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Report to the Chairman, Committee on Environment and Public Works, 
U.S. Senate: 

United States Government Accountability Office: 
GAO: 

May 2010: 

Nanotechnology: 

Nanomaterials Are Widely Used in Commerce, but EPA Faces Challenges in 
Regulating Risk: 

GAO-10-549: 

GAO Highlights: 

Highlights of GAO-10-549, a report to Chairman, Committee on 
Environment and Public Works, U.S. Senate. 

Why GAO Did This Study: 

Nanotechnology involves the ability to control matter at the scale of 
a nanometer—one billionth of a meter. The world market for products 
that contain nanomaterials is expected to reach $2.6 trillion by 2015. 
In this context, GAO (1) identified examples of current and potential 
uses of nanomaterials, (2) determined what is known about the 
potential human health and environmental risks from nanomaterials, (3) 
assessed actions EPA has taken to better understand and regulate the 
risks posed by nanomaterials as well as its authorities to do so, and 
(4) identified approaches that other selected national authorities and 
actions U.S. states have taken to address the potential risks 
associated with nanomaterials. GAO analyzed selected laws and 
regulations, reviewed information on EPA’s Nanoscale Materials 
Stewardship Program, and consulted with EPA officials and legal 
experts to obtain their perspectives on EPA’s authorities to regulate 
nanomaterials. 

What GAO Found: 

Companies around the world are currently harnessing the properties of 
nanomaterials for use in products across a number of sectors and are 
expected to continue to find new uses for these materials. GAO 
identified a variety of products that currently incorporate 
nanomaterials already available in commerce across the following eight 
sectors: automotive; defense and aerospace; electronics and computers; 
energy and environment; food and agriculture; housing and 
construction; medical and pharmaceutical; and personal care, cosmetics 
and other consumer products. Within each of these sectors, GAO also 
identified a wide variety of other uses that are currently under 
development and are expected to be available in the future. 

The extent to which nanomaterials present a risk to human health and 
the environment depends on a combination of the toxicity of specific 
nanomaterials and the route and level of exposure to these materials. 
Although the body of research related to nanomaterials is growing, the 
current understanding of the risks posed by these materials is 
limited. This is because the manner in which some studies have been 
conducted does not allow for valid comparisons with newer studies or 
because there has been a greater focus on certain nanomaterials and 
not others. Moreover, the ability to conduct necessary research on the 
toxicity and risks of nanomaterials may be further hampered by the 
lack of tools to conduct such studies and the lack of models to 
predict the characteristics of nanomaterials. 

EPA has undertaken a multipronged approach to understanding and 
regulating the risks of nanomaterials, including conducting research 
and implementing a voluntary data collection program. Furthermore, 
under its existing statutory framework, EPA has regulated some 
nanomaterials but not others. Although EPA is planning to issue 
additional regulations later this year, these changes have not yet 
gone into effect and products may be entering the market without EPA 
review of all available information on their potential risk. Moreover, 
EPA faces challenges in effectively regulating nanomaterials that may 
be released in air, water, and waste because it lacks the technology 
to monitor and characterize these materials or the statutes include 
volume based regulatory thresholds that may be too high for 
effectively regulating the production and disposal of nanomaterials. 

Like the United States, Australia, Canada, the United Kingdom, and the 
European Union have begun collecting data to understand the potential 
risks associated with nanomaterials and are reviewing their 
legislative authorities to determine the need for modifications. 
Australia and the United Kingdom have undertaken a voluntary data 
collection approach whereas Canada plans to require companies to 
submit certain types of information. Some U.S. states, like 
California, have also begun to address the potential risks from 
nanomaterials by, for example, collecting information from 
manufacturers on a limited number of nanomaterials in use in those 
states and making some of this information publicly available. 

What GAO Recommends: 

GAO recommends that EPA complete its plans to modify its regulatory 
framework for nanomaterials as needed. EPA concurred with our 
recommendations and provided technical comments, which we incorporated 
as appropriate. 

View [hyperlink, http://www.gao.gov/products/GAO-10-549] or key 
components. For more information, contact Anu Mittal at (202) 512-3841 
or mittala@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Nanomaterials Currently Enhance Products across a Number of Industry 
Sectors, and New Uses Continue to Be Developed: 

Potential Risks to Human Health and the Environment from Nanomaterials 
Depend on Toxicity and Exposure, and Current Understanding of the 
Risks Is Limited: 

EPA Has Taken a Multipronged Approach to Managing the Potential Risks 
of Nanomaterials but Faces Various Challenges in Regulating These 
Materials: 

Other National Authorities Are Collecting Information on Nanomaterials 
and Are Evaluating Their Legislation to Ascertain if Changes Are 
Needed: 

Some State and Local Governments Have Begun to Address the Risks of 
Nanomaterials: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Environmental Protection Agency: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Reports: 

Figures: 

Figure 1: Examples of Nanomaterials as Raw Materials, Intermediates, 
and Finished Products: 

Figure 2: Examples of Current and Potential Nanotechnology Innovations 
that May Be Used in an Automobile: 

Figure 3: Examples of Current and Potential Nanotechnology Innovations 
That May Be Used in a Mobile Phone: 

Figure 4: Examples of Current and Potential Nanotechnology Innovations 
That May Be Used in a Drink Bottle: 

Figure 5: Examples of Current and Potential Nanotechnology Innovations 
That May Be Used in a House: 

Figure 6: Potential Exposure Routes throughout the Life Cycle of 
Nanomaterials: 

Figure 7: The Increase in Environment and Human Safety Research 
Relating to Nanomaterials since 2005: 

Abbreviations: 

CERCLA: Comprehensive Environmental Response, Compensation, and 
Liability Act: 

EPA: Environmental Protection Agency: 

FIFRA: Federal Insecticide, Fungicide, and Rodenticide Act: 

ISO: International Organization for Standardization: 

NICNAS: National Industrial Chemicals Notification and Assessment 
Scheme: 

NNI: National Nanotechnology Initiative: 

OECD: Organisation for Economic Co-operation and Development: 

RCRA: Resource Conservation and Recovery Act: 

REACH: Regulation, Evaluation and Authorization of Chemicals: 

SNUR: Significant New Use Rule: 

TSCA: Toxic Substances Control Act of 1976: 

UV: ultraviolet: 

Wilson Center: Woodrow Wilson International Center for Scholars' 
Project on Emerging Nanotechnologies: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

May 25, 2010: 

The Honorable Barbara Boxer:
Chairman:
Committee on Environment and Public Works: United States Senate: 

Dear Madam Chairman: 

The term "nanotechnology" encompasses a wide range of innovations 
based on the understanding and control of matter at the scale of 
nanometers--the equivalent of one-billionth of a meter. For 
illustration, a sheet of paper is about 100,000 nanometers thick, a 
human hair is about 80,000 nanometers wide, and three gold atoms lying 
side by side are about 1 nanometer long. Unusual properties can emerge 
in materials manufactured at the nanoscale--including catalytic, 
electrical, magnetic, mechanical, optical, and thermal properties--
that differ in important ways from the properties of conventionally 
scaled materials. Some of these new properties can enhance products 
and their applications across a number of sectors, including 
electronics, medicine, and defense. The world market for 
nanotechnology-related products is growing and is expected to total 
between $1 trillion and $2.6 trillion by 2015. 

Nanomaterials can occur naturally, be created incidentally, or be 
manufactured intentionally. For example, naturally occurring 
nanomaterials can be found in volcanic ash, forest fire smoke, and 
ocean spray. Incidental nanomaterials are by-products of industrial 
processes, such as mining and metal working, and combustion engines, 
such as those used in cars, trucks, and some trains. In contrast, 
manufactured nanomaterials (sometimes called engineered nanomaterials) 
have been specifically designed for a particular function or property, 
such as improved strength, decreased weight, or increased electrical 
conductivity. Our review will focus on manufactured nanomaterials, 
rather than nano-sized materials that occur naturally in the 
environment or are incidentally produced, and for the remainder of 
this report, we will call such materials "manufactured nanomaterials," 
or simply "nanomaterials." While the use of nanomaterials holds 
promise for the future, their small size and unique properties raise 
questions about potential risks to people or the environment that 
might result from exposure to them during their manufacture, use, and 
disposal. Risk is usually defined as the potential for harmful effects 
to human health or the environment resulting from exposure to a 
substance--in this case, nanomaterials. In general terms, risk depends 
on a combination of the exposure a person or the environment has to 
the substance as well as the inherent toxicity of the chemical. In 
other words, the same exposure to two different substances each with 
their own toxicity would result in different levels of potential risk. 

The Environmental Protection Agency (EPA) administers several laws 
that regulate chemicals, pesticides, pollutants in air or water, and 
wastes that may be composed of or contain nanomaterials.[Footnote 1] 
These laws include the following: 

* the Toxic Substances Control Act of 1976 (TSCA), which authorizes 
EPA to require chemical companies to report certain information about 
chemicals used in commerce and authorizes EPA to require testing of 
and control chemicals that pose an unreasonable risk to human health 
or the environment, among other things; 

* the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 
which authorizes EPA to regulate the sale and use of pesticides and 
prohibits marketing of pesticides that have not been registered with 
EPA;[Footnote 2] 

* the Clean Air Act, which requires EPA to set standards for common 
air pollutants and to regulate industrial sources of hazardous air 
pollutants; 

* the Clean Water Act, which authorizes EPA to regulate discharges of 
pollutants into federally regulated waters; 

* the Resource Conservation and Recovery Act (RCRA), which establishes 
a framework for regulation of hazardous and solid wastes and 
authorizes EPA to issue administrative orders to address imminent 
hazards; and: 

* the Comprehensive Environmental Response, Compensation, and 
Liability Act (CERCLA), commonly known as Superfund, which authorizes 
EPA to compel parties responsible for contaminating sites to clean 
them up or to conduct cleanups itself and then seek reimbursement from 
responsible parties. 

On the international level, other national authorities are also 
concerned about the potential risks of nanomaterials and whether their 
current regulatory framework authorities are sufficient to address 
these risks. For example, Australia, Canada, the United Kingdom, and 
the European Union have begun to review their regulatory approaches 
for nanomaterials. Furthermore, the Organisation for Economic Co-
operation and Development--a forum in which the governments of 30 
developed countries, including the United States, work together to 
address economic, social, and environmental issues--has established a 
"working party" on nanomaterials. In addition to the international 
focus on this topic, some U.S. states have begun to explore ways to 
address the potential risks of nanomaterials. 

In this context, you asked us to (1) identify examples of current and 
potential uses of nanomaterials, (2) determine what is known about the 
potential human health and environmental risks from nanomaterials, (3) 
specifically assess actions EPA has taken to better understand and 
regulate the risks posed by nanomaterials as well as its authorities 
to do so, and (4) identify approaches that selected other national 
authorities have taken to address the risks associated with 
nanomaterials. In addition, you asked us to identify any U.S. states 
and localities that have begun to address the risks from nanomaterials. 

To identify examples of current and potential uses of manufactured 
nanomaterials, we analyzed documents and reports that discuss the 
current and future uses of manufactured nanomaterials, such as market 
research reports produced by Lux Research, an independent research 
firm that conducts market analysis of nanotechnology, among other 
things. In addition, we interviewed cognizant agency officials from 
the six U.S. agencies that conduct the majority of nanotechnology-
related research.[Footnote 3] We also interviewed knowledgeable 
stakeholders, including officials from the National Nanotechnology 
Initiative, the Wilson Center, the National Academy of Sciences, Lux 
Research, and the NanoBusiness Alliance--a nanotechnology-related 
business association. We used an iterative process, often referred to 
as "snowball sampling," to identify knowledgeable stakeholders, and we 
selected for interviews those who would provide us with a broad range 
of perspectives on the current and potential uses of nanomaterials. 

To determine what is known about the potential human health and 
environmental risks of manufactured nanomaterials, we reviewed 
documents that had been published by peer-reviewed journals, 
government agencies, and international nonprofit organizations. In 
conducting this review, we searched databases, asked knowledgeable 
stakeholders to identify relevant studies, and reviewed studies from 
article bibliographies to identify additional sources of information 
on the potential risks. Our review focused on 20 such studies, 
selected in part because they provided a synthesis of available 
research related to nanomaterials' risks and covered a variety of 
nanomaterials. For the purposes of this report, all the documents, 
studies, and synthesis studies we reviewed will be referred to as 
"studies." We also spoke with a variety of knowledgeable stakeholders 
representing industry, academia, nongovernmental organizations, and 
the regulatory community. These knowledgeable stakeholders were also 
selected using a snowball sampling method. 

To assess actions EPA has taken to better understand and regulate 
manufactured nanomaterials and its authorities to do so, we analyzed 
selected laws and regulations, including TSCA, FIFRA, the Clean Air 
Act, the Clean Water Act, RCRA, and CERCLA. We also reviewed data and 
reports on EPA's Nanoscale Materials Stewardship Program, which EPA 
developed to encourage companies to voluntarily develop and submit 
information to the agency on the characteristics of nanomaterials. 
Furthermore, we consulted with EPA officials and legal experts to 
obtain their perspectives on EPA's available authorities to regulate 
manufactured nanomaterials. 

To identify the approaches that other selected national authorities- 
Australia, Canada, the United Kingdom, and the European Union--have 
used to address the potential risks associated with manufactured 
nanomaterials, we analyzed these authorities' laws and regulations 
that would be applicable to regulating manufactured nanomaterials. We 
selected these authorities based on interviews with knowledgeable 
stakeholders who identified them as having taken actions related to 
better understanding, assessing, or regulating the potential risks of 
nanomaterials. To identify any states that may be taking action with 
regard to nanomaterials, we spoke with federal regulators; industry 
and environmental groups; and other knowledgeable stakeholders, 
including the Environmental Council of States. 

A more detailed description of our scope and methodology is presented 
in appendix I. We performed our work between May 2009 and May 2010, in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

In fiscal year 2009, federal support for nanotechnology research 
totaled about $1.7 billion. Cumulatively from fiscal year 2001 through 
fiscal year 2009, federal agencies have devoted over $10.5 billion to 
nanotechnology research. To guide federal development of 
nanotechnology, the National Nanotechnology Initiative (NNI) was 
established in 2001 to support long-term research and development 
aimed at accelerating the discovery, development, and deployment of 
nanoscale science, engineering, and technology. The NNI is a mechanism 
to coordinate the nanotechnology-related activities of the 25 
currently participating federal agencies that fund nanoscale research 
or have a stake in the outcome of this research, such as those 
agencies that may regulate products containing nanomaterials. While 
the NNI is designed to facilitate intergovernmental cooperation and 
identify overarching goals and priorities for nanotechnology research, 
it is not a research program and has no funding or authority to 
dictate the nanotechnology research agenda for participating agencies 
or to ensure that adequate resources are available to achieve specific 
goals. Instead, participating agencies develop and fund their own 
nanotechnology research agendas. In fiscal year 2009, six NNI agencies 
accounted for over 95 percent of federal nanotechnology research 
reported. These are the Department of Defense, the Department of 
Energy, EPA, the Department of Health and Human Services' National 
Institutes of Health, the Department of Commerce's National Institute 
of Standards and Technology, and the National Science Foundation. 

