Meeting of the National Organics Standards Board (Docket No. AMS-TM-09-0014)
Michael Hansen, Ph.D.
April 20, 2009
Consumers Union (CU) would like to provide the following comments to the six questions posed by the Materials Committee of NOSB on nanotechnology:
1. As currently understood, is Nanotechnology compatible with organic?
It all depends on what one means by nanotechnology, although in general the answer is no. A simple definition of nanotechnology is “the study of the control of matter at the atomic and molecular scale.” Nanotechnology has also been defined as the “design, characterization, production and application of functional materials, structures, devices and systems based on nanoparticles.” In general, nanotechnology refers to nanoparticles and nanostructures that have one or more dimensions at the scale of 100 nanometers or less (often people say nanoparticles are in the range of 1 – 100 nm). While nanoparticles and nanomaterials can occur naturally—as the result of combustion or in colloidal solutions (such as milk)—the vast majority of interest in the field of nanotechnology is about constructing or synthesizing nanoparticles and nanomaterials. Thus, engineered nanomaterials (ENM) can be defined as: discrete materials having structures with at least one dimension between 1 and 100 nanometers and that are intentionally created, as opposed to those that are naturally or incidentally found . Some research has shown that the potential adverse effects associated with nanoparticles can be see at sizes above 100 nanometers and some have called for the cut off to be particles smaller than 300 nanometers . Clearly, ENMs should be excluded as a synthetic or prohibited substance. In addition, since nanotechnology as popularly understood is about the production and synthesis of compounds at the atomic and molecular scale, it should be an excluded method. Part of the great interest in nanotechnology comes from the fact that at the nanometer level, a substance can behave very differently and have different properties than at the macrolevel. It is precisely this fact—that nanomaterials can have unique properties at the nanoscale that cannot be predicted by their properties at the macroscale—which should make it an excluded methos.
For complete comments, go to: http://www.consumersunion.org/pdf/nanotechnology-comments-4-20-09.pdf