Apparently, radical environmental groups and fake "consumer advocate" groups have joined hands to accellerate the ongoing campaign to have the EPA regulate all commercial forms of nanosilver, including colloidal silver, as a "new pesticide."

We received today an email from our good friend George Foss, a top nutritional supplement formulator and natural health watchdog, explaining that the Center for Food Safety (an elitist, pro-regulatory group masquerading as a "consumer advocacy" group) is now urging their readers to send comments to the EPA supporting the "Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”

This petition -- if accepted and acted upon by the EPA -- would essentially allow the EPA to regulate colloidal silver into oblivion, on the grounds that it could potentially cause harm to the environment. (See more on this issue below.)

Public Comments Soon to Be Closed

We also learned that public comments on this petition have been open for some time. But apparently only the rabid environmental groups and fake "consumer advocate" groups supporting the proposal have been told about the comment period, which ends January 20th. These pro-regulatory groups have been sending emails to their thousands of readers, urging them to go to a special web page they have set up where an automated system exists for submitting comments to the EPA en masse.

Unfortunately, this comment submission system only allows for comments from people who favor futher strict regulation of nanosilver by the EPA. Even if you use the system to send a comment against the proposal to regulate nanosilver as a "new pesticide," the system overrides your comment by superceding it with a "canned" favorable comment.

This means virtually all of the comments going to the EPA have been in favor of further regulation of nanosilver products.

Since EPA depends heavily upon public comments when deciding upon new regulatory action, it is vitally important that they get to hear the views of those who do not want to see nanosilver further regulated by the EPA as a "new pesticide."

Comments to the EPA will be closed as of January 20, 2009, so we have only a short time to act on this issue in order to save colloidal silver from being regulated into oblivion.

My Contact with the EPA

I picked up the phone this afternoon and called the EPA at the number under “Contact Us” on their web site (202-564-4700).

A very nice gentleman named “Peter” answered and I asked him how I could submit a comment on the nanosilver regulation issue, as their web site appears to offer no easy way to take and deliver such comments from the public.

He said to send comments by fax or email directly to the EPA Administrator, Mr. Stephen Johnson:

Email: johnson.stephen@epa.gov

Fax: 202-501-1450

Be sure to reference Docket # EPA-HQ-OPP-2008-0650.

Also, be sure to state that you are commenting in regards to the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”

I also found a page on the EPA web site that says comments can be sent by mail to the following address:

Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P)
Environmental Protection Agency

Washington, DC 20460-0001

Additionally, after much searching, I was able to figure out a way to post a comment to the EPA web site regarding the proposed regulations. I used this link, which I hope works for everyone else, too:

http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=09000064807cd9b1

Must Act Quickly and Decisively!

As quickly as possible we need to get the above contact information posted on as many relevant natural health internet forums as possible, and also circulated by email to all relevant people in the natural health industry.

Please do your part to help by referring as many "natural health" people as possible to this blog post.

The rabid environmentalists have had a huge head start on this issue, since they are the only ones who knew where to send comments to. And there is only a very short period of time left between now and January 20th to submit further comments.

Wild and Invalid Claims

As you may already know, the environmental groups and fake "consumer advocate" groups have been making wild and invalid claims about nanosilver for some time now, stating that it is in immediate need of EPA regulation due to its alleged potential to harm the environment.

Through deception and chicanery these groups have managed to convince the EPA to re-classify nanosilver as a "pesticide" under an obscure set of regulations known as FIFRA.

Now they are pressing the FDA to strictly enforce those regulations under the supposition that nanosilver products represents a dire threat to the environment.

Yet not one study to date – I repeat, not one study -- has ever demonstrated nanosilver to have harmed any part of the environment. Instead, only test tube and lab studies extrapolating its alleged negative effects on the environment have been conducted.

And for the most part, those studies have been conducted by researchers who were either hired by the environmental groups to demonstrate nanosilver’s alleged harmful environmental attributes, or by researchers specifically working to forward the agenda of these groups.

In other words, the so-called studies have been conducted by researchers who are predisposed to believe nanosilver is somehow harmful, or somehow represents a dire threat to the environment. They have been paid to demonstrate exactly that. This means the study outcomes are decided upon in advance, before the studies are even started. This is junk science at its worst.

Re-Defining NanoSilver to Include Colloidal Silver

What’s more, the environmental groups behind this drive to have nanosilver regulated into oblivion have re-defined the term “nanosilver” to include just about any commercial form of natural silver available on the market today, including ALL colloidal silver products.

In one of their petitions to the EPA demanding the regulation of nano-silver products, these groups have even named some of the top commercial colloidal silver brands on the market today (including Sovereign Silver, Meso-Silver, ASAP Colloidal Silver, Utopia Silver and more) as being in dire need of “regulation.”

So the whole thing reeks of a stealth campaign to have colloidal silver banned.

The Bottom Line

The bottom line is that silver has been in the environment for millions of years. In its natural state, bonded to other minerals and natural substances, it causes no harm to the environment whatsoever.

As commercially produced nanosilver returns to the environment it is very rapidly degraded as it agglomerates (i.e., bonds together) with natural minerals, salts and other natural environmental substances that in effect eliminate its commercial nano-scale attributes, as well as effectively neutralizing its so-called “potentially harmful pesticide qualities” (i.e., its ability to kill pathogens on contact).

So in reality, there is no threat to the environment whatsoever from nanosilver products.

Rigged Studies

The researchers who have ostensibly demonstrated harmful attributes of nanosilver on environmental life forms such as bacteria or tiny minnows used extremely high quantities of pure commercially produced nanosilver products in their lab studies.

In other words they used levels of nanosilver that would simply never be found in the environment, due to silver’s propensity to bond rapidly with a multitude of other minerals, salts and other substances and return to its natural state once back in the environment.

In short, the studies are bunk. They prove nothing. The reason the studies were conducted in the laboratory rather than in the actual environment is because it was already known what would have been demonstrated in an true environmental study. No environmental harm whatsoever would have been found.

But by doing lab studies under rigged conditions that could never be found in the environment itself, the environmentalist researchers were able to demonstrate exactly what they set out to demonstrate. In other words, these studies were a “fix” from the beginning, in my opinion.

My Comments to the EPA

Here is what I posted through the EPA web site comment submission system earlier today. Whether or not these comments actually get posted to the EPA web site is another story. We shall see. Nevertheless, I also intend to submit my comments through the EPA’s email and fax systems noted above, as well as through the U.S. mail at the address noted above.

Folks, we need to bombard EPA with comments against the proposal to further regulate nano-silver as a “pesticide,” just as the environmentalists have been bombarding them with comments in favor of the proposal. Here’s the comment I submitted:

To the Honorable Mr. Stephen Johnson, Administrator:

The idea that nanosilver needs to be regulated by EPA due to ostensilbe harm to the environment is ridiculous at face value.
No study has ever demonstrated nanosilver to have caused harm to the environment.

The only studies conducted have been laboratory studