Bergeson & Campbell, P.C.

The Nuances of ‘Nano’ in Pesticide Products


On June 17, 2011, the U.S. Environmental Protection Agency released a much-anticipated notice describing possible approaches for obtaining information on the potential presence of nanoscale materials in registered pesticide products.

The EPA has repeatedly, and legitimately, expressed its need for information relating to the existence of nanoscale materials in the composition of registered pesticide products where the presence was unknown to the EPA at the time it registered the product. The need is driven in no small measure by concerns expressed by the International Center for Technology Assessment, a not-for-profit environmental group, relating to the inclusion of nanosilver and nanocopper in existing registered pesticide products.

The notice is much anticipated because the EPA’s previously expressed option of choice for collecting such information was a controversial interpretation of its authority under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) to require registrants to submit information under Section 6(a)(2), frequently referred to as the FIFRA “adverse effects” reporting provision.

While the notice is well written and reflects solid work on the EPA’s part, the agricultural and biocidal chemical community continues to be troubled with the unintended consequences of the use of FIFRA Section 6(a)(2) to obtain information and the inadvertent linking of “nano” material composition in pesticides with affects considered “adverse.”

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