and
tests a company must perform, including a staggering array of toxicity tests such
as fish toxicity, bird toxicity, algal toxicity, human toxicity, inhalation
toxicity, dermal toxicity, repeated dose toxicity, environmental toxicity,
genetic toxicity as well as “environmental fate” toxicity tests and a host of
other tests:
Tier
1 Data Requirements Product Chemistry
830.1550
Product
Identity and Composition. Topology of the nanocomposite needs to be fully described.
Information on the binding and distribution of nanosilver in the matrix
(uniform or heterogeneous).
830.1750
Certified
Limits.
Data are needed on the upper and lower limits for the nanosilver present.
830.1800
Enforcement
Method.
Analytical method needs to include high resolution images of the active.
830.6313
Stability
to Normal and Elevated Temperatures, Metals, and Metal Ions. Methods
also need to include test of stability to sunlight, detergents, and salinity.
830.6317
Storage
Stability.
Storage Stability studies were submitted using accelerated method. EPA requires
one-year study at ambient temperature.
830.6320
Corrosion
Characteristics. See Storage Stability above.
830.7050
UV-Visible
Light Adsorption. UV/visible spectrum of nano-material. This study is a reliable
identification method for nanoproducts and one that the SAP recommended.
830.7520
Particle
Size, Fiber Length, and Diameter (size) Distribution. Data
required to characterize adequately the size distribution of the nanoproduct
composite and the nanosilver particles in the composite.
830.7840
Water
Solubility:
Column Elution Method; Shake Flask Method is needed at pH 5, 7, and 9.
NoGuideline
Surface
Area Determination. Data required to characterize adequately the size distribution
of the nanoproduct composite and the nanosilver particles in the composite.
Environmental
Fate
No Guideline
Dissolution
Kinetics Study. This is a fundamental study on the persistence of the
nanoparticle in the environment and the extent of silver ion or nanoparticle
release. This test will dictate the test substance to be used for the Tier 2
other studies.
Environmental
Effects
850.1010
Acute
Toxicity Freshwater Invertebrates
850.1075
Freshwater
Fish Toxicity
850.2100
Avian
Oral Toxicity
850.5400
Algal
Toxicity,
Tier 2 The proposed use of the conditionally registered nanosilver product
could lead to surface water contamination that could impact fish,
invertebrates, avian, and algal communities. The above studies will address
concerns regarding the potential risks of the nanosilver compound and will
provide toxicity endpoints applicable to ecological risk assessment.
Human
Exposure
875.1200
875.1400
Applicator,
Indoor Exposure. These studies provide information useful for evaluating the
form, route, and level of exposure experienced by workers who handle the
nanosilver compound in the process of treating textiles. The exposure data are
used in conjunction with the toxicology endpoints to assess the risk to
applicators.
No Guideline
Textile
Leaching Study. A leaching study is needed to determine what, if any, materials
are released from the nanosilver treated textiles under conditions of use. This
study should be done in the manner of Geranio et al. [no reference given] with
the addition of electron microscopy to characterize the particulate.
Toxicology
870.3465
90-Day
Inhalation Toxicity (Rat). This is a conditional required study triggered by the potential
for inhalation exposure to the nanosilver based upon its formulation as a
powder and is use in textiles.
870.3200
21-Day
Dermal Toxicity (Rat). This is a conditional required study triggered by the potential
for dermal exposure to the nanosilver based upon its formulation as a powder
and its use in textiles. Consumer dermal exposures could occur while wearing
treated clothing.
870.3650
Combined
Repeat Dose Toxicity Study with Reproduction/Developmental Toxicity Screening
Test.
This is a conditional required study triggered by the potential for incidental
oral exposure to the nanosilver based upon its use in textiles.
870.5100
870.5300
870.5375
870.5385
870.5395
Genetic
Toxicity Tests. Genetic toxicity tests are used to screen chemicals for mutagenic
or carcinogenic potential. The data from these tests will be used to determine
if the nanosilver product is a potential mutagen or carcinogen.
Tier
2 Requirements
Tier 2 data are required if the nanoparticles are released during
the Tier1 stability, dissolution, or leaching studies. Tier 2 data requirements
are the same as above for all disciplines except for the environmental fate
studies listed below. The testing for Tier 2 should be carried out with the
material(s) that are released from the nanosilver composite.
Environmental
Fate
850.1730
Fish
Bioaccumulation Factor. Bioconcentration studies will assess the potential that the test
substance will accumulate in fish and therefore its potential to impact the
food chain.
835.1230
Adsorption/Desorption
(Batch Equilibrium). EPA is requesting adsorption/desorption equilibrium studies to be
conducted with the nanosilver. This information will be used to assess the
sorption of a test material on soil/sediment and to estimate exposure.
