American Bar Association (ABA)

ABA SEER CAA Nanotechnology Briefing Paper


Courtesy of American Bar Association (ABA)

In reviewing the statute, regulations, guidance, science, engineering, and technology utilized in implementing the Clean Air Act (CAA), the American Bar Association (ABA) Section of Environment, Energy, and Resources (SEER) CAA Nanotechnology Subcommittee developed this paper outlining possible application of the CAA to engineered nanoparticles (specifically excluding non-engineered nanoparticles, such as naturally occurring nanoparticles or nanoparticles from combustion sources). Several critical issues arise in this application. The most important issues are summarized in the following paragraphs.

First, the U.S. Environmental Protection Agency (EPA) must distinguish between types of nanoparticles, identifying nanoparticles posing actionable risk, and determining appropriate regulatory approaches for each type of nanoparticle requiring regulatory control. Nanoparticles exist in many forms in our environment today from natural and manmade sources, such as smoke, pollen, and viruses. For the first time, however, technology has developed sufficiently to allow the intentional engineering of structures with dimensions in the range of one to 100 nanometers, however. The almost infinite variety of nanostructures renders generalizations difficult and problematic, while the process of developing regulation addressing nanoparticle emissions requires caution to ensure proper priority is utilized in determining which types of nanoparticles require more conservative regulatory approaches.

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