Nanomaterials can take a variety of forms and can generally be 
organized into four types: 

* Carbon-based materials. These nanomaterials are composed mostly of 
carbon, and are most commonly spherical, elliptical, or tubular in 
shape. Spherical and elliptical carbon shapes are referred to as 
fullerenes, while tubular ones are called nanotubes. 

* Metal-based materials. These nanomaterials include nanoscale gold, 
nanoscale silver, and metal oxides, such as titanium dioxide. They 
also include quantum dots, which are closely packed semiconductor 
crystals comprised of hundreds or thousands of atoms, on the scale of 
a few nanometers to a few hundred nanometers. 

* Dendrimers. These nanomaterials are nanoscale polymers built from 
branched units. The surface of a dendrimer has numerous branch ends, 
which can be tailored to perform specific chemical functions. Also, 
some dendrimers contain interior cavities into which other molecules 
can be placed, such as for drug delivery. 

* Composites. These materials combine nanoparticles with other 
nanoparticles or with larger, conventional-scale materials. For 
example, nanoparticles, such as nanoscale clay can be combined with 
other materials to form a composite material. 

EPA uses a risk assessment process to estimate the extent of harm, if 
any, that can be expected from exposure to a given substance 
throughout its life cycle and to help regulators determine whether the 
risk meets the requirements for taking action under its statutory 
authorities, such as banning the substance's production or limiting 
its use. The basic risk assessment paradigm includes the following: 

* an evaluation of scientific information on a substance's hazardous 
properties--or toxicity--which may potentially affect human health or 
the environment; 

* the dose-response relationship--the relationship between the extent 
of exposure (dose) and the resulting changes in health or body 
function (response)--describes the toxic effect of a substance; and: 

* exposure--the extent to which humans or the environment are expected 
to be exposed to the chemical. 

EPA is applying this risk assessment paradigm to assess the potential 
risks from nanomaterials. EPA officials also told us that risk 
assessment is not the only means of using scientific information to 
inform decision making. For example, they said that by using green 
chemistry and life cycle assessment approaches,[Footnote 4] a 
material's properties may be modified or exposure controls 
incorporated to minimize and manage potential risk. 

Nanotechnology is an example of a fast-paced technology that poses 
challenges to agencies' policy development and foresight efforts. We 
have conducted past work looking at the challenges of exercising 
foresight when addressing potentially significant but somewhat 
uncertain trends,[Footnote 5] including technology-based trends that 
proceed at a high "clockspeed," that is, a (1) faster pace than trends 
an agency has dealt with previously or (2) quantitative rate of change 
that is either exponential or exhibits a pattern of doubling or 
tripling within 3 or 4 years, possibly on a repeated basis.[Footnote 
6] As our prior work has noted, when an agency responsible for 
ensuring safety faces a set of potentially significant high-clockspeed 
technology-based trends, it may successfully exercise foresight by 
carrying out activities such as: 

* considering what is known about the safety impact of the trend and 
deciding how to respond to it; 

* reducing uncertainty as needed by developing additional evidence 
about the safety of the trend; and: 

* communicating with Congress and others about the trends, agency 
responses, and policy implications. 

Similarly, our 21st Century Challenges report raised concern about 
whether federal agencies are poised to address fast-paced technology- 
based challenges.[Footnote 7] Other foresight literature illustrates 
the potential future consequences of falling behind a damaging trend 
that could be countered by early action. These analyses suggest that 
unless agencies and Congress can stay abreast of technological 
changes, such as nanotechnology, they may find themselves "in a 
constant catch-up position and lose the capacity to shape outcomes." 
[Footnote 8] 

Nanomaterials Currently Enhance Products across a Number of Industry 
Sectors, and New Uses Continue to Be Developed: 

Industries around the world are harnessing the properties of 
nanomaterials for a variety of products across a number of sectors and 
are expected to continue to find new uses for these materials. 
Nanomaterials can enter the marketplace as materials themselves, as 
intermediates that either have nanoscale features or incorporate 
nanomaterials, and as final nano-enabled products (see figure 1). For 
example, a manufacturer of clay nanoparticles can provide them to a 
plastic manufacturer, who can use them to enhance a composite material 
(an intermediate). The plastic manufacturer can then sell the 
composite material to an automobile manufacturer, who can use the 
material to mold parts for cars (nano-enabled products). 

Figure 1: Examples of Nanomaterials as Raw Materials, Intermediates, 
and Finished Products: 

[Refer to PDF for image: illustration] 

Nanomaterials: Nanoscale structures in unprocessed form: 
Such as: 
* Carbon nanotubes; 
* Ceramic nanoparticles; 
* Dendrimers; 
* Fullerenes; 
* Metal nanoparticles; 
* Nanostructured metals; 
* Nanowires. 

Nanointermediates: Intermediate products with nanoscale features: 
Such as: 
* Catalysts; 
* Coatings; 
* Composites; 
* Displays; 
* Drug delivery systems; 
* Energy storage; 
* Sensors. 

Nano-enabled products: Finished goods incorporating nanotechnology: 
Such as: 
* Automobiles; 
* Bottles; 
* Buildings; 
* Cancer treatment; 
* Mobile phones. 

Source: Adapted by GAO from materials produced by Lux Research. 

[End of figure] 

As the uses of nanomaterials continue to evolve, the overall market 
for them is growing, along with the degree to which they are 
permeating our everyday lives. In 2009, the Woodrow Wilson 
International Center for Scholars' Project on Emerging 
Nanotechnologies (Wilson Center) identified a list of more than 1,000 
nano-enabled products currently on the market, reflecting a 379 
percent increase since this list was first compiled in 2006.[Footnote 
9] The list contains information on products from over 20 countries 
that can be purchased and used by consumers and provides a baseline 
for understanding the extent to which nanotechnology is being used. As 
the Wilson Center has reported, the trend of an increased number of 
products and applications featuring nanomaterials is also reflected in 
the number of nanotechnology patents issued by the U.S. Patent and 
Trademark Office, growing from 125 in 1985 to 4,995 in 2005, which 
represents a compound annual growth rate of 20 percent. The following 
is a list of selected industry sectors and some examples of current 
and potential uses of nanomaterials within each sector that illustrate 
the ubiquitous nature of these materials in commerce. Because 
assembling a complete catalog of uses would be difficult in an 
evolving, dynamic industry, the list is not comprehensive, the 
examples chosen are simply illustrative, and we have not verified the 
claims made by the manufacturers of the products used in these 
examples. 

Automotive: 

From car bodies to exterior coatings to engines on the market today, 
cars contain numerous enhancements made possible by nanomaterials. In 
the current marketplace, some bumpers and other auto parts incorporate 
composite materials containing nanomaterials, such as nanoscale clays, 
metals, and carbon nanotubes to make these parts stronger, and more 
fire resistant.[Footnote 10] Many nano-enabled products in the 
automotive sector involve the addition of nanoscale ceramic and metal 
particles to a wide variety of coatings. These nanomaterials provide 
advantages for coatings over conventional materials, such as the 
ability to block ultraviolet (UV) light or promote self-cleaning 
without altering the transparency of the coatings. For example, 
coatings containing nanoparticles are currently dispersed in paints 
and pigments to make surfaces stronger, smoother, more scratch and 
stain resistant, waterproof, or some combination of these and other 
properties. In addition, carbon nanotubes offer an especially high 
tensile strength--the ability to withstand a stretching force without 
breaking--of about 100 times greater than that of steel at one-sixth 
the weight, and their electrical conductivity can be precisely 
controlled, which helps prevent the build-up of static electricity. As 
a result, when a manufacturer of fuel lines adds carbon nanotubes to 
traditional engineering materials, it results in stronger, safer fuel 
lines. 

In the future, nanomaterials could be used to improve the performance 
of cars, including reducing wear on engine parts and increasing 
battery power and fuel efficiency. For example, lubricants that 
contain certain nanomaterials could provide smaller, stronger, and 
more stable alternatives to oil-based lubricants. In addition, 
electrodes--electrical conductors that contain movable electric 
charges--manufactured at the nanoscale could enable higher-performance 
rechargeable batteries. For example, according to documents we 
reviewed, one company that is developing a new lithium-ion battery for 
electric vehicles uses nanoscale metal oxide materials to create 
crystallized nanoparticles that may enable this nano-enabled battery 
to deliver 20 percent more power. Moreover, fuel additives with 
nanoparticles of cerium oxide could increase diesel engine fuel 
efficiency.[Footnote 11] One British company has developed such an 
application for a fuel-based additive that, due to the size-based 
properties of cerium nanoparticles, creates a greater surface area for 
catalyzing the combustion reactions between diesel and air.[Footnote 
12] According to this company, the result is a cleaner burn that 
converts more fuel to carbon dioxide, produces less noxious exhaust, 
and deposits less carbon on the engine cylinder walls than other fuel 
additives. Figure 2 shows examples of some current and potential 
nanotechnology innovations that may be used in automobiles. 

Figure 2: Examples of Current and Potential Nanotechnology Innovations 
that May Be Used in an Automobile: 

[Refer to PDF for image: illustration] 

* Lubricating nanocoating on engine parts improves fuel economy; 

* Carbon nanotube fuel line lessens risk of fire; 

* Nanocomposite body moldings are lighter than conventional materials; 

* Magnetic nanomaterial for memory chips may remove need for battery; 

* Nanocoating improves scratch resistance; 

* Nanoscale catalysts allow reduction in emissions. 

Source: Adapted by GAO from materials produced by Lux Research. 

Note: The photo is illustrative and not intended to imply that this 
particular vehicle currently utilizes the nanotechnology innovations 
depicted or will in the future. 

[End of figure] 

Defense and Aerospace: 

Nanomaterials are beginning to be used in aerospace applications by 
manufacturers seeking to take advantage of the electrical and 
mechanical strength advantages they offer and by the Department of 
Defense, which is seeking ways to enhance the tools available to its 
soldiers and the effectiveness of its weapons systems. Nanomaterial 
polymers are currently being used as sensors that detect very small 
traces of explosives, which indicate the presence of buried landmines, 
according to Department officials. In addition, according to documents 
we reviewed, stronger and lighter planes that are better protected 
against lightning and fire have been made possible by using carbon 
nanotubes and other nanostructured materials. For example, one company 
has created a nanolaminated material used for planes that is comprised 
of layers of metal alloys that are stronger, lighter, and more energy 
absorbent than steel. In addition, polymers with embedded silver 
nanoparticles are helping to keep surfaces, including the interiors of 
aircraft, free of microbes.[Footnote 13] The polymers contain 
nanoscale silver particles that, when added to a product's surface, 
release ions that kill bacteria existing on the surface.[Footnote 14] 
Companies are also introducing nanostructured alternatives to standard 
copper wiring. For example, one company has developed a process to 
create highly conductive sheets of fabric and lengths of yarn 
containing carbon nanotubes that can be used to create wiring and 
cables for airplanes and satellites that weigh much less than 
traditional copper wire. 

In the future, nanomaterials may help enable the development of new 
applications and products across a wide spectrum in the defense arena, 
including surveillance devices, explosives and propellants, and 
uniforms. For example, according to Department of Defense officials 
and documents we reviewed, nearly "invisible" surveillance may be 
possible through the incorporation and integration of different 
nanotechnologies, including radio frequency identification chips; 
integrated circuits; minute biosensors; and "intelligent" fabrics, 
films, and surfaces. Miniaturized surveillance techniques under 
research include using live insects ("spy" bees) tagged with 
nanomaterials or tiny winged robots that emulate insects to fly into 
an enemy situation to record data. In addition, more powerful 
conventional explosives and faster moving missiles may be possible due 
to the greater amounts of energy provided by nanostructured aluminum. 
In combination with metal oxides, such as iron oxide, nanostructured 
aluminum allows many more chemical reactions to occur in a given 
surface area, increasing the explosive force. Also, nanomaterials such 
as carbon nanotubes embedded in fabric could allow for lighter 
uniforms and multifunctional combat suits for soldiers. The uniforms 
could potentially, for example, change color to match the environment, 
become rigid casts to protect injuries, or help block bullets and 
chemical/biological agents. The material could even incorporate 
sensors that monitor a soldier's condition, or function as drug 
dispensers activated automatically via radio waves by a remote doctor. 

Electronics and Computers: 

Computers and consumer electronics have also begun to benefit from the 
advantages nanomaterials offer, including improved display screens and 
improved electrical conductivity. Carbon nanotubes, quantum dots, 
[Footnote 15] and nanoscale layers of polymers can improve the 
properties of displays. For example, one company has developed an 
ultra-thin, layered system of polymers that, unlike conventional 
liquid crystal displays, requires no backlights or filters. The images 
are brighter and clearer, and the technology could make possible fully 
bendable plastic displays, according to the company. In addition, 
since nanomaterials often enhance electrical conductivity, metallic 
nanoparticles and carbon nanotubes are being used in a growing number 
of conductive coatings, such as those used for touchscreens and solar 
cells. According to documents we reviewed, one company sells a 
transparent conductive coating and a coated film, both incorporating 
nanowires, which conduct electricity better than traditional 
materials. The coating and film could eventually replace rare and 
expensive indium tin oxide, currently the most widely used transparent 
conductor in the display industry. Moreover, nanomaterials such as 
lead-free, conductive adhesives could eliminate several steps in 
manufacturing electronics and could lead eventually to elimination of 
some or all of the 3,900 tons of toxic, leaded solder used every year 
by the U.S. electronics industry, according to an EPA document. 

In the future, computers and electronic devices could employ 
nanomaterials to create more efficient data storage and longer-
lasting, rechargeable batteries. Memory storage devices could become 
more powerful through a variety of nanotechnology applications. New 
methods of storing information electronically are emerging from a 
variety of applications aimed at increasing the amount of information 
that can be stored on a given physical space. For example, one company 
has demonstrated the potential to create high-density memory devices 
with an estimated storage capacity of 1 terabyte per square inch--more 
than 200 times higher than the storage density of a DVD--by storing 
information mechanically using nanoscale probes to punch nanoscale 
indentations into a thin plastic film.[Footnote 16] In addition, 
companies, research institutions, and government labs are working to 
develop nano-based technology that could perfect "microbatteries," 
which are smaller, cheaper, and more powerful than batteries currently 
in use. The greater surface area of the nanowires used in these 
batteries lowers the internal resistance of the battery and therefore 
allows greater current flow. Figure 3 shows some examples of current 
and potential nanotechnology innovations that may be used in a mobile 
phone. 

Figure 3: Examples of Current and Potential Nanotechnology Innovations 
That May Be Used in a Mobile Phone: 

[Refer to PDF for image: illustration] 

* Nanocomposite plastics are lighter and stronger; 

* Nanomaterials make batteries lighter and longer lasting; 

* Nanomaterials enable faster memory; 

* Nanostructured optical components allow better images; 

* Nano-enabled light emitting diode or light emitting polymer displays 
are lighter and cheaper; 

* Antimicrobial nanocoating resists bacteria. 

Source: Adapted by GAO from materials produced by Lux Research. 

Note: The photo is illustrative and not intended to imply that this 
particular phone currently utilizes the nanotechnology innovations 
depicted or will in the future. 

