Rachel's Democracy & Health News #855, May 18, 2006
[Rachel's introduction: Eight public interest groups are forcing the Food and Drug Administration (FDA) to confront the reality that nanotechnology creates products that may be useful but may also be quite dangerous. Up to now, the FDA has kept its head in the sand on this issue, pretending there's no problem. Time for a major showdown.]
By Tim Montague
Just in time for summer, a group of eight environmental and public interest groups have petitioned the U.S. Food and Drug Administration (FDA) to recall nanotech sunscreens from supermarket shelves. This will force FDA to finally decide whether nano particles are something radically new or not.
Nano particles are named for their small size (a nanometer is a billionth of a meter), and nano particles are smaller than anything humans have ever put into commercial products before. Their tiny size changes their characteristics completely. If they didn't represent something new, they wouldn't have the commercial world excited. At present something like a goldrush mentality surrounds nanotech.
Friends of the Earth, Greenpeace and the International Center for Technology Assessment on May 17 demanded of FDA "that nanoparticles be treated as new substances; nanomaterials be subjected to nano-specific paradigms of health and safety testing; and that nanomaterial products be labeled to delineate all nanoparticle ingredients." In other words, they are asking the FDA to wake up to the consensus of respected scientific bodies like the British Royal Society who concluded in their 2004 report that nano particles are different from anything humans have ever created before and that we need to take a precautionary approach.
The petition to FDA says, "Engineered nanoparticles have fundamentally different properties from their bulk material counterparts -- properties that also create unique human health and environmental risks -- which necessitate new health and safety testing paradigms." And this is confirmed by scientists like Gunter Oberdorster who has written text books on the subject and a recent review of 'nanotoxicology'. Until now, FDA (like U.S. Environmental Protection Agency and the Occupational Safety and Health Administration) have remained oblivious to all nanotech health risks. Their position is that carbon is carbon regardless of the size of its particles, zinc is zinc, and titanium is titanium. Size does not matter, says FDA.
But every physicist knows that size matters a great deal. The smaller an object is, the larger its surface is in relation to its volume. Thus nano particles have an enormous surface to volume ratio, which renders them biologically active. Oberdorster says, "This increased biologic activity can be either positive and desirable (e.g., antioxidant activity, carrier capacity for therapeutics, penetration of cellular barriers for drug delivery) or negative and undesirable (e.g., toxicity, induction of oxidative stress or of cellular dysfunction), or a mix of both."
Now public interest organizations are asking the FDA to "Declare all currently available sunscreen drug products containing engineered nanoparticles of zinc oxide and titanium dioxide as an imminent hazard to public health." The petition (2.8 MB) and a related report (4 MB) by Friends of the Earth (FOE) expose the dark underbelly of the health and beauty industry that has joined the nanotech gold rush without much thought for the short or long term consequences to nature or human health. But how could they? The structure of the modern corporation doesn't allow for ethical perspectives or precautionary action if they might significantly limit the bottom line.
Next time you (or your kids) want to slather up with your favorite sunblock, remember that the active ingredient in the sunscreen -- typically zinc oxide and/or titanium dioxide -- could very well be a nanomaterial. There are now hundreds of sunscreens, moisturizers, cosmetics and other personal care products containing sub-microscopic materials that we simply don't understand. And because the FDA doesn't require labeling, consumers are left in the dark -- a vast experiment with only one winner, and that isn't you or me.
We aren't talking about the same zinc oxide that you knew as a youth on lifeguard's noses. Nanoscale engineered materials (smaller than 100 nanometers in diameter -- iron, aluminum, zinc, carbon, and many others) are measured in billionths of a meter. A human hair is 80,000 nanometers wide. A strand of DNA is 3.5 nm across. The nanoworld is quite a different place -- a world where particles can pass directly from the environment into your bloodstream, tissues, cells and organelles. The nano revolution has burst upon us for just that reason -- nanomaterials take on new and unique properties that make them attractive as drug delivery vehicles, chemical sponges and nano-robot ("nanobot") building blocks.
There are three typical ways in which nanomaterials get into our bodies -- we breath them, ingest them or absorb them through our skin. And despite the evidence that nanomaterials cause lung, liver and brain damage in animals, our Food and Drug Administration (FDA) is treating nanomaterials like their standard or bulk sized counterparts of yesteryear.
In March, 2006, Jennifer Sass of the Natural Resources Defense Council (NRDC) summarized the state of regulatory affairs for nanotechnology thus: "The Toxic Substances Control Act is the most obvious law for regulating nanomaterials. But the law does not require manufacturers to provide safety data before registering a chemical, instead placing the burden on the government to demonstrate that a substance is harmful. If the government does not follow up on potential risks with a new product application within several months, the company can proceed to sell its product. Other laws on the books also are inadequate. The Food, Drug and Cosmetic Act [giving FDA regulatory power] includes only feeble safeguards for cosmetics, which already promise to be a major use of nanomaterials. Likewise, the poorly enforced Occupational Safety and Health Act fails to address nano- specific worker protections."
As we reported in Rachel's #816, the British Royal Society (approximately the equivalent of our National Academy of Sciences) issued a report in July 2004 recommending a series of precautionary actions based on their review of the scientific literature on the possible health effects of nanomaterials:
** "The evidence we have reviewed suggests that some manufactured nanoparticles and nanotubes are likely to be more toxic per unit mass than particles of the same chemicals at larger size and will therefore present a greater hazard."
** "There is virtually no evidence available to allow the potential environmental impacts of nanoparticles and nanotubes to be evaluated."
** Therefore, "the release of nanoparticles to the environment [should be] minimized until these uncertainties are reduced."