No Guideline
MITI
Glucose.
The purpose of the study is to assess the impact of nanosilver or its
constituents on microbial activity in waste water treatment.
Are
you boggled by the regulatory morass companies have to navigate in order to
bring a product to market containing antimicrobial silver?
You
can bet the companies that would like to meet the consumer demand for such products
are boggled, also -- so much so, in fact, that the numbers of new consumer products
being produced with antimicrobial silver have now literally slowed to a trickle
in the United States. And the same thing
is happening in other countries, as well.
The HeiQ
Story:
A Cautionary
Tale
Here’s an eye-opening example of the kind of nonsense companies have to go through in order to market a consumer product containing antimicrobial silver in the United States.
You’ll
be stunned to see that while such companies have to risk millions of dollars in
the process, they have no guarantees their product will ever be allowed on the
market even if they agree to comply with
every regulatory hurdle.
Several
years back, a Swiss company named HeiQ petitioned the EPA to allow them to market
consumer products containing antimicrobial silver in the U.S. These products apparently
included textiles such as sheets, blankets, towels, napkins, sportswear,
sleepwear, undergarments, socks and hosiery.
After
several year’s worth of negotiation, the EPA finally issued HeiQ a conditional
permit to sell their products. But it
was strictly limited to four years. In return, HeiQ had to agree to perform the
required studies during the four year conditional period, and report the
results to the EPA as each study was completed.
The
EPA apparently felt this would give them invaluable information on the
environmental impact of consumer products containing antimicrobial silver. And HeiQ felt this would allow them to
demonstrate conclusively -- under real-world
conditions -- that consumer products containing antimicrobial silver are no
threat to the environment.
Of
course, such testing is extremely expensive, in some cases costing hundreds of
thousands or even millions of dollars to complete. And it all has to be done to
strict EPA specifications and standards, or the tests results are simply
rejected out-of-hand.
As
you can imagine, not many companies have the financial wherewithal to complete
such an astonishing battery of tests on their products. But HeiQ agreed, even though they knew that
at the end of the four year conditional period, they could end up losing all of
the money they’d invested on testing, plus potentially millions of dollars more
in product development, manufacturing and marketing costs.
They
apparently felt the risk would be worth it, if they could demonstrate conclusively,
once and for all time, that consumer products imbued with nanosilver were
environmentally safe.
Triggering
the Ire of Environmental Groups
But
when the EPA finally issued HeiQ a conditional permit to manufacture products
infused with antimicrobial silver, it triggered the ire of anti-silver
environmentalists groups who saw the EPA’s permit approval as a betrayal of their
efforts to ban the sale of consumer products containing antimicrobial
silver.
That’s right. It didn’t matter to the radical, anti-silver environmentalists that HeiQ was willing to complete all of those toxicology tests and demonstrate there would be no appreciable harm to the environment from their consumer products containing antimicrobial silver.
That’s right. It didn’t matter to the radical, anti-silver environmentalists that HeiQ was willing to complete all of those toxicology tests and demonstrate there would be no appreciable harm to the environment from their consumer products containing antimicrobial silver.
And
it didn’t matter that HeiQ had agreed to conduct and complete the testing at
its own expense during the four years of its conditional permit.
Nope. The environmental groups simply acted in typical,
sensationalistic knee-jerk fashion and sued
the EPA for granting HeiQ the permit claiming essentially that the EPA had
acted in reckless disregard for public safety in granting the permit!
Indeed,
on January 26, 2012, the Natural Resources Defense Council (NRDC) filed suit
against the Environmental Protection Agency (EPA) over the HeiQ permit.
The
NRDC is known as one of the country’s largest environmental lobbying and
litigating groups – which means if they can’t force their agenda on you
politically, they’ll happily sue the daylights out of you, instead.
According
to news reports, this radical anti-silver group insists that HeiQ should have
to conduct all of the required studies and tests without ever manufacturing a single product containing antimicrobial
silver. This of course, is a physical impossibility. You can’t test the
potential environmental impact of a product that doesn’t exist.
Even
the EPA, not always known for being reasonable, had ruled that the marketing and
sales of the HeiQ consumer products containing antimicrobial silver would pose “no
unreasonable adverse health or environmental effects” in such a short time.
And
this is true, of course, particularly considering the fact that antimicrobial
silver has already been used commercially for over 120
years
and to date has never caused a single serious environmental concern.
But
the enviro-litigators in the Natural Resources Defense Council saw it
otherwise. They claim the EPA must
consider the HeiQ products to be dangerous “pesticides” right from the get-go, without any evidence, and disallow their
sales.
And
now years of litigation must go by before HeiQ will ever know whether or not it
can finally begin to manufacture and sell its products here in the U.S., and
conduct the necessary regulatory testing.