[End of figure] 

Energy and Environment: 

Companies are beginning to use nanomaterials to clean up waste, 
substitute nonrenewable resources with renewable ones, reduce 
pollution, and increase the efficiency of solar power. Because 
nanoscale particles can be more chemically reactive than 
conventionally scaled particles of the same substance due to their 
large surface area to volume ratio, these materials can be useful for 
environmental remediation. Specifically, the increased surface area of 
various types of ceramic or metal nanomaterials can result in the 
rapid reduction of contaminant concentrations in soil, water, and air, 
as pollutants or toxins in these media react with the nanomaterials. 
Similarly, nanoscale iron is being deployed in a growing number of 
environmental remediation projects with results that are proving 
successful so far, according to EPA officials. For example, at one 
remediation project, researchers injected carbon infused with 
nanoparticles of iron into contaminated soil and found that the 
nanoparticles made the resulting material more effective at absorbing 
contaminants than similar materials without the nanoparticles. In 
addition, nanomaterials are being used to create packaging materials 
made from waste. For example, one company produces nanoparticle paper 
coatings made from renewable natural starches that can replace 
conventional material in paper coatings, which is typically made from 
nonrenewable petroleum. Nanomaterials are also being used to improve 
automotive catalytic converters, which feature nano-enabled catalysts 
that reduce air pollution more efficiently. One company is 
manufacturing a catalyst consisting of nanostructures with surface 
areas much higher than traditional materials and that allows catalytic 
converters to remain effective under prolonged exposure to high 
temperatures, resulting in more stable, durable, and cost-effective 
products. In the energy arena, nano-enabled thin-film and photovoltaic 
technologies are making solar power more efficient. For example, one 
company has reported gains in the ability of its thin-film solar cell 
materials to absorb light, because the structure of the nanomaterial 
is much smaller than the wavelength of light, which allows it to act 
like an antenna that concentrates, absorbs, and transfers energy with 
high efficiency. 

In the future, nanomaterials could help deliver alternative forms of 
energy, cleaner water, and more efficient energy transmission. Using 
nanoscale catalysts, hydrogen--an alternative form of energy--could be 
produced from water more efficiently. For example, a company has 
developed a photoelectrode that uses nanoscale material and converts 
sunlight into hydrogen six times more efficiently than its 
conventionally scaled equivalent.[Footnote 17] In addition, 
nanotechnology-enabled water desalination and filtration systems may 
offer affordable, scalable, and portable water filtration in the 
future. Filters, comprised of nanoscale pores which incorporate a wide 
variety of nanomaterials--including nanoparticles made of aluminum 
oxide, iron, and gold, and carbon nanotubes--have the potential to 
allow water molecules to pass through, but screen out larger 
molecules, such as salt ions and other impurities such as bacteria, 
viruses, heavy metals, and organic material. In addition, 
nanoparticles could be used to improve the efficiency of energy 
transmission by increasing the capacity and durability of insulation 
for underground electrical cables, allowing cables of smaller diameter 
to carry the same power as larger cables and to last longer. For 
example, one company's research shows that cable insulation treated 
with nanocomposites containing nanosilica have about 100 times longer 
voltage endurance compared to untreated material. In addition, 
researchers have demonstrated that carbon nanotube fiber bundles could 
carry 100 times more electrical current than the leading transmission 
wires, without as much energy loss. Moreover, one study predicts that 
if energy transmission losses could be reduced from the current 7 
percent using copper wires to 6 percent by using carbon nanotube 
fibers, the annual energy savings in the United States would be equal 
to 24 million barrels of oil. 

Food and Agriculture: 

Nanomaterials are currently appearing in food packaging and food 
supplements.[Footnote 18] Specifically, nanomaterials are being used 
in food packaging, where applications such as antimicrobial nanofilms--
thin layers of substances meant to hamper the growth of bacteria and 
fungi--are intended to bolster food safety. Also, composite materials 
made of nanoclays embedded in nylon can offer strong oxygen and carbon 
dioxide barriers and have been used in plastic bottles and films for 
packaging food and beverages. For example, one company produces a 
nylon and clay nanocomposite used as a flexible, puncture-resistant 
oxygen barrier for beer and carbonated beverage bottles; in packaging 
for processed meats and cheeses; and in coatings for paper packaging 
for juice or dairy products. Moreover, products such as cutting boards 
and food containers have been infused with nanosilver--which is known 
for its antimicrobial properties. In addition, encapsulation--the 
process of using one material to deliver another material inside the 
human body--has been in use for decades but is being improved with 
nanomaterials. Nanoencapsulated food products and supplements can 
target nutrients, release drugs on a controlled schedule, and mask 
tastes. For example, some vitamins can be difficult to deliver in 
beverages because they degrade and may not be easily absorbed by the 
body. One company has developed nanoscale structures to deliver the 
vitamin to the digestive system, making it easier for absorption to 
occur. Another manufacturer has used nanocapsules to incorporate 
certain fatty acids that have purported health benefits into bread. 
The company claims the acids in the nanocapsules bypass the taste 
buds, emerging only after the nanocapsules reach the stomach, thus 
avoiding any unpleasant taste. 

In the future, manufactured nanomaterials could be used to enhance 
agriculture; monitor food quality and freshness; improve the ability 
to track food products from point of origin to retail sale; and modify 
the taste, texture, and fat content of food. Nanomaterials are being 
developed to more efficiently and safely administer pesticides, 
herbicides, and fertilizers by controlling more precisely when and 
where they are released. In addition, researchers are developing a 
nanoscale powder that can retain water better than other materials and 
allows fertilizers to gradually release nutrients for crops or grass, 
according to the Wilson Center. In addition, researchers have 
developed nanobiosensors using nanoscale particles for detecting 
bacteria, such as salmonella, in water and liquid food. Their work 
could lead to nanosensors that could be used in fields to monitor for 
bacterial contamination of crops, such as spinach, lettuce, and 
tomatoes, potentially reducing the spread of food-borne illnesses. In 
addition, electrically conductive inks containing nanomaterials could 
be used to print radio-frequency identification tags, which could be 
integrated into packaging for food products, potentially resulting in 
improved food security and better inventory tracking and management. 
Figure 4 shows some examples of current and potential nanotechnology 
innovations that may be used in a drink bottle. 

Figure 4: Examples of Current and Potential Nanotechnology Innovations 
That May Be Used in a Drink Bottle: 

[Refer to PDF for image: illustration] 

* Nanoencapsulated carriers deliver food and dietary supplements; 

* Nanosensors detect changes in food and beverage quality; 

* Gas barrier nanocoatings keep food and beverages fresher; 

* Coatings and plastics containing nanomaterials block ultraviolet 
light; 

* Nanosilver antimicrobial coating resists bacteria; 

* Electrically conductive inks containing nanoparticles make radio 
frequency identification tag printable. 

Source: Adapted by GAO from materials produced by Lux Research. 

Note: The photo is illustrative and not intended to imply that this 
particular juice bottle currently utilizes the nanotechnology 
innovations depicted or will in the future. 

[End of figure] 

Housing and Construction: 

Materials and coatings are currently making buildings and homes 
cleaner and stronger, and in the future will allow them to operate 
with higher energy efficiency, according to documents we reviewed. 
Protective coatings and materials that incorporate nanoparticles of 
titanium dioxide are being used to manage heat and light by blocking 
UV light from the sun's rays and are taking on self-cleaning 
properties through a photocatalytic effect.[Footnote 19] For example, 
titanium dioxide is being added to paints, cements, windows, tiles, 
and other products for its sterilizing and deodorizing properties. 
Additionally, as titanium dioxide is exposed to UV light, it becomes 
increasingly hydrophilic--attractive to water--and is therefore being 
used for antifogging coatings or self-cleaning windows. Nanomaterials 
are also proving beneficial to the construction industry by, for 
example, making steel tougher and concrete stronger, more durable, and 
more easily placed. For example, one company has created a structural 
material with a grain size reduced to the 100 nanometer scale, which 
it claims has a strength-to-density ratio four times that of the 
toughest titanium alloys and also resists corrosion. Inside the walls 
of buildings, insulation made from nanomaterials is providing high 
thermal performance at minimal weight and thickness. In addition, 
nanomaterials are being incorporated into some air monitoring 
technologies, air purification products, and energy-efficient air 
conditioning systems for residential, commercial, and industrial 
settings. For example, some air filters that are on the market use 
nanomaterials to clean air better than conventional materials. 

In the future, nanoparticle coatings on windows and buildings could 
retain energy from the sun for later release. For example, researchers 
working on phase change materials--materials which absorb and release 
thermal energy--have found that when graphite nanofibers are blended 
into these materials the nanofibers improve the material's thermal 
performance. The result could be cheaper and more efficient uses of 
these materials for solar energy storage. In addition, nanomaterials 
may offer approaches that enable materials to "self-heal" by 
incorporating, for example, nanocontainers of a repair substance 
(e.g., an epoxy) throughout the material. When a crack or corrosion 
reaches a nanocontainer, it could be designed to open and release its 
repair material to fill the gap and seal the crack. Figure 5 shows 
some examples of current and potential nanotechnology innovations that 
may be used in a house. 

Figure 5: Examples of Current and Potential Nanotechnology Innovations 
That May Be Used in a House: 

[Refer to PDF for image: illustration] 

* Nanomaterials allow solar cells to be integrated into roof material; 

* Nanoporous materials make insulation more efficient; 

* Self-cleaning, nanostructured window coatings loosen dirt so windows 
can self-clean; 

* Nanocomposite materials make drywall stronger; 

* Nanocoatings make bathroom surfaces easy to clean; 

* Nanoparticles make paint durable and mildew resistant. 

Source: Adapted by GAO from materials produced by Lux Research. 

Note: The photo is illustrative and not intended to imply that this 
particular house currently utilizes the nanotechnology innovations 
depicted or will in the future. 

[End of figure] 

Medical and Pharmaceutical: 

Nanotechnology is important to the medical and pharmaceutical industry 
because the extremely small size of nanomaterials makes possible 
medical interventions that can be directed to individual cell types, 
allowing for better diagnosis, treatment, and prevention of cancer and 
other deadly diseases.[Footnote 20] Current disease detection efforts 
include the use of nanoscale sensors to identify biomarkers, such as 
altered genes, that may provide an early indicator of cancer. Doctors 
are also using nanomaterials as markers to enhance images from deep 
inside human tissue, allowing them to track particles to the site of a 
tumor, resulting in earlier detection of tumors. Certain nanomaterials 
such as polymer nanoparticles are being used to treat cancer by 
delivering medication directly to tumors while sparing healthy tissue. 
In addition, silver nanocrystals are being used in antimicrobial wound 
dressings, thereby requiring fewer dressing changes and causing 
patients less pain. 

In the future, nanomaterials could be used to help doctors better 
diagnose and treat disease. In diagnosis, nanomaterials hold promise 
for showing the presence, location, and contours of cardiovascular and 
neurological disease, and small tumors. For example, researchers could 
use metallic and magnetic nanoparticles to enhance imaging, the 
results of which can be used to guide surgical procedures and to 
monitor the effectiveness of nonsurgical therapies in reversing the 
disease or slowing its progression. In the future, sensors implanted 
or delivered with a drug could allow for continuous and detailed 
health monitoring so disease might be managed better, turning a drug 
into a multifunctional tool for diagnosis and treatment. For example, 
bio-sensors could be attached to targeted drugs and linked to a 
mechanism that reports the body's condition. Furthermore, according to 
the National Institutes of Health, gold nanoshells are being developed 
to simultaneously image and destroy cancer cells using infrared light. 
Nanoshells can be designed to absorb light of different frequencies, 
generating heat. Once the cancer cells take up the nanoshells, 
scientists apply near-infrared light that is absorbed by the 
nanoshells, creating an intense heat inside the tumor that selectively 
kills tumor cells without disturbing neighboring healthy cells. Such a 
targeted delivery approach could reduce the amount of chemotherapy 
drug needed to kill cancer cells, potentially reducing the side 
effects of chemotherapy. Medical researchers are also exploring the 
use of nanomaterials to deliver molecules and growth factors to 
promote better healing for burns and wounds that heal without scars. 
For example, Department of Defense researchers have conducted tests in 
animals using nanofiber mesh scaffolds to treat bone, nerve, 
cartilage, and muscle injuries and have reported that preclinical data 
from the studies indicate improved healing. Other nanofibers are being 
developed for medical use as mesh barriers to stop the flow of blood 
and other fluids more quickly and effectively. 

Personal Care, Cosmetics, and Other Consumer Products: 

Nanomaterials are currently being used in a variety of personal care 
items, cosmetics, and other consumer products.[Footnote 21] These 
products include sunscreens that contain nanoscale titanium dioxides 
and zinc oxides, which act as physical filters that absorb UV light. 
Because these nanomaterials are smaller than the wavelength of light, 
they make sunscreens transparent instead of opaque, and they may also 
adhere better when applied and absorb harmful ultraviolet rays more 
effectively than conventional sunscreens, according to stakeholders 
and documents we reviewed. In addition, nanomaterials are being 
incorporated into cosmetics, such as an anti-aging cream, which allows 
the active ingredients to penetrate deep into the skin where they can 
be most effectively administered, according to the manufacturer. 
Nanomaterials are also being used in a wide range of other consumer 
products. For example, companies are using carbon nanotubes to 
reinforce a variety of sporting goods, such as bicycle frames, tennis 
rackets, baseball bats, and hockey sticks, because they offer greater 
strength and reduced weight, while retaining, or even increasing, 
stiffness. Companies are using other nanomaterials to improve the 
performance of products such as ski wax and tennis balls. For example, 
a nanomaterial coating decreases the gas permeability in tennis balls 
and therefore allows the balls to maintain pressure for longer periods 
of time, according to the company producing the coating. Nanomaterials 
are also being used in coatings to make fabrics and clothing stain and 
water resistant. For example, one company embeds nanomaterials on the 
surface of fabric fibers, creating a cushion of air around them. The 
fabric allows sweat to pass out, while also causing surface water to 
bead up and roll off. Another company has developed socks treated with 
nanosilver for its antimicrobial properties. 

In the future, consumers may benefit from advanced applications that 
could emerge from nanomaterial research occurring in a variety of 
sectors. For example, developments in the health arena could lead to 
new, beneficial pharmaceutical therapies designed to treat aging and 
age-related disease. In addition, according to documents we reviewed, 
researchers are working to make textiles functional by combining 
manufactured nanomaterials with materials that react to light to 
create power-generating clothing and nanosilver could be used in 
textiles to treat skin conditions. Researchers are also developing 
nano-enabled textile surfaces that can remove scratches and scuff 
marks, as well as decolorize red wine spills. 

Potential Risks to Human Health and the Environment from Nanomaterials 
Depend on Toxicity and Exposure, and Current Understanding of the 
Risks Is Limited: 

The properties of nanomaterials affect their toxicity and, in turn, 
their risks to human health and the environment. Furthermore, the risk 
of nanomaterials also depends on the extent and route of exposure to 
nanomaterials, but current understanding of nanomaterial toxicity and 
exposure is limited, according to the studies we reviewed. 

The Toxicity of Individual Nanomaterials May Vary According to Their 
Properties and Affects Their Risks: 

The toxicity of each nanomaterial may vary according to a combination 
of the individual properties of these materials--including size, 
shape, surface area, and ability to react with other chemicals--and 
these properties affect the potential risks posed by nanomaterials, 
according to some of the studies we reviewed. The properties of a 
nanomaterial may differ from the properties of conventionally scaled 
material of the same composition. For example, the properties of 
conventionally scaled gold have been well characterized: gold is 
metallic yellow in color and does not readily react with other 
chemicals. As a nanoparticle, however, gold can vary in color from red 
to black and become highly reactive. The following are examples of how 
toxicity may be affected by the properties of nanomaterials as 
compared with their conventionally scaled counterparts: 

* Size. Research assessing the role of particle size on toxicity has 
generally found that some nanoscale (<100 nanometers) particles are 
more toxic and can cause more inflammation than conventionally scaled 
particles of the same composition. Specifically, some research 
indicates that the toxicity of certain nanomaterials, such as some 
forms of carbon nanotubes and nanoscale titanium dioxide, may pose a 
risk to human health because these materials, as a result of their 
small size, may be able to penetrate cell walls, causing cell 
inflammation and potentially leading to certain diseases. For example, 
the small size of these nanomaterials may allow them to penetrate 
deeper into lung tissue, potentially causing more damage, according to 
some of the studies we reviewed. In addition, some nanomaterials may 
disperse differently into the environment than conventionally scaled 
materials of the same composition because of their size. However, 
according to EPA, the small particle size may also cause the 
nanomaterials to agglomerate, which may make it more difficult for 
them to penetrate deep lung tissue. 

* Shape. Nanomaterials may be produced in a wide variety of shapes, 
including spheres, tubes, threads, and sheets, as well as more ornate 
forms, such as dumb-bells. The shape of nanomaterials may be connected 
to the type of health risks they may pose. For example, some carbon 
nanotubes resemble asbestos fibers. When inhaled by people, asbestos 
fibers are known to cause mesothelioma--which is a disease associated 
with asbestos exposure. The similarity of these carbon nanotubes to 
asbestos fibers has caused researchers to question if exposure to such 
nanomaterials may lead to a similar disease. Furthermore, a study has 
shown that exposing the abdominal cavity of mice to certain long 
carbon nanotubes may be linked with inflammation of the abdominal 
wall. The abdominal cavity in mice is often used as a surrogate for 
understanding how the mesothelial lining of the human chest cavity 
will react to substances. 

* Surface area and reactivity. Nanomaterials may also be more reactive 
with other chemicals than similar conventionally scaled materials 
because nanomaterials have a higher surface area-to-mass ratio, 
providing more area by weight for chemical reactions to occur. Some 
studies have found that because of this increased reactivity, some 
nanoscale particles may be potentially explosive and/or photoactive-- 
that is, sunlight triggers a chemical reaction in them. For example, 
some nanomaterials--such as nanoscale titanium dioxide and silicon 
dioxide--may explode if finely dispersed in the air and they come into 
contact with a sufficiently strong ignition source. However, in 
general, the extent to which such nanoscale dusts may be more 
explosive than larger size dusts of the same composition is not fully 
known, according to the National Institute for Occupational Safety and 
Health. Other research has shown that particle surface area is a 
better predictor of toxic response to inhaled particles than is 
particle mass. For example, research into nanoscale titanium dioxide 
in mice and rats has shown that particle surface area seems to be a 
more appropriate measure for comparing the effects of different-sized 
particles, provided they are of the same chemical structure. 

Risk of Nanomaterials Is Also Affected by the Route and Extent of 
Exposure: 

In addition to toxicity, the risk that nanomaterials pose to humans 
and the environment is also affected by the route and extent of 
exposure to such materials. Nanomaterials can enter the human body 
through three primary routes: inhalation, ingestion, and dermal 
penetration.[Footnote 22] 

* Inhalation is the most common route of exposure to airborne 
nanoparticles, according to the National Institute of Occupational 
Health and Safety. For example, workers may inhale nanomaterials while 
producing them if the appropriate safety devices are not used, while 
consumers may inhale nanomaterials when using products containing 
nanomaterials, such as spray versions of sunscreens containing 
nanoscale titanium dioxide. According to officials at the National 
Institutes of Health, although the vast majority of inhaled particles 
enter the pulmonary tract, evidence from studies on laboratory animals 
suggest that some inhaled nanomaterials may travel via the nasal 
nerves to the brain and gain access to the blood, nervous system, and 
other organs, according to studies we reviewed. 

* Ingestion of nanomaterials may occur from unintentional hand-to-
mouth transfer of nanomaterials or from the intentional ingestion of 
nanomaterials.[Footnote 23] Ingestion may also accompany inhalation 
exposure because particles that are cleared from the respiratory tract 
can be swallowed. A large fraction of nanoparticles, after ingestion, 
rapidly pass out of the body; however, according to some of the 
studies we reviewed, a small amount may be taken up by the body and 
then migrate into organs. The effect of these small amounts of 
ingested nanomaterials is currently unknown, but concerns have arisen 
from a growing body of evidence which indicates that certain types of 
nanoparticles may cross cellular barriers. 

* Nanomaterials may also be absorbed through the skin. For example, 
one laboratory study has shown that certain nanomaterials have 
penetrated layers of pig skin within 24 hours of exposure. In 
addition, some cosmetics and sunscreens--among the first commercial 
products to incorporate nanomaterials--contain nanoscale titanium 
dioxide to increase the ultraviolet light-blocking power of the 
product. The nano titanium dioxide is believed to be less toxic than 
other chemicals that have been used to provide ultraviolet protection 
in sunscreens. However, according to some of the studies we reviewed, 
concerns have been raised that nanomaterials in sunscreens could 
penetrate damaged skin. In contrast, according to officials at the 
National Institutes of Health, there are several studies that have 
found little dermal penetration from nanomaterials when applied to 
undamaged skin. According to some stakeholders we spoke to, given the 
known hazards of sun exposure, sunscreens containing nanomaterials may 
be reasonable choices for the protection that they provide to 
consumers from sun exposure. 

In addition to the route of exposure, the extent of exposure--that is 
the frequency and magnitude--to consumers and workers also affects the 
risks posed by nanomaterials. Workers may be accidentally exposed to 
nanomaterials during the production of nanomaterials or products 
containing them, as well as during use, disposal or recycling of these 
products. At present, there is insufficient information on the number 
of workers exposed to nanomaterials in the work place or the effects 
on human health of such exposure, according to the European Agency for 
Safety and Health at Work. In addition, because nanomaterials have 
applications in many consumer products and the use of such materials 
in products is increasing, consumers have an increasing chance of 
exposure to these materials. For example, consumers may now purchase 
appliances such as washing machines coated with silver nanomaterials 
purported to kill bacteria. When consumers purchase such a machine, 
their clothing will be exposed to the silver nanomaterials, thus 
increasing their exposure to nanomaterials. Similarly, consumers may 
now purchase socks containing nanosilver, which exposes them to this 
nanomaterial. According to EPA officials, occupational exposure is a 
particular concern and warrants attention because the exposure and 
risk to workers is potentially greater than the risk to consumers. 
[Footnote 24] 

In addition to humans, the environment may also be exposed to 
nanomaterials through releases into the water, air, and soil, during 
the manufacture, use, or disposal of these materials. For example, 
nanomaterials could enter water through discharges from production 
facilities. In addition, when nanomaterials are used in 
pharmaceuticals, cosmetics, and sunscreens, the nanomaterials could 
enter water via the sewage system during washing, showering, or 
swimming after having been applied to the skin and may eventually end 
up in a waste water treatment plant. These nanomaterials, if 
antibacterial in nature and if released in sufficient amounts, could 
potentially interfere with beneficial bacteria in sewage and waste 
water treatment plants and could also contaminate water intended for 
re-use, according to some of the studies that we reviewed. Moreover, 
some researchers have raised serious concerns that antibacterial 
nanomaterials will pose toxicity risks to human health and to 
environmental systems into which waste products are released. In 
addition, according to research, unused cosmetics are most likely to 
be disposed of in household waste, which may be incinerated, 
potentially putting nanomaterials into the air, or put in a landfill, 
potentially leaching out of the landfill into the water. In addition, 
nanomaterials that are currently being used to treat polluted water 
will result in releases of the materials into water and soil. For 
example, iron nanoparticles are being used to treat polluted water. 
According to EPA officials, although little is known about how these 
particles move through the environment, they are expected to react 
with contaminants or with naturally occurring substances in water and 
become iron oxides. Figure 6 shows the potential exposures to humans 
and the environment throughout the lifecycle of nanomaterials. 

Figure 6: Potential Exposure Routes throughout the Life Cycle of 
Nanomaterials: 

[Refer to PDF for image: illustration] 

Life cycle: 
Nanomaterial production; 
Product manufacturing; 
Consumer use; 
End of life (disposal or recycling). 

Worker and consumer exposure routes: 
Dermal; 
Ingestion; 
Inhalation. 

Environmental exposure routes: 
Air; 
Soil; 
Water. 

Source: Adapted by GAO from materials produced for the European 
Parliament's Committee on the Environment, Public Health and Food 
Safety. 

[End of figure] 

Currently, it is difficult to assess the risk of nanomaterials that 
are released into the environment because these materials are so 
varied and it is difficult to make generalizations about how they will 
behave once they are released, according to EPA officials. 
Specifically, it is unclear whether the nanomaterials will (1) stay 
suspended, (2) aggregate or cluster together to form larger particles, 
(3) dissolve or further break down, or (4) react with natural 
materials found in the environment. For example, the release of carbon 
nanotubes, nanoparticles of iron and titanium dioxide, or fullerenes--
which are nanoscale spheres of carbon--into water may result in their 
aggregation, according to some of the studies we reviewed. These 
larger aggregates may have different toxicological properties when 
compared to those exhibited by the original nanomaterials. The risk 
posed by some nanomaterials is presumed to decrease if they aggregate 
because the nanomaterials may grow to the size of conventionally 
scaled substances, according to some of the studies we reviewed. 
However, the extent of aggregation may be limited because many 
nanomaterials receive coatings to decrease the aggregation of these 
materials. In addition, some nanomaterials may react with the 
environment and eventually build up in the environment, according to 
some of the studies we reviewed. Specifically, some nanomaterials may 
become attached to and continue to build up in the soil, depending on 
the nanomaterial characteristics and the characteristics of the soil. 
Some nanomaterials may also bioaccumulate in organisms, according to 
EPA. 

Understanding of the Risks Posed by Nanomaterials Is Limited by 
Several Factors: 

Current understanding of the risks that nanomaterials may pose is 
limited by several factors, including the limited amount of research 
that has been conducted to date and a lack of tools and methods needed 
to conduct additional research. As a result, predicting and assessing 
the potential hazards, exposures, and resulting risks from 
nanomaterials is difficult. Although the number of studies that have 
focused on assessing the risks of nanomaterials has increased over the 
past 5 years (see figure 7), the studies completed to date have 
yielded limited risk information, according to EPA officials and other 
stakeholders that we spoke with, and our review of these studies. Some 
of these limitations include the following: 

* The findings from completed toxicity studies of a nanomaterial 
constructed in one manner may not be applicable to understanding the 
risks posed by the same nanomaterial constructed in a different manner 
and, therefore, studies of similar nanomaterials may not be 
comparable. For example, carbon nanotubes may be produced in several 
ways, each with its own potential level of toxicity so that the 
results of a study for one type of carbon nanotube may not be 
comparable to the results of a study of a different type of carbon 
nanotube. Similarly, some early studies of carbon nanotubes did not 
specify the length of the nanotubes being studied, making it difficult 
to compare the results of those studies with subsequent carbon 
nanotube studies, according to stakeholders. This is important because 
researchers now know that different nanotube lengths may pose 
different risks. 

* The studies that have been conducted have focused more extensively 
on some nanomaterials than others. For example, certain silica 
nanoparticles and carbon black are among the best studied 
nanomaterials, according to EPA. In contrast, less is known about 
nanomaterials such as nanoscale aluminum oxide and nanoclays. 
Therefore, little or no information is known about the risks of these 
types of nanomaterials. 

Figure 7: The Increase in Environment and Human Safety Research 
Relating to Nanomaterials since 2005: 

[Refer to PDF for image: vertical bar graph] 

Year: 2005; 
Number of publications: 128. 

Year: 2006; 
Number of publications: 197. 

Year: 2007; 
Number of publications: 377. 

Year: 2008; 
Number of publications: 462. 

Year: 2009; 
Number of publications: 721. 

Source: GAO analysis of International Council on Nanotechnology data. 

[End of figure] 

Additional efforts to study the risks from nanomaterials will also be 
hampered because certain tools necessary to conduct these studies are 
lacking. Specifically, according to studies we reviewed, research on 
nanomaterials depends on the availability of tools, such as models or 
measurement technologies, to characterize or describe the 
nanomaterials' main qualities. However, although some tools are 
available, the scientific community does not currently possess all the 
needed tools to do so, and it will require extensive research to 
develop these tools. Additionally, lack of data and appropriate models 
also limits our ability to study the risks posed by nanomaterials, 
according to some of the studies we reviewed and stakeholders that we 
spoke with. While researchers have developed models for conventionally 
scaled chemicals that predict their characteristics based on the 
characteristics of similar, or analogous, chemicals, no such models 
exist yet for nanomaterials. For example, as mentioned earlier, free 
nanoparticles may aggregate in the natural environment, forming larger 
structures that may have different toxicological properties to those 
exhibited by the original nanoform, but researchers lack models to 
accurately predict how, when, and with which nanomaterials this 
aggregation will occur. Moreover, according to stakeholders we spoke 
to, small changes in the characteristics of some nanomaterials, such 
as a 10 percent change in their size, may alter the toxicity of the 
nanomaterials. The effect of such a small change compounds the 
difficulty in creating predictive models of nanomaterial toxicity. 

EPA Has Taken a Multipronged Approach to Managing the Potential Risks 
of Nanomaterials but Faces Various Challenges in Regulating These 
Materials: 

EPA has taken a variety of actions to better understand and regulate 
the risks of nanomaterials, including conducting research and asking 
companies to voluntarily provide information about the nanomaterials 
that they produce or use. Although EPA has taken some regulatory 
action under its existing statutory framework with regard to 
nanomaterials, its authority to do so varies depending on the statute 
that it is using to regulate specific nanomaterials.[Footnote 25] 
Moreover, the agency faces additional technical and informational 
challenges that may impact its ability to regulate nanomaterials 
effectively. 

EPA Has Ongoing Research Efforts Related to Nanomaterials: 

In June 2009, EPA issued its Nanomaterial Research Strategy, which 
lays out the agency's plans for research to understand the potential 
human health and environmental impacts from exposure to nanomaterials, 
as well as how certain nanomaterials can be used in environmental 
protection applications, such as remediating contaminated waste. The 
strategy builds upon a body of research already conducted by EPA in 
areas such as ultrafine particulate exposure and toxicity, fate and 
transport modeling, life cycle assessment, and green chemistry. 
[Footnote 26] EPA's strategy states that the agency's research efforts 
will advance two key objectives: (1) develop approaches for 
identifying and addressing any hazardous properties, while maintaining 
beneficial properties, before a nanomaterial enters the environment 
and (2) identify whether, once a nanomaterial enters the environment, 
it presents environmental risks. EPA stated that it plans to pursue 
these objectives from a life cycle perspective--from the production of 
a nanomaterial, through its use in products, and as it is disposed of 
or recycled. Ultimately, EPA plans to develop models and other tools 
to enable it to predict the risks posed by various types of 
nanomaterials. According to the strategy, EPA's research efforts will 
be coordinated with those of other federal agencies. For example, 
EPA's laboratories are collaborating with the National Institutes of 
Health to conduct research on, among other things, the health effects 
of carbon nanotubes. According to EPA, its research builds on and is 
consistent with the scientific needs identified by the NNI's 
Nanotechnology Environmental and Health Implications working group and 
in EPA's 2007 Nanotechnology White Paper. 

EPA is also coordinating with international organizations, such as the 
Organisation for Economic Co-operation and Development (OECD) and the 
International Organization for Standardization (ISO),[Footnote 27] on 
nanomaterials research. Specifically, the OECD established the Working 
Party on Manufactured Nanomaterials in September 2006, with EPA as a 
member and the initial chair of the working party. This working party 
is engaged in a variety of projects to further the understanding of 
the properties and risks of nanoscale materials and how to mitigate 
exposures and potential risks. For example, one project involves a 
program for testing the safety of a set of 14 nanomaterials. 
Specifically, member countries have agreed to develop certain data for 
a group of 14 nanomaterials selected by the OECD working party, in 
part, because they are in commerce or close to commercial use. 
[Footnote 28] As part of this effort, EPA has the lead for the testing 
of fullerenes, single-walled carbon nanotubes, multiwalled carbon 
nanotubes, silver nanoparticles, and nano cerium oxide, among others. 
In addition, EPA is participating in several ISO working groups for 
nanomaterials. ISO has established a technical committee to develop 
international standards for, among other things, nanotechnology 
terminology, specifications for reference materials, and test 
methodologies. 

Under TSCA, EPA Has Regulated Some Nanomaterials as New Chemicals or 
New Uses, but Some Nanomaterials May Be Entering the Market without 
EPA Review: 

Over the last 3 years, EPA's approach for regulating nanomaterials 
under TSCA has been evolving as more information has become available 
on the potential risks. In January 2008, EPA launched a voluntary 
program called the Nanoscale Material Stewardship Program. Under this 
program, EPA posted a notice in the Federal Register asking 
manufacturers and processors of nanomaterials to submit existing 
information on the nanomaterials they produce or use to help EPA 
better understand the human health and environmental risks from these 
substances. Thirty-one companies voluntarily provided information on 
132 nanomaterials, according to EPA officials. In its interim report 
on this program, issued in January 2009, EPA noted that although the 
program provided useful information regarding certain nanomaterials in 
commerce, a significant number of environmental health and safety data 
gaps remain. For example, as part of the voluntary program, EPA 
estimated that companies provided information on only about 10 percent 
of the nanomaterials that are likely to be commercially available. In 
addition, EPA reported that its review of data submitted through the 
program revealed instances in which the details of the manufacturing, 
processing, and use of the nanomaterials, as well as exposure and 
toxicity data, were not provided. This further reduced the usefulness 
of the information received because exposure and toxicity data are two 
of the major categories of information that EPA had identified as 
being needed to better inform its risk assessments of nanomaterials. 
EPA concluded from the low response rate that most companies were not 
inclined to voluntarily supply information on their nanomaterials. 

In January 2008, EPA released a document entitled TSCA Inventory 
Status of Nanoscale Substances--General Approach, which addressed 
whether nanomaterials constituted new chemicals for the purpose of 
regulation under TSCA. TSCA provides EPA with different authorities 
for regulating new chemicals and existing chemicals. New chemicals are 
those that are not already listed on the TSCA inventory, which is a 
list of chemical substances manufactured or processed in the United 
States. Existing chemicals are those already in commerce, including 
about 62,000 which were already in commerce when EPA began reviewing 
chemicals in 1979. In general, existing chemicals can be manufactured 
or processed without any notification to EPA. By contrast, companies 
intending to manufacture a new chemical must generally submit a notice 
to EPA before manufacturing or producing the chemical. In its 2008 
document, EPA stated that a nanomaterial is a new chemical for 
purposes of regulation under TSCA only if it does not have the same 
"molecular identity" as a chemical already on the inventory. Under 
TSCA, a chemical is defined in terms of its particular molecular 
identity. Although molecular identity is not defined in the statute, 
EPA considers chemicals to have different molecular identities when, 
for example, they represent different allotropes--a variant of a 
substance consisting of only one type of atom--or isotopes. [Footnote 
29] According to EPA officials, EPA generally does not consider the 
properties--such as size, shape, and reactivity--of a chemical in 
establishing its molecular identity. Thus, because titanium dioxide is 
already listed on the TSCA inventory, nanoscale versions of titanium 
dioxide, which have the same molecular formula, would not be 
considered a new chemical under TSCA, despite having a different size 
or shape, different physical and chemical properties, and potentially 
different risks. However, fullerenes--a class of nanomaterials made of 
spheres of carbon--would be considered a new chemical because they 
represent a different allotrope, or molecular arrangement of carbon 
atoms, than those chemicals already listed on the inventory. 

If EPA makes certain findings, on the basis of information presented 
in a premanufacture notice, it may control the manufacture, 
processing, distribution in commerce, use, and disposal of the 
chemical. The agency sometimes issues a consent order to the company 
that places conditions on the use of the chemical or requires the 
company to generate more information on the chemical's health and 
environmental effects. Since 2005, the agency has received over 90 
premanufacture notices for nanomaterials under TSCA, according to EPA 
officials. EPA officials also told us that about 20 of these notices 
were requests to be exempt from the full new chemical review process 
based on regulatory exemptions for substances that met specific low 
release and exposure criteria or which were produced at low volumes. 

TSCA also authorizes EPA to issue rules addressing new uses of certain 
materials--known as Significant New Use Rules (SNUR). These rules 
identify new uses of existing chemicals that could affect the nature 
of human and environmental exposure to the substance. If a company 
wants to use a chemical in a way that has been designated as a 
significant new use, it must submit a Significant New Use Notice to 
EPA. For example, if EPA determines that manufacturing a chemical in a 
powder form instead of a liquid form would be a significant new use of 
that chemical, the company planning on manufacturing the chemical in a 
powder form would have to notify EPA. Upon receipt of a notice, EPA 
has 90 days to evaluate the intended use and, if warranted, to 
prohibit or limit it before it occurs. In 2008, EPA issued two such 
rules for nanomaterials. Specifically, having received premanufacture 
notices for nanoscale versions of siloxane-modified silica and alumina 
particles, EPA determined that certain uses of these chemicals, 
including use without employing personal protective equipment, as a 
powder, and uses different from those described in the premanufacture 
notices, were significant new uses. 

In 2008, EPA entered into consent orders with a manufacturer of a 
specific type of carbon nanotubes that placed conditions on the use of 
that manufacturer's carbon nanotubes. EPA was unable to determine the 
potential for human health effects of these nanomaterials based on the 
information available in the premanufacture notices and determined 
that the uncontrolled manufacture, import, processing, distribution, 
use, or disposal of these nanomaterials may present an unreasonable 
risk to human health. Accordingly, EPA imposed exposure and release 
controls on the manufacture of these nanomaterials in addition to 
certain testing requirements. Subsequently, in November 2009, EPA 
proposed SNURs for these nanomaterials, making the limitations 
articulated in the consent orders applicable to all companies that 
might seek to manufacture them, and in January extended the comment 
period until February 2010.[Footnote 30] As of March 2010, no final 
rule had been issued, but according to EPA, the agency is in the 
process of issuing the final SNURs after considering public comment. 
Until the SNURs are finalized, carbon nanotubes produced by 
manufacturers other than those bound by the consent orders may be 
entering the market without EPA review of available information on 
their potential risk. However, according to EPA, no manufacturer or 
importer has been able to demonstrate that their carbon nanotubes are 
chemically identical to another manufacturer's carbon nanotubes; hence 
the agency has treated all carbon nanotubes as unique chemical 
substances for the purpose of listing them on the TSCA chemical 
inventory. 

In the fall of 2009, EPA announced it would reconsider the policy 
described in its January 2008 document, TSCA Inventory Status of 
Nanoscale Substances--General Approach, and subsequently announced it 
planned to develop a SNUR to regulate nanoscale versions of 
conventionally scaled chemicals that are already on the TSCA inventory 
as a significant new use of that chemical. The agency intends to 
propose this rule in December 2010. EPA stated the agency would 
determine the existing uses of nanomaterials by using information 
submitted through the voluntary Nanoscale Materials Stewardship 
Program and other sources. EPA officials told us that issuing a SNUR 
would allow the agency to regulate nano versions of chemicals already 
on the TSCA inventory the same way it would regulate a new chemical. 
One problem that EPA may face in issuing such a SNUR is that many uses 
of nanomaterials are no longer new because nanomaterials are rapidly 
entering the market, according to stakeholders we spoke with. 

TSCA also gives EPA authority to issue rules requiring companies to 
submit certain information about chemicals. EPA plans to issue one 
such rule for nanomaterials that would require manufacturers to 
provide information on production volume, methods of manufacture and 
processing, and exposure and release, as well as available health and 
safety studies.[Footnote 31] Evaluation of this information will 
provide EPA with an opportunity to consider appropriate action under 
TSCA to reduce unreasonable risks to human health or the environment, 
according to EPA. This rule may also help them collect information on 
nanomaterials not covered by the SNUR discussed above. EPA intends to 
propose this rule in December 2010. This, however, raises the concern 
that, in the meantime, nanomaterials may be entering the market 
without the scrutiny these materials may merit. Furthermore, 
stakeholders and EPA officials point out that the completeness of 
information collected under a reporting rule may be limited because 
the current definition of small manufacturers and processors may 
exempt numerous manufacturers and processors of nanomaterials from 
such rules. Some stakeholders told us this exemption may be 
particularly limiting in the case of nanomaterials because much 
nanomaterial development is being done by small startup companies. 
Moreover, the reporting rule that EPA intends to propose will not 
require periodic updates of the material reported. 

EPA also collects data on chemicals through its Inventory Update Rule. 
Under this rule, EPA requires companies to regularly report certain 
information, including production volume and use information for 
chemicals they produce in quantities over 25,000 pounds.[Footnote 32] 
This reporting threshold is intended to capture information on 
chemicals that account for most of the total U.S. production volume 
covered by TSCA. EPA has not adjusted this threshold to capture the 
production of nanomaterials, and thus EPA may be missing the 
opportunity to collect important information on nanomaterials under 
this rule. 

Under TSCA, EPA can also issue rules that require chemical companies 
to test chemicals for their health and environmental effects. To 
require testing, EPA must find that a chemical (1) may present an 
unreasonable risk of injury to human health or the environment or (2) 
currently is or will be produced in substantial quantities and that 
either (a) there is or may be significant or substantial human 
exposure to the chemical or (b) the chemical enters or may reasonably 
be anticipated to enter the environment in substantial quantities. EPA 
must also determine that there are insufficient data to reasonably 
determine or predict the effects of the chemical on health or the 
environment and that testing is necessary to develop such data. EPA 
officials told us they intend to propose a rule in December 2010 that 
would require companies to generate test data on the health effects of 
15 to 20 different nanomaterials, including carbon nanotubes, 
nanoclays, and nano aluminum, and also on nanomaterials used in 
aerosol-applied products.[Footnote 33] This information will help EPA 
correlate the properties of these materials with specific health 
effects, manage or minimize risk and exposure, and help EPA determine 
the need for additional testing of these nanomaterials, according to 
EPA. EPA officials told us they will be working with the National 
Institute for Occupational Safety and Health, the Occupational Safety 
and Health Administration, and the Consumer Product Safety Commission 
on this effort. However, as we have noted in a prior report, EPA has 
had difficulty in promulgating test rules in the past because, as 
described above, it must demonstrate that chemicals may pose certain 
health or environmental risks or meet volume and exposure thresholds 
before it can require companies to establish such risks through 
testing.[Footnote 34] Because relatively little is currently known 
about the potential risks of nanomaterials and many of them have low 
production volumes, EPA may have similar difficulties in making the 
types of determinations necessary to promulgate a test rule for 
nanomaterials. 

EPA Has Not Developed a Clear Process under FIFRA for Regulating 
Pesticides Containing Nanomaterials: 

FIFRA requires companies to obtain a registration in order to 
distribute or sell a pesticide. According to EPA, this authority 
extends to pesticides containing nanomaterials. EPA must register a 
pesticide if it determines, among other things, the pesticide will 
perform its intended function without unreasonable adverse effects on 
the environment.[Footnote 35] Under FIFRA, EPA is authorized to 
require companies to submit or generate data that EPA needs to assess 
the risks of the pesticide. EPA may publish and periodically revise 
both data requirements and guidelines identifying the types of 
information it generally requires to assess pesticides for 
registration and the methods by which such data may be generated. 
According to EPA, the agency may, on a case-by-case basis, modify data 
requirements and guidelines for specific pesticides. In making its 
registration decision, EPA can allow the pesticide to be distributed 
and sold; allow it to be distributed and sold under certain 
conditions, such as the need to develop further information; or 
prohibit its distribution and sale altogether. However, according to 
the agency, EPA's current guidelines do not require companies to 
specify whether their pesticides contain nanoscale materials. 

Officials told us that since 2007 they have received a few 
applications for registration of various nanosilver pesticide 
preparations. EPA officials told us that some of the companies that 
have submitted registration applications for nanopesticides have told 
EPA that the pesticide includes nanomaterials, while in other cases 
EPA told us they were able to determine the pesticide contained 
nanomaterials from the manufacturing processes. However, EPA officials 
told us they registered at least one pesticide since 2007 without 
being aware that it contained nanomaterials. A group of environmental 
and consumer organizations has identified 260 products currently on 
the market that claim to contain nanosilver. This group contends these 
products should be regulated as pesticides due to the antimicrobial 
effects of nanosilver, but that these products are not registered with 
EPA under FIFRA.[Footnote 36] Because applicants do not have to 
identify whether their pesticidal product contains nanomaterials, EPA 
may not know that certain pesticides contain nanomaterials, and these 
pesticides may be entering the market without EPA specifically 
considering the potential risks their nanomaterials may pose. 

EPA officials told us that if a company replaces a conventionally 
sized active ingredient in a pesticide with a nanoscale version of 
that ingredient, it is mandatory for the company to amend its 
registration. Officials also noted, however, that the agency's 
position on this point needs to be made explicit to the regulated 
community and such a clarification could be made in EPA guidance. 
According to stakeholders, manufacturers of nanopesticides are 
required to obtain an amended registration in such a circumstance even 
without new EPA guidance explicitly requiring it since the 
registration requirement is based not only on questions of chemical 
identity, but also on claims made about the pesticide; its 
composition; and its chemistry, toxicology, and other information. 
However, until EPA makes the requirement to obtain an amended 
registration for pesticides that substitute a nanoscale ingredient for 
a conventionally sized ingredient clear, such pesticides may be re-
engineered to include nanomaterials without EPA's knowledge and review. 