** And, "until there is evidence to the contrary, factories and research laboratories should treat manufactured nanoparticles and nanotubes as if they were hazardous and seek to reduce them as far as possible from waste streams."
At the heart of the health and safety concerns is the tendency for nanoparticles like fullerenes, nanotubes, and nanoparticle metal oxides to produce free radicals -- charged atoms that are highly reactive and which can cause oxidative stress, inflammation, and subsequent damage to cells and tissue. A recent study by Duke University found that fullerenes (Buckyballs) cause brain damage in large mouth bass.
The FOE report says "Because of their size, nanoparticles are more readily taken up by the human body than larger sized particles and are able to cross biological membranes and access cells, tissues and organs that larger sized particles normally cannot." Once in the blood stream, nanomaterials can affect all of the organs and tissues of the body including the bone marrow, heart, lungs, brain, liver, spleen and kidneys. But little is known about what dose may cause harmful effects or how long different nanomaterials remain in various tissues.
It is known that nanoparticles can inhibit the growth of and kill kidney cells. At the cellular level, unlike larger particles, nanomaterials can pass into organelles like the mitochondria -- the power plant of the cell -- and cell nucleus where they can cause DNA mutation and cell death.[1 p. 7]
Nanoparticles of titanium dioxide and zinc oxide -- widely used in sunscreens and cosmetics -- are photo active, "producing free radicals and causing DNA damage to human skin cells when exposed to UV light."[1 p.7] Although there is conflicting data on just how much nanoparticles can actually penetrate human skin and enter our blood, there is no doubt that what we put on our skin will end up in our air, food, and water. A recent report in Environmental Science & Technology found fish throughout Europe are contaminated with UV- filter-chemicals -- from sunscreen -- (4-methylbenzylidene camphor or 4-MBC; and octocrylene or OC) which are known hormone disruptors. What we rub on our bodies washes into the lakes and rivers, and then gets into the food chain.
Even nanotech industry professionals themselves are skeptical about the safety of these materials. Speaking about the incorporation of fullerenes into skin-care products, Professor Robert Curl Jr. -- who shared the 1996 Nobel Prize in Chemistry for his co-discovery of fullerenes -- expressed concern: "I would take the conservative path of avoiding using such cosmetics while withholding judgment on the actual merits or demerits of their use."
And when a scientist at an international nanotoxicology meeting asked 200 of her colleagues whether they would feel comfortable using face cream that contained fullerenes, fewer than ten indicated that they would.[1 p.8]
The scientists who specialize in nano materials don't trust the stuff, yet thousands of workers and consumers are being exposed every day in the manufacture, transport and application of skin care and many other products from tires to computer hard drives and skis.
There is very little known about current levels of workplace exposure. The US National Science Foundation estimates that by 2015 2 million workers worldwide will be directly employed in nanotechnology industries. This means the total number of exposed workers will certainly be much larger.[1 p. 10]
While the evidence continues to pile up that nanomaterials pose significant health risks to consumers and workers, the federal bureaucracy turns a blind eye concerned mostly with fostering economic growth at all cost. Of the "$1.3 billion budget for the US National Nanotechnology Initiative, only $38.5 million (less than 4%) was earmarked for the study of the health, safety and environmental impacts of nanotechnology. Conversely, the US Department of Defense received $436 million (33.5% of the nanotechnology budget)." We are spending more than ten times as much on nanotech warfare technology as we are investing on basic health and safety research.
By their nature, corporations cannot regulate themselves -- by law they are only allowed to do one thing: return a decent profit to investors using every legal means available. But judging from the chemical, nuclear and biotechnology industries, government is not up to the task of regulating corporations to protect human health. So, while our tax dollars are doing relatively little to bring health and safety research into the public domain, corporations are ploughing forward, constrained only by consumer tastes and trends. We don't want a visible white paste on our bodies (nanomaterials help the sunscreen disappear fast), therefore we must want nanotech.
Now public health advocates are calling for a "moratorium on the commercialization of nanoproducts until the necessary safety research has been conducted." And they specifically call on a precautionary approach which shifts the burden of proof onto industry to demonstrate product safety, calls for product labeling and transparent peer- reviewed health and safety studies that become part of the public domain.
In March 2006 the EPA issued 'voluntary' reporting guidelines (you've heard this one before) which give no incentive to industry to invest in product safety research much less reveal what little they may actually know about the health effects of their nano-products. Time and time again -- remember tobacco, asbestos, and lead? -- the profit motive will always drive corporations to release products into the market (our air, food, water and soil) even if they know the product is dangerous to human health and the environment.
As reported in Rachel's #816, the insurance industry is deeply concerned about the environmental and health effects of these largely untested technologies. They understand that nanomaterials could be the next asbestos liability debacle. It would be interesting to see a full cost accounting (see Rachel's #765) of the potential benefits and costs not only to industry but to the public that currently shoulders the burden of proof with their tax dollars, endangered health and degraded environment.
As the pharmaceutical industry has demonstrated -- operating within a precautionary framework -- a better safe than sorry approach can work for investors and consumers alike. Big pharma has been hugely succesful under a system that demands precautionary pre-market testing -- so successful that it's now under constant attack for using its financial influence to corrupt the regulatory system. When industry and the current regulatory agencies tell us they fear a precautionary approach will 'stifle innovation', they really don't have a leg to stand on.
In the meantime, I'll be heading for the fantasy nano-free section of my supermarket for some non-nano sunscreen.
 Nanomaterials, sunscreens and cosmetics: small ingredients big risks. Friends of the Earth, Washington, D.C. May 17, 2006 available here and at www.foe.org