Regulatory
Hell
After
seeing this, how many other companies do you think will attempt to meet the growing
consumer demand for products containing antimicrobial silver? The likelihood is: None.
Why: Regulatory hell. After all, the risks are just too great. Companies like this have to spend millions of dollars on product
development and manufacturing. Then they
have to spend hundreds of thousands or even millions more to meet the costs of the regulatory requirements.
And
after all of that, there’s no way for them to know whether or not, at the whim
of some lawsuit-happy environmental group or some faceless environmental
bureaucrat, they’ll lose every penny of their investment and never be able to
recoup their substantial costs.
The risk-costs of doing business under such an egregiously contentious anti-business environment are just too high, and the environmentalists know it.
The risk-costs of doing business under such an egregiously contentious anti-business environment are just too high, and the environmentalists know it.
They
don’t really want to know whether or
not antimicrobial silver will harm the environment. They simply want to make sure it is so
financially risky to bring consumer products that utilize antimicrobial silver
to market that no company will even attempt it.
And
that, my friends, is exactly how the
environmentalists have destroyed the market for antimicrobial silver, and
deprived consumers of its powerful, infection-fighting protection.
The Plain Truth,
Left Untold…
Of
course, what the environmentalists always fail to mention when they
sensationalistically claim that antimicrobial silver is “threat to the
environment” is that silver came from the
environment in the first place.
And
more importantly, they fail to mention that the world is already awash in
natural trace silver without any harm whatsoever to the environment or to the
ecology.
In
fact, the oceans alone contain millions of tons
of natural trace silver, and have for millions of years. Yet they’re teaming with life from the
smallest microbe to the biggest whale.
What’s
more, the lakes and streams of the world contain tons of natural trace silver,
yet they too are teaming with life. Indeed,
the very ground you walk on contains tons of natural trace silver, yet it is abundantly
rich in microbial life as well as numerous other forms of life.
You see, in nature, silver tends to bond rapidly with other natural substances, such as biological silica, salts, sulfur and other common minerals that in turn neutralize its powerful antimicrobial qualities.
You see, in nature, silver tends to bond rapidly with other natural substances, such as biological silica, salts, sulfur and other common minerals that in turn neutralize its powerful antimicrobial qualities.
So
the entire idea that adding a little bit of nanosilver to a computer keyboard or
kitchen cutting board or plastic food container to keep germs from growing on
it will "harm the environment" is ludicrous at face value.
But
the truth be damned, because once the environmentalists get their hands around
a thing, they simply won't let go of it.
While They’re
Still Legal…
In
this age of strange diseases, widespread infections and antibiotic-resistant
super-pathogens, I hope you’ll consider the many dramatic and potentially
life-saving benefits of making your own high-quality colloidal silver with a
new Micro-Particle
Colloidal Silver Generator.
By
putting the means of colloidal silver production into your own hands, you guarantee yourself access to this
remarkable natural infection-fighting agent for life – no matter what the
environmentalists do. But you must act quickly and decisively
while these little machines are still legal to sell.
After
all, it won’t be long before the environmentalists turn their sites on them,
too. Learn more about the powerful
antimicrobial qualities of colloidal
silver
by clicking the link.
Yours for the
safe, sane and responsible use of colloidal
silver,
Steve
Barwick, author
The Ultimate Colloidal Silver Manual
The Ultimate Colloidal Silver Manual
Helpful Links:
Important Note and
Disclaimer: The contents of this Ezine have not been
evaluated by the Food and Drug Administration.
Information conveyed herein is from sources deemed to be accurate and
reliable, but no guarantee can be made in regards to the accuracy and
reliability thereof. The author, Steve
Barwick, is a natural health journalist with over 30 years of experience
writing professionally about natural health topics. He is not
a doctor. Therefore, nothing stated in
this Ezine should be construed as prescriptive in nature, nor is any part of
this Ezine meant to be considered a substitute for professional medical
advice. Nothing reported herein is
intended to diagnose, treat, cure or prevent any disease. The author is simply reporting in
journalistic fashion what he has learned during the past 17 years of
journalistic research into colloidal silver and its usage. Therefore, the information and data presented
should be considered for informational purposes only, and approached with
caution. Readers should verify for
themselves, and to their own satisfaction, from other knowledgeable sources
such as their doctor, the accuracy and reliability of all reports, ideas,
conclusions, comments and opinions stated herein. All important health care decisions should be
made under the guidance and direction of a legitimate, knowledgeable and
experienced health care professional.
Readers are solely responsible for their choices. The author and publisher disclaim responsibility
or liability for any loss or hardship that may be incurred as a result of the
use or application of any information included in this Ezine.
Copyright
2012 | Life & Health Research Group, LLC | PO Box 1239 | Peoria AZ
85380-1239 | All rights reserved
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