EPA Believes It Has the Authority to Regulate Nanomaterials under Air, 
Water, and Waste Statutes but Technology-related Limitations and 
Volume-based Regulatory Thresholds Present Regulatory Challenges: 

According to EPA officials and stakeholders, the agency can regulate 
nanomaterials as it regulates other pollutants and waste under the 
Clean Air Act, Clean Water Act, and RCRA, as well as undertake 
cleanups of nanomaterials under CERCLA. Nanomaterials do not pose the 
same definitional difficulties under the air, water, and waste 
statutes as they do under TSCA and FIFRA because pollutants and wastes 
are defined by their effects on humans and the environment rather than 
by their composition. For example, EPA can list a nanomaterial as a 
hazardous air pollutant if the agency can establish that the 
nanomaterial may present a threat of adverse human health effects. 
[Footnote 37] Similarly, EPA can list a nanomaterial as a toxic water 
pollutant if exposure to the nanomaterial causes death, disease, and 
genetic mutations, among other effects. Similarly under RCRA, a 
material is characterized as a hazardous waste if it is specifically 
listed as hazardous waste by EPA or it demonstrates any of four 
hazardous characteristics--ignitability, corrosivity, reactivity, or 
toxicity--based on testing or the knowledge of the manufacturer or 
processor that generated the waste. Finally, under CERCLA, a material 
is characterized as a hazardous substance if it is deemed hazardous 
under CERCLA, RCRA, the Clean Water Act, the Clean Air Act, or TSCA. 
EPA can designate additional substances as hazardous under CERCLA if 
their release may present substantial danger to the public health or 
welfare or the environment. 

According to EPA officials and stakeholders, the agency faces 
technical challenges to enforcing certain statutory provisions for 
nanomaterials in air, water, and waste. For example, some stakeholders 
told us that because fine particulates (particulates under 2.5 
micrometers in diameter) are already defined as a conventional air 
pollutant under the Clean Air Act,[Footnote 38] EPA could apply this 
conventional air pollutant standard to nanomaterials. However, EPA 
officials told us that while they could regulate nanomaterials under 
this standard, they do not yet have the technology needed to monitor 
particles of this size to enforce the standard. According to EPA and 
stakeholders, the agency may need to reassess how it measures 
pollutants under the Clean Air Act with respect to nanomaterials. This 
is because given the relatively small weight associated with 
nanomaterials, EPA may need to count particles or measure their 
surface area rather than weigh them, as the current air pollutant 
standard calls for. 

Similarly, according to some stakeholders, in order to enforce any 
technology-based effluent limitations for nanomaterials established 
under the Clean Water Act in the future, EPA would need to identify 
technology that can reliably and economically measure these materials 
in effluents, which it does not currently have.[Footnote 39] 
Similarly, EPA may face challenges in regulating nanomaterials in 
waste under RCRA because the tests used to establish the hazards of 
waste in general may be inadequate to characterize the hazards of 
nanomaterials. For example, according to some stakeholders, to the 
extent that nanoparticles behave in significantly different ways than 
larger-scale particles in soil, groundwater, and drinking water, EPA's 
assumptions under current testing procedures may not fully assess how 
toxic wastes containing nanomaterials might affect groundwater. 

In regulating nanomaterials, EPA also faces challenges attributable to 
volume-based thresholds and special conditions, such as waste coming 
from households, that trigger application of air, water, and waste 
laws and regulations. For example, EPA exempts household waste from 
RCRA hazardous waste regulation because it is impractical to regulate 
individual households. Moreover, EPA officials told us that landfill 
liners, as described in EPA's criteria for municipal solid waste 
landfills under RCRA, are sufficient to handle the small amounts of 
hazardous waste that end up in municipal landfills as a result of the 
household hazardous waste exemption. However, some stakeholders argue 
that until the risks of nanomaterials are better understood, it will 
not be known whether the landfill liners are sufficient to address the 
potential risks of nanomaterials that might be present in household 
waste. An example of a volume-based threshold issue arises under the 
Emergency Planning and Community Right to Know Act.[Footnote 40] EPA 
has set thresholds in the regulations implementing hazardous chemical 
inventory reporting requirements under these provisions that may not 
establish a threshold that is appropriate for nanomaterials. For 
example, the regulations include a default inventory reporting 
threshold for releases of 500 pounds for extremely hazardous 
substances and releases of 10,000 pounds for other hazardous 
chemicals. Stakeholders question whether these thresholds may be too 
high in the context of nanomaterials. EPA can set the thresholds lower 
than the defaults and has, for example, reduced the default threshold 
for some specific extremely hazardous substances to 1 pound. However, 
it has not yet done so for any nanomaterials. 

In addition to the challenges that EPA faces in regulating 
nanomaterials under air, water, and waste statutes, the agency may 
also be missing certain opportunities for gathering information on 
nanomaterials under the Clean Water Act. For example, EPA may not be 
collecting all available data on nanomaterials discharged into water. 
EPA has authority under the Clean Water Act to require owners or 
operators of facilities discharging pollutants to keep records, report 
information, monitor and sample discharges, and provide other 
information that EPA may reasonably require to carry out the act. The 
act also gives EPA the authority to inspect facilities and review 
records.[Footnote 41] According to stakeholders, at least one court 
has interpreted this authority broadly, upholding as reasonable an EPA 
permit requirement directing an applicant to disclose all toxic 
pollutants used or produced in the facility.[Footnote 42] Thus, 
stakeholders pointed out that EPA was able to obtain information not 
only on toxic pollutants that were in fact being discharged from a 
facility, but on those that had the potential to be discharged as 
well. Stakeholders concluded that even if EPA cannot currently measure 
nanomaterial discharges or cannot impose monitoring requirements on 
facilities, the agency has the ability to obtain information on the 
potential for nanomaterial discharge by a facility. 

Other National Authorities Are Collecting Information on Nanomaterials 
and Are Evaluating Their Legislation to Ascertain if Changes Are 
Needed: 

Australia and the United Kingdom have undertaken a voluntary approach 
to collecting information on nanomaterials while Canada plans to 
require companies to submit certain data. In contrast, the European 
Union collects data on all chemicals being produced at a certain 
volume as required by its basic chemicals legislation, which also 
includes nanomaterials. All of these entities are reviewing their 
existing legislation to determine the need for additional regulatory 
authority to specifically address nanomaterials.[Footnote 43] 

Australia Has Asked Companies to Voluntarily Provide Information on 
Nanomaterials and Is Currently Reviewing Comments on Proposed 
Legislative and Regulatory Changes: 

Australia's National Industrial Chemicals Notification and Assessment 
Scheme (NICNAS)--the government's regulatory body for chemicals--has 
issued two requests for companies to voluntarily provide information 
on nanomaterials but, like the U.S. experience, these requests have 
produced limited results. In February 2006, NICNAS issued a voluntary 
request for information from industry on the uses and quantities of 
nanomaterials being manufactured or imported into the country. 
Nanomaterials used exclusively in certain products, such as sunscreens 
and food additives, among others, do not fall within the scope of 
NICNAS and were consequently outside the request for information. Data 
requested included chemical and trade name, molecular formula, and 
estimates of total quantity imported or manufactured, and NICNAS did 
not request data on nanomaterial toxicity. Companies supplied 
information on 21 types of nanomaterials, 17 of which were available 
for commercial use. The largest group of nanomaterials reported was 
metal oxides, which are used in surface coatings, water treatment, 
cosmetics, and catalysts. In October 2008, Australia expanded the 
information requested in 2006 when it initiated a second request for 
information that targeted all manufacturers or importers of 
nanomaterials or products containing nanomaterials for commercial or 
research and development purposes. The second request was for 
companies to identify what data they have on their nanomaterials' 
toxicological properties, while not requiring the data be provided to 
NICNAS. The request also stipulated that no new data needed to be 
generated. Although information was due to NICNAS by the end of 
January 2009, the results of this request have not yet been made 
public. 

In addition to collecting information, NICNAS announced in fall 2009 
that it is reviewing Australia's legislative framework and 
administrative practices to ensure that any potential risks from 
nanomaterials are adequately identified and appropriately managed. A 
2008 review by an Australian university determined that Australia's 
regulatory frameworks should be reviewed to ensure that the risks 
posed by nanotechnology are better managed.[Footnote 44] The following 
are areas, among others, that were identified for review by the report. 

* Classification of nanomaterials as new or existing. Uncertainty 
exists as to whether the nano-form of a chemical is considered new or 
an existing chemical under current legislation. The NICNAS new 
chemicals program--for chemicals not listed on the national inventory--
currently applies to nanomaterials and allows for them to be assessed 
before commercial use. However, nanoscale versions of existing 
chemicals--chemicals already on the national inventory--can legally be 
introduced and used without notification to NICNAS. 

* Weight or volume. Some Australian regulatory requirements are 
currently triggered by weight or volume. For nanomaterials, weight or 
volume thresholds may not be meaningful because current production 
levels of nanomaterials are too low to trigger the threshold and not 
enough is known about the appropriate threshold levels. 

* Risk assessment protocols. It is uncertain whether risk assessment 
methods currently being employed by various regulatory agencies are 
suitable for goods that contain nanomaterials. Such uncertainties 
reduce confidence in the results of assessments. 

To address these areas of concern, Australia's NICNAS has proposed a 
range of reforms, including removing nanomaterials from certain 
exemptions and potentially requiring nanomaterials based on 
conventionally scaled existing chemicals to go through the new 
chemicals review program. Public comment on these proposals closed on 
February 12, 2010, but the results of these comments have not yet been 
made public. 

The United Kingdom Has Asked Companies to Voluntarily Report Certain 
Data on Nanomaterials and Is Currently Reviewing Whether Legislative 
Changes Are Needed: 

The United Kingdom launched a voluntary reporting scheme for 
nanomaterials in 2006 that targeted manufacturers, importers, and 
users and that also resulted in the collection of limited information. 
This effort focused on free nanomaterials--nanomaterials not enclosed 
in other materials--because they were identified as having greater 
potential for environmental exposure. Information requested included 
chemical identity; dimensions and shape; size range; predictions of 
surface area; uses; available toxicological data; and certain physical 
and chemical characteristics, such as water solubility, stability, and 
flammability. As of July 2007, the United Kingdom had only received 
nine responses to its voluntary reporting scheme. 

Regarding legislation, the United Kingdom commissioned reviews of the 
adequacy of existing legislation for each of its key regulatory 
departments to assess whether current regulatory frameworks are 
adequate to address the potential risks posed by nanomaterials. In 
general, these reviews concluded that the current regulatory 
framework, while broadly sufficient, has the potential for 
nanomaterials to fall outside of regulatory controls in certain 
circumstances, such as regulations with production volume or mass 
thresholds developed in the context of macroscale materials. The 
review also found that certain consumer products containing 
nanomaterials may be found safe for consumer use, but that risk 
assessments may not consider the full product life cycle, including 
its disposal. Consequently, in June 2009, the United Kingdom 
recognized that there may be a need to adjust existing systems to 
create a more integrated approach to address risks from nanomaterials. 
The United Kingdom is currently considering these issues as it 
develops its strategy on nanotechnologies. 

Canada Is Drafting a Requirement That Companies Provide Information on 
Nanomaterials and Plans to Review the Data Collected before Proposing 
Any Regulatory Changes: 

Canadian officials have proposed but have not implemented a one-time 
requirement for companies to provide information on nanomaterials 
produced in or imported into Canada. Canadian importers and 
manufacturers would be required to report their use of nanomaterials 
produced or imported in excess of 1 kilogram. In 2009, Canadian 
officials reported to the OECD that information required would include 
chemical and trade name; molecular formula; and any available 
information on the shape, size range, structure, quantity imported or 
manufactured, and known or predicted uses. Also required would be any 
available information on the nanomaterial's physical and chemical 
properties--such as solubility in water and toxicological data, among 
others. Under the proposal, companies could claim information as 
confidential, but regulators would publish a summary of information 
provided. Canada plans to use this information to help develop a 
regulatory framework for nanomaterials and to determine which 
information requirements would be useful for subsequent risk 
assessments. Canadian officials stated they originally hoped to issue 
this requirement in the spring of 2009 but could not predict when it 
would be implemented. 

With regard to current law, a report prepared for the government of 
Canada in 2008 stated that Canada has no specific requirements for 
nanomaterials and is considering whether they are needed. However, 
Health Canada and Environment Canada--two agencies responsible for 
health and the environment--have taken the first steps in recognizing 
the potentially unique aspects of nanomaterials. These regulatory 
agencies are currently relying on existing authority delegated to them 
through legislation, such as the Canadian Environmental Protection 
Act, to address nanomaterials. Specifically, in June 2007, Environment 
Canada released a new substances program advisory announcing that 
nanomaterials will be regulated under the act's new substances 
notification regulations. Per this advisory, any nanomaterial not 
listed on Canada's chemical inventory--the Domestic Substances List--
or with "unique structures or molecular arrangements" compared to 
their non-nano counterparts, requires a risk assessment. A review 
panel of the Canadian Academies found that, while it is not necessary 
to create new regulatory mechanisms to address the unique challenges 
presented by nanomaterials, the existing regulatory mechanisms could 
and should be strengthened in a variety of ways, such as by creating a 
specific classification for nanomaterials and by reviewing the 
regulatory triggers that prompt review of the health and environmental 
effects. 

The European Union Is Considering Revising Its Chemicals Legislation 
to Better Address Nanomaterials, and Is Requiring Labeling of 
Nanomaterials in Certain Products: 

The European Union passed its chemical legislation in 2007, known as 
Regulation, Evaluation and Authorization of Chemicals (REACH), 
[Footnote 45] under which the European Union generally collects 
information on all chemicals. However because REACH requirements apply 
to chemicals with a production volume of greater than 1 metric ton per 
year, some stakeholders have expressed concern that the provisions of 
REACH will not identify the risks of most nanomaterials because 
companies do not produce these materials at this level or volume. 
Because of this concern, the European Union is reviewing whether the 
provisions of REACH need to be modified to take into consideration the 
unique properties of nanomaterials by, for example, adjusting the 
volume-based thresholds. This review is ongoing, according to official 
EU reports, and is not scheduled for completion until 2012. 

In addition to efforts under REACH, the European Union has developed a 
regulation to require labeling on certain types of products containing 
nanomaterials. For example, a European Union Cosmetics Regulation will 
require cosmetic products that contain nanoscale ingredients to be 
labeled as such. The regulation would also require the manufacturers 
of new cosmetic products containing nanomaterials to notify regulators 
and provide them with certain safety information. Manufacturers of 
products containing nanoscale ingredients already being sold in the 
European Union also would have to notify regulators and submit certain 
safety information. In addition, the regulation requires all 
nanomaterial ingredients be clearly indicated in the list of 
ingredients and the names of such ingredients shall be followed by the 
word "nano" in brackets. The regulation also calls for the European 
Commission to compile a publicly available catalogue of all 
nanomaterials used in cosmetic products placed on the market, 
including those used as colorants, UV filters, and preservatives. 
Although this regulation was published in November 2009, its 
provisions are not scheduled to go into effect until July 2013. 

