Nanosilver is not a new material. The assumption of nanosilver being a new material with fears of
new properties and new unknown hazards is at the heart of both regulatory and many popular
perceptions about nanosilver. However, contrary to assumptions of newness, nanosilver materials
are old and have been well known throughout the ages. Indeed, nanosilver has been rationally
manufactured and used commercially for over a century.
Many different terminologies have been used throughout scientific history to describe ultrasmall
silver particles including "colloidal silver", "millimicron silver" and among other terms the
current "nanosilver" terminology. Accordingly, while the term “nanosilver” is new, the
technology it represents is not.
The SNWG provided the SAP meeting with a detailed historical and technical analysis that
demonstrated that these materials have a long established commercial history as engineered
particles of nanoscale size.¹ Despite changes in terminology, the underlying material being
described is in fact the same that has been used for decades. i.e. nanoscale silver.
EPA has a long history of safely regulating nanosilver
The EPA has been safely and successfully regulating nanosilver products for decades. These
products have been used in a wide range of consumer applications such as swimming pool
treatments and drinking water filters with an established record under FIFRA of regulated and
safe use dating as far back as the 1950’s.
A detailed look at the depth of history of silver within the EPA shows that the toxicological
studies that form the basis of the EPA’s general hazard limits for silver derive from historical data
from nanoscale silver materials and not ‘conventional (bulk) silver’ as is often mistakenly
A careful examination of the EPA public registration database (NPIRS Public) for silver over a period of 6
The very first registered silver product was a colloidal nanosilver algaecide product that has been safely used by millions of consumers for over 50 years (registered since 1954).
Every EPA silver registration between 1970 and 1990 was either a colloidal nanosilver or nanosilver-composite product.
The very first NON-nanosilver product registered by EPA was not registered until 1994.
An overall analysis reveals that today over 50% of all EPA registered silver products are in fact based on nanoscale silver.
EPA has a range of existing regulatory structures that have successfully addressed silver materials
across the size spectrum for over 5 decades. Throughout this period, the EPA has not recorded
any incidents of significance on the Agency’s formal incident reporting database (EPA OPP IDS)
– indicating that thorough monitoring of real-life use supports the safety of these products.
The EPA should be congratulated for this record of successful monitoring and risk management
for these materials despite different terminologies being used throughout this period of time.
Indeed, given that with nanosilver there is perhaps more historical data and evidence of safe use
than for many other regulated materials, EPA has the opportunity to assess nanosilver products
with confidence given this long history of safe use under existing EPA regulations.
The following themes are vital for consideration of an informed regulatory approach:
Nanosilver is NOT a new material - EPA needs to look beyond general conceptions of nano
terminology and consider the broader established regulatory record of nanoscale silver products
within the Agency.
Nanosilvers have seen decades of safe use in real-life - Given the long history of safe use for
EPA-registered nanoscale silver products (stretching back as far as 1954) calls for treatment of
nanosilver as a new material requiring development of expensive new test regimes and
discriminatory regulatory consideration are difficult to justify.
Source: Silver Nanotechnology Working Group, Dr. Rosalind Volpe
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