In addition to the Cosmetics Regulation, the European Union has also 
begun to regulate nanomaterials in food. Specifically, in January 
2010, revised regulations on food additives went into effect. The 
regulations clarify that when there is a change in the particle size 
of a previously approved food additive, a new approval is required 
before the additive goes to market. The European Union is also 
considering an update to its regulations on novel foods--foods or 
ingredients not widely consumed by people prior to 1997--that includes 
measures to regulate manufactured nanomaterials in food. Specifically, 
the proposed update would require that all foods containing 
manufactured nanomaterials undergo premarket authorization. 

Some State and Local Governments Have Begun to Address the Risks of 
Nanomaterials: 

Some U.S. states and localities have begun to address the potential 
risks from nanomaterials by, for example, issuing requests for 
information. Specifically, in January 2009, California required 
companies that manufacture or import carbon nanotubes into the state 
submit certain readily available data on these materials to the 
California Department of Toxic Substances Control by January 22, 2010. 
California officials told us that carbon nanotubes are an important 
category of emerging nanomaterials for which data on toxicity, 
physiochemical properties, and environmental fate and transport are 
largely unavailable. California posted the 22 responses it received on 
its Web site, as well as the names of companies that failed to 
respond. In addition, California environmental officials said they are 
now considering whether to conduct additional information requests on 
nanoscale forms of metal oxides, including nano aluminum oxide, nano 
silicon dioxide, nano titanium dioxide, and zinc oxide, as well as 
nanosilver, nano zerovalent iron, and nano cerium oxide. According to 
stakeholders we spoke with, environmental officials in other states 
have also considered similar information requests. For example, in 
2009, some Wisconsin state legislators called for a study on the 
feasibility of creating a nanotechnology registry and the development 
of subsequent legislation. 

In addition to states, some municipalities have considered collecting 
information on nanomaterials. For example, in December 2006, the City 
of Berkeley, California, issued a hazardous materials ordinance that 
requires companies to report the manufacture or use of nanomaterials. 
According to stakeholders we spoke with, this was the first time a 
U.S. city took such an approach. Berkeley's ordinance requires that 
facilities that manufacture or use nanoparticles submit a separate 
written disclosure of the material's known toxicology and how the 
facility will safely handle, monitor, contain, dispose, track, and 
mitigate the risks of such materials. Cambridge, Massachusetts, also 
considered implementing a similar ordinance but has not done so yet. 

Several state environmental officials told us they have considered 
whether their states' current regulations provide enough authority to 
address the risks of nanomaterials. For example, environmental 
officials in California told us they planned to review the data 
gathered under their requests for information to determine if 
additional action is needed. According to a report issued by the 
Environmental Council of the States, [Footnote 46] other states are 
taking some preliminary actions with regard to nanomaterials. 
Specifically, 

* Maine officials developed an Air Toxics Priority List in July 2007 
that includes particulate matter from nanotechnology, 

* the Massachusetts Department of Environmental Protection identified 
nanomaterials as an emerging contaminant of concern and established an 
Interagency Nanotechnology Committee, 

* the Washington State Department of Ecology considers nanomaterials 
to be an emerging contaminant of concern and has revised its manual 
for hazardous waste inspectors to include specific information on 
nanomaterials, and: 

* Pennsylvania and South Carolina have identified nanoparticles as 
contaminants of concern. 

The report identified nanomaterials, among other substances, as 
emerging contaminants of concern.[Footnote 47] The report specifically 
requested that federal agencies consider nanomaterials as a special 
class of emerging contaminants due to properties that may make them 
behave in ways that conventional-scale contaminants do not. In 
addition, the report identified a number of states that are taking 
some preliminary actions with regard to nanomaterials. 

Conclusions: 

The use of nanomaterials in products is growing faster than our 
understanding of the risks these materials pose to human health and 
the environment. While EPA has taken steps to improve our 
understanding of these risks, such as by asking companies to 
voluntarily provide information on the nanomaterials they produce, the 
information gathered through these efforts has been limited and does 
not provide a strong foundation for understanding the increasing 
potential for exposure to these materials as their uses become more 
prevalent. EPA has taken some regulatory action with regard to 
nanomaterials under TSCA and has developed plans to take further 
action with regard to information collection and testing of 
nanomaterials. However, these changes have not yet gone into effect 
and products may be entering the market without EPA review of 
available information on their potential risk. Moreover, although EPA 
requires chemical companies to periodically provide certain 
information on many of the chemicals currently in commerce, EPA has 
not extended this requirement to nanomaterials. Thus, EPA may be 
missing the opportunity to gather some additional information on 
nanomaterials from the regulated community. Furthermore, although EPA 
is taking steps to regulate pesticides containing nanomaterials, it 
has not clearly stated this to manufacturers, and the current data 
requirements do not require companies to specify whether any materials 
in their pesticides are nanoscaled. 

EPA also may be missing the opportunity to gather some additional 
information on potential discharges of nanomaterials from the 
regulated community. We acknowledge that EPA faces technical 
challenges in its research and regulatory efforts caused in part by a 
lack of tools and models to help generate information on the potential 
risks; however, better use of existing environmental statutes, such as 
the Clean Water Act, may enable EPA to collect useful information on 
nanomaterials. 

Recommendations for Executive Action: 

We recommend that the Administrator of EPA, take the following three 
actions: 

* Complete its plan to issue a Significant New Use rule for 
nanomaterials. 

* Modify FIFRA pesticide registration guidelines to require applicants 
to identify nanomaterial ingredients in pesticides. 

* Complete its plan to clarify that nanoscale ingredients in already 
registered pesticides, as well as in those products for which 
registration is being sought, are to be reported to EPA and that EPA 
will consider nanoscale ingredients to be new. 

In addition, the Administrator of EPA should make greater use of the 
agency's authorities to gather information under existing 
environmental statutes. Specifically, EPA should: 

* complete its plan to use data gathering and testing authorities 
under TSCA to gather information on nanomaterials, including 
production volumes, methods of manufacture and processing, exposure 
and release, as well as available health and safety studies; and: 

* use information-gathering provisions of the Clean Water Act to 
collect information about potential discharges containing 
nanomaterials. 

Finally, the Administrator of EPA should consider revising the 
Inventory Update Rule under TSCA so that it will capture information 
on the production and use of nanomaterials and so that the agency will 
receive periodic updates on this material. 

Agency Comments: 

We provided EPA a draft of this report for review and comment. EPA 
concurred with the report's recommendations and stated that the 
recommendations are consistent with the agency's approach to 
effectively managing nanoscale materials. EPA's comments are 
reproduced in appendix II. In addition, EPA provided technical 
comments, which we incorporated into the report as appropriate. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
appropriate congressional committees, the Administrator of EPA, and 
other interested parties. The report will be available at no charge on 
the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or mittala@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made key contributions 
to this report are listed in appendix III. 

Sincerely yours, 

Signed by: 

Anu K. Mittal: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives for this review were to (1) identify examples of 
current and potential uses of nanomaterials, (2) determine what is 
known about the potential human health and environmental risks from 
nanomaterials, (3) specifically assess actions the Environmental 
Protection Agency (EPA) has taken to better understand and regulate 
nanomaterials as well as its authorities to do so, and (4) identify 
approaches that selected national authorities have taken to address 
the risks associated with nanomaterials. In addition, you asked us to 
identify any U.S. states and localities that may have begun to address 
risks from nanomaterials. 

To identify examples of current and potential uses of manufactured 
nanomaterials, we analyzed documents and reports created by 
stakeholders, including synthesis studies, databases of nanotechnology-
related products, and Web sites that compiled and analyzed 
nanotechnology-related products from various sources. We identified 
the documents and reports (1) through interviews with knowledgeable 
stakeholders, (2) through open source research, and (3) from a 
literature search. Because of the dynamic nature of nanotechnology, we 
used only documents published since 2005. We also sought reports that 
sorted the current and potential uses of nanomaterials into broad 
categories, so that our report would not exclude any major industry 
sectors. We analyzed the information, compared the sets of industry 
sectors used in various reports to each other, and created a list of 
eight industry sectors that in our estimation reflected the breadth 
and depth of the commercial market for products enabled by 
nanomaterials. We selected specific examples within each sector for 
further analysis. Because assembling a comprehensive catalog of uses 
would be difficult in an evolving, dynamic industry, our list of 
examples is not comprehensive but rather was selected in a manner that 
allowed us to convey the wide spectrum of materials in current use, or 
which could be in use in the future, across a large range of products. 
In addition, we interviewed cognizant agency officials from the top 
six agencies conducting nanotechnology-related research. These six 
agencies accounted for over 95 percent of federal nanotechnology 
research reported in fiscal year 2009.[Footnote 48] We also 
interviewed knowledgeable stakeholders, including officials from the 
National Nanotechnology Initiative, the Woodrow Wilson International 
Center for Scholars' Project on Emerging Nanotechnologies, Lux 
Research--an independent research firm that conducts market analysis 
of nanotechnology, among other things--and the NanoBusiness Alliance--
a nanotechnology related business association. To identify 
knowledgeable stakeholders, we used an iterative process, often 
referred to as "snowball sampling," in which we asked our initial 
interviewees to identify others we should talk to, and we selected for 
interviews those who would provide us with a broad range of 
perspectives on the current and potential uses of nanomaterials. 

To determine what is known about the potential human health and 
environmental risks of nanomaterials, we reviewed documents that had 
been published by peer-reviewed journals, government agencies, and 
international nonprofit organizations. In conducting this review, we 
searched databases, asked knowledgeable stakeholders to identify 
relevant studies, and reviewed studies from article bibliographies to 
identify additional sources of information on the potential risks. 
Because of the importance of using the most current risk-related 
research, the team used only documents published since 2005. Of the 
over 700 documents we identified published between 2005 and 2010, we 
narrowed our review to 140. Of these, we selected 20 for more detailed 
analysis. We selected these documents in large part because they 
provided a synthesis of available research related to nanomaterials 
risks and they covered a variety of nanomaterials. To assess the 
credibility, reliability, and methodological soundness of these 
publications, a senior GAO technology analyst reviewed each of the 
publications and considered such factors as the bibliographies of 
evidence cited and the location of where the articles were published. 
We did not examine the references cited by these studies as part of 
our analysis. We concluded that all 20 reviews were sufficiently 
reliable for the purposes of this report. For the purposes of this 
review, all the documents, studies, and syntheses we reviewed will be 
referred to in our report as "studies." We also spoke with a variety 
of knowledgeable stakeholders representing government, industry, 
academia, nongovernmental organizations, and the regulatory community. 
These knowledgeable stakeholders were also selected using a snowball 
sampling method. 

To assess actions EPA has taken to better understand and regulate 
nanomaterials and its authorities to do so, we analyzed selected laws 
and regulations, including the Toxic Substances Control Act of 1976; 
the Federal Insecticide, Fungicide, and Rodenticide Act; the Clean Air 
Act; the Clean Water Act; the Resource Conservation and Recovery Act; 
and the Comprehensive Environmental Response, Compensation, and 
Liability Act. We also reviewed data and reports on EPA's Nanoscale 
Materials Stewardship Program, which EPA developed to encourage 
companies to voluntarily develop and submit information to EPA on the 
characteristics of nanomaterials. We interviewed and obtained 
documentation from agency officials responsible for implementing these 
laws in EPA's Office of Air and Radiation, Office of Pollution 
Prevention and Toxic Substances, Office of Pesticide Programs, Office 
of Solid Waste and Emergency Response, and Office of Water. We also 
interviewed and obtained documentation from staff in EPA's Office of 
Research and Development. Furthermore, we consulted with knowledgeable 
stakeholders and legal experts to obtain their perspectives on EPA's 
available authorities to regulate nanomaterials. 

To determine which national authorities had recently addressed 
nanomaterials, we interviewed knowledgeable stakeholders, including 
EPA officials who participated in working groups within the 
Organisation for Economic Co-operation and Development to identify 
candidate national authorities. We selected a judgmental sample of 
four countries for our review based on the following criteria: (1) EPA 
officials agreed that these countries have robust environmental 
regulations that were comparable to US regulations and (2) the 
countries had recently taken action with regard to nanomaterials, 
including considering to regulate nanomaterials. Based on this, we 
selected Australia, Canada, the United Kingdom, and the European 
Union. To identify the approaches these national authorities have used 
to address the potential risks associated with nanomaterials, we 
analyzed these authorities' laws and regulations that would be 
applicable to regulating nanomaterials, reviewed reports that other 
organizations had conduced of these countries' laws as they pertain to 
nanotechnology, and supplemented our understanding with interviews 
with knowledgeable stakeholders and legal experts. 

To identify any states or local governments that may be taking action 
with regard to nanomaterials, we interviewed with knowledgeable 
stakeholders including EPA officials, representatives from 
environmental organizations, and the Environmental Council of States-- 
a nonpartisan association of state environmental officials. We 
collected and analyzed documentation on these activities and 
supplemented our analysis with interviews with selected state 
officials. 

[End of section] 

Appendix II: Comments from the Environmental Protection Agency: 

United States Environmental Protection Agency: 
Office Of Chemical Safety And Pollution Prevention: 
Washington, D.C. 20460: 

May 4, 2010: 

Anu Mittal, Director: 
Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW, Room HQ 2T31: 
Washington, D.C. 20548: 

Dear Ms. Mittal: 

Thank you for the opportunity to review the U.S. Government 
Accountability Office's (GAO's) draft report entitled Nanotechnolov: 
Nanomaterials Are Widely Used in Commerce, but EPA Faces Challenges in 
Regulating Risk (GA0-10-549). We appreciate and concur with GAO's 
recommendations, which are consistent with the Agency's approach to 
effectively managing nanoscale materials. 

We note GAO's acknowledgement that there are unanswered questions 
about the potential risks of nanoscale materials to human health and 
the environment. The same special properties that make nanoscale 
materials useful are also properties that may cause some nanoscale 
materials to pose potential risks to humans and the environment. At 
this point, not enough information exists to fully assess these risks. 
EPA will need a sound scientific basis for assessing and managing any 
unforeseen future impacts resulting from the introduction of nanoscale 
materials into the environment, as well as informing material design 
and use decisions that avoid or reduce risk. A challenge for 
environmental protection is to help fully realize the societal 
benefits of nanotechnology while identifying and minimizing any 
adverse impacts to humans or ecosystems from exposure to nanoscale 
materials. The growing diversity and complexity of the types and uses 
of nanoscale materials available and being developed presents 
challenges in evaluating risks associated with the manufacture and use 
of these materials. 

As noted in the GAO report, this understanding will come from 
environmental research and development activities. EPA is heavily 
involved in efforts to understand the potential risks to humans, 
wildlife, and ecosystems from exposure to nanomaterials. Through 
innovation and discovery, scientists are studying the unique 
properties of nanomaterials, determining their potential impacts, and 
developing approaches to evaluate and prevent any risks. They are also 
exploring how nanomaterials can be used effectively to clean up 
contaminants released into the environment. With the use of 
nanotechnology in the consumer and industrial sectors expected to 
increase significantly in the future, nanotechnology offers society 
the promise of major benefits. The challenge for environmental 
protection is to ensure that, as nanomaterials are developed and used, 
unintended consequences of exposures to humans and ecosystems are 
prevented or minimized. 

The recommendations contained in the GAO draft report are consistent 
with the Agency's approach to effectively managing nanoscale materials 
and we accept them. Below are comments on each of the recommendations 
found in the draft report. 

EPA Response to GAO's Recommendations for Executive Action: 

We recommend the Administrator, EPA, take the following actions: 

* Complete its plan to issue a Significant New Use Rule for 
nanomaterials. 

EPA agrees. EPA will continue to issue SNURs for nanoscale materials 
that are new chemical substances on a case-by-case basis, as 
appropriate, and intends to propose a SNUR for nanoscale materials 
that are existing chemical substances by December 2010. 

* Modify FIFRA pesticide registration guidelines to require applicants 
to identify nanomaterial ingredients in pesticides. 

EPA agrees and intends to clarify that, as part of the application for 
registration, applicants for pesticide registrations which contain 
nanomaterial ingredients need to specifically identify those 
ingredients. 

* Complete its plan to clarify the FIFRA guidelines to make clear that 
already registered pesticides that have been reengineered to include 
nanomaterials need to obtain an amended registration. 

EPA agrees and is working on clarification of registrant's 
responsibilities under FIFRA with respect to nanomaterials. 

In addition, GAO recommends the EPA Administrator should make greater 
use of its authorities to gather information under existing 
environmental statutes. Specifically, GAO recommends EPA should: 

* Complete its plan to use data gathering authorities under the Toxic 
Substances Control Act (TSCA) to gather information on nanomaterials, 
including production volumes, methods of manufacture and processing, 
exposure and release, as well as available health and safety studies. 

EPA agrees and intends to propose a section 8(a) information gathering 
rule as described in the recommendation and also intends to propose a 
section 4 test rule. 

* Use information gathering provisions of the Clean Water Act to 
collect information about potential discharges containing 
nanomaterials. 

The Agency agrees that collecting information about discharges is a 
critical component of understanding potential environmental risks. 
EPA's Office of Research and Development, and others, is conducting 
research to determine whether nanomaterials may enter the water in 
forms and levels of concern, as well as how to detect and monitor 
nanomaterials in effluents and aquatic systems. Once we have these 
capabilities, EPA will consider whether new reporting requirements 
should be applied to companies who may be discharging nanomaterials 
into the environment, including under the Clean Water Act. 

* Finally, the EPA Administrator should consider revising the 
Inventory Update Rule under TSCA so that it will capture information 
on the production and use of nanomaterials and so that the Agency will 
receive periodic updates on this material. 

EPA agrees and will consider proposing periodic reporting under the 
Inventory Update Rule for nanoscale materials. 

Again, we appreciate the opportunity to review and comment on this 
drag report. Should you have any questions or concerns regarding this 
response, please contact Bob Trent, EPA's GAO Liaison Team Lead, at 
202-566-0983. 

Sincerely, 

Signed by: 

Stephen A. Owens: 
Assistant Administrator: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Anu Mittal, 202-512-3841 or mittala@gao.gov: 

Staff Acknowledgments: 

In addition to the contact person named above, Elizabeth Erdmann 
(Assistant Director), David Bennett, Antoinette Capaccio, Nancy 
Crothers, Cindy Gilbert, Gary Guggolz, Nicole Harkin, Kim Raheb, and 
Hai Tran made key contributions to this report. 

[End of section] 

Related GAO Reports: 

Food Safety: FDA Should Strengthen Its Oversight of Food Ingredients 
Determined to Be Generally Recognized as Safe (GRAS). [hyperlink, 
http://www.gao.gov/products/GAO-10-246]. Washington, D.C.: February 3, 
2010. 

Chemical Regulation: Observations on Improving the Toxic Substances 
Control Act. [hyperlink, http://www.gao.gov/products/GAO-10-292T]. 
Washington, D.C.: December 2, 2009. 

High-Risk Series: An Update. [hyperlink, 
http://www.gao.gov/products/GAO-09-271]. Washington, D.C.: January 22, 
2009. 

Federal Research: Opportunities Exist to Improve the Management and 
Oversight of Federally Funded Research and Development Centers. 
[hyperlink, http://www.gao.gov/products/GAO-09-15]. Washington D.C.: 
October 8, 2008. 

Highway Safety: Foresight Issues Challenge DOT's Efforts to Assess and 
Respond to New Technology-Based Trends. [hyperlink, 
http://www.gao.gov/products/GAO-09-56]. Washington, D.C.: October 3, 
2008. 

Nanotechnology: Accuracy of Data on Federally Funded Environmental, 
Health, and Safety Research Could Be Improved. [hyperlink, 
http://www.gao.gov/products/GAO-08-709T]. Washington, D.C.: April 24, 
2008: 

Nanotechnology: Better Guidance Is Needed to Ensure Accurate Reporting 
of Federal Research Focused on Environmental, Health, and Safety 
Risks. [hyperlink, http://www.gao.gov/products/GAO-08-402]. 
Washington, D.C.: March 31, 2008. 

Chemical Regulation: Comparison of U.S. and Recently Enacted European 
Union Approaches to Protect against the Risks of Toxic Chemicals. 
[hyperlink, http://www.gao.gov/products/GAO-07-825]. Washington, D.C.: 
August 17, 2007. 

21st Century Challenges: Reexamining the Base of the Federal 
Government. [hyperlink, http://www.gao.gov/products/GAO-05-325SP]. 
Washington, D.C.: February 2005. 

[End of section] 

Footnotes: 

[1] EPA is one of four key agencies that administer laws that regulate 
manufactured nanomaterials depending on how they are used. The other 
regulatory agencies include the Consumer Product Safety Commission, 
the Department of Health and Human Services' Food and Drug 
Administration, and the Department of Labor's Occupational Safety and 
Health Administration. We did not review these other agencies' 
regulatory authorities as part of this work. 

[2] In addition, EPA has authority under the Federal Food, Drug, and 
Cosmetic Act to establish tolerances or exemptions for the requirement 
of a tolerance for pesticide residues that remain in food. Food is 
considered adulterated if, amongst other conditions, it contains any 
residue of a pesticide chemical for which there is no tolerance or 
exemption or which exceeds any established tolerance. 

[3] These agencies are the Department of Defense, the Department of 
Energy, EPA, the Department of Health and Human Services' National 
Institutes of Health, the Department of Commerce's National Institute 
of Standards and Technology, and the National Science Foundation. 
These six agencies accounted for over 95 percent of federal 
nanotechnology research reported in fiscal year 2009. 

[4] Green chemistry, also known as sustainable chemistry, is the 
design of chemical products and processes that reduce or eliminate the 
use or generation of hazardous substances. Green chemistry can be 
applied across the life cycle of a chemical product, including its 
design, manufacture, and use. 

[5] Exercising foresight consists of basing policies on an 
understanding of forces shaping the future. In this context, a 
potentially significant trend is one that, although somewhat 
uncertain, may substantially affect progress toward basic goals across 
a time horizon more than 5 years forward. 

[6] GAO, Highway Safety: Foresight Issues Challenge DOT's Efforts to 
Assess and Respond to New Technology-Based Trends, [hyperlink, 
http://www.gao.gov/products/GAO-09-56] (Washington, D.C.: Oct. 3, 
2008). 

[7] GAO, 21st Century Challenges: Reexamining the Base of the Federal 
Government, [hyperlink, http://www.gao.gov/products/GAO-05-325SP] 
(Washington, D.C.: February 2005). 

[8] Rejeski, David, and Carly Wobig. 2002. Long-term Goals for 
Governments. Foresight 4, no. 6:14-22. 

[9] The Wilson Center is a nonpartisan research institution 
established by an act of Congress in 1968 and supported by public and 
private funds. The products in the Wilson Center's consumer products 
database are products identified as containing nanomaterials by their 
manufacturers or another source, which can be readily purchased by 
consumers, and for which the nanomaterials-based claims for the 
product appear reasonable. The NanoBusiness Alliance, an industry 
association representing the nanotechnology business community, 
estimates that thousands of additional products using nanomaterials 
are not publicized by their manufacturers. These products would 
therefore most likely not be counted in databases like the Wilson 
Center's database. 

[10] Carbon nanotubes are basically tubes that consist of rolled-up 
sheets of graphite. These materials have novel properties, including 
extraordinary strength and unique electrical conductivity. 

[11] Cerium oxide additives are already in use on a large scale in bus 
fleets in a number of countries including the United Kingdom, but 
their sale is not currently authorized in the United States. 

[12] A catalyst is a substance that increases the rate of a chemical 
reaction without being consumed by the reaction. 

[13] A polymer is a material made of long, chain-like molecules. 

[14] An ion is an atom or group of atoms that bears one or more 
positive or negative electrical charges. 

[15] A quantum dot is a nano-sized crystal that efficiently absorbs 
light and emits either photons or electrons. 

[16] A terabyte is about 1 trillion bytes or about 1,000 gigabytes. 

[17] Photoelectrolysis is the splitting of water into hydrogen and 
oxygen using light energy. 

[18] The Food and Drug Administration is generally responsible for 
overseeing the safety of color additives and foods, including food 
additives and dietary supplements, as well as for safety of food 
packaging. 

[19] Photocatalysis is the acceleration of a photoreaction in the 
presence of a photocatalyst. 

[20] The Food and Drug Administration is generally responsible for 
overseeing the safety and effectiveness of drugs and devices for 
humans and animals, and of biological products for humans. 

[21] The Food and Drug Administration is generally responsible for 
overseeing the safety of cosmetics. In addition, the U.S. Consumer 
Product Safety Commission is responsible for protecting the public 
from unreasonable risks of serous injury or death from more than 
15,000 types of consumer products, including some that may be 
manufactured with nanomaterials. 

[22] The routes of exposure listed are generally for incidental or 
consumer exposures to nanomaterials. For medical applications, the 
primary route of exposure is intravenous. 

[23] Some consumer products containing edible nanomaterials are 
available. Consumers may now purchase food containing nanomaterials 
such as prepared milkshakes containing nanoscale vitamins used to 
fortify the shakes. 

[24] The Occupation Safety and Health Administration is responsible 
for ensuring the safety and health of workers by setting and enforcing 
standards and encouraging continual improvement in workplace safety 
and health. 

[25] We selected six key statutes administered by EPA--TSCA, FIFRA, 
the Clean Air Act, the Clean Water Act, RCRA, and CERCLA--for the 
purpose of assessing actions EPA has taken to better understand and 
regulate the risks posed by nanomaterials as well as its authorities 
to do so. Also, as noted previously, EPA is one of four agencies that 
administers laws that regulate manufactured nanomaterials depending on 
how they are used. We did not review the other three agencies' 
regulatory authorities as part of this report, although we did 
identify nanomaterial uses that may be regulated by them. 

[26] EPA has been conducting research in ultrafine particulate matter, 
particularly in the air. In this research, EPA defines ultrafine 
particles as those less than 100 nanometers, making them nanoscaled. 

[27] The OECD is a forum for the governments of 30 developed countries 
to work together to address economic, social, and environmental issues. 

[28] The 14 nanomaterials that the OECD has selected for further 
review are aluminum oxide, carbon black, cerium oxide, dendrimers, 
fullerenes, iron nanoparticles, multiwalled carbon nanotubes, 
nanoclays, polystyrene, silicon dioxide, silver nanoparticles, single-
walled carbon nanotubes, titanium dioxide, and zinc oxide. 

[29] Allotropes are different forms of the same element in which the 
atoms are arranged differently. For example, graphite and diamond are 
allotropes of carbon. Isotopes are different forms of the same element 
that have different atomic weights because they have different numbers 
of neutrons. For example, helium-3, which has two protons and one 
neutron in its nucleus, is an isotope of helium. 

[30] The SNURs were originally issued as direct final rules--that is, 
they would go into effect without formal consideration of public 
comment after a certain period if EPA did not receive any adverse 
comments. Because EPA received a notice of intent to submit adverse 
comments, however, EPA withdrew the SNURs. When EPA proposed these 
rules again in November, it provided for a public comment period. 

[31] EPA plans to propose this rule under section 8(a) of TSCA. 

[32] Every 5 years, companies must report certain information on the 
production volume for chemicals they produced over 25,000 pounds at 
one location during that year. Companies must also report additional 
use information on chemicals that they produce over 300,000 pounds at 
one location. 

[33] EPA plans to propose this rule under section 4 of TSCA. 

[34] GAO, Chemical Regulation: Options Exist to Improve EPA's Ability 
to Assess Health Risks and Manage Its Chemical Review Program, 
[hyperlink, http://www.gao.gov/products/GAO-05-458] (Washington, D.C.: 
June 13, 2005). 

[35] The phrase "unreasonable adverse effects on the environment" 
means (1) any unreasonable risk to man or the environment, taking into 
account the economic, social, and environmental costs and benefits of 
the use of any pesticide, or (2) a human dietary risk from residues 
that result from a use of a pesticide in or on any food inconsistent 
with the standard for tolerance under the Federal Food, Drug, and 
Cosmetic Act. 7 U.S.C. § 136(bb) (2006). 

[36] In November 2008, a group of environmental and consumer 
organizations filed a petition asking EPA to regulate products 
containing nanosilver as pesticides. Petitioners included the 
International Center for Technology Assessment, the Center for Food 
Safety, Friends of the Earth, Greenpeace, the Center for the Study of 
Responsive Law, and the Consumers Union. 

[37] EPA may promulgate a rule designating a given material as a 
hazardous air pollutant if the material presents, or may present, 
through inhalation or other routes of exposure, a threat of adverse 
human health effects (including carcinogenicity, mutagenicity, 
neurotoxicity, reproductive dysfunction, or acute or chronic toxicity) 
or adverse environmental effects whether through ambient 
concentrations, bioaccumulation, deposition, or otherwise. 42 U.S.C. § 
7412(b)(2) (2006). 

[38] A conventional air pollutant is one that causes or contributes to 
air pollution that may reasonably be anticipated to endanger public 
health or welfare. There are five other conventional air pollutants in 
addition to particulates: they are ground-level ozone, carbon 
monoxide, sulfur oxides, nitrogen oxides, and lead. 

[39] An effluent limitation is a restriction on the discharge of 
pollutants from, for example, a factory, into the waters of the United 
States. 

[40] Under this act, covered facilities must submit an emergency and 
hazardous chemical inventory form to (a) the appropriate local 
emergency planning committee; (b) the state emergency response 
commission; and (c) the fire department with jurisdiction over the 
facility. 42 U.S.C. § 11022(a) (2006). 

[41] 33 U.S.C. § 1318 (2006). 

[42] NRDC v. EPA, 822 F.2d 104, 119 (D.C. Cir. 1987). 

[43] We selected a judgmental sample of four national authorities for 
our review, based on criteria such as countries that have recently 
taken action with regard to nanomaterials. 

[44] Monash University, Review of the Possible Impacts of 
Nanotechnology on Australia's Regulatory Frameworks (May 2008). 

[45] REACH's requirements are being phased in and will not be in full 
force until 2018. 

[46] The Environmental Council of the States is the national non- 
profit, non-partisan association of state and territorial 
environmental agency leaders. 

[47] Environmental Council of the States. State Experiences with 
Emerging Contaminants: Recommendations for Federal Action, January 
2010. 

[48] These agencies are the Department of Defense, the Department of 
Energy, EPA, the Department of Health and Human Services' National 
Institutes of Health, the Department of Commerce's National Institute 
of Standards and Technology, and the National Science Foundation. 

[End of section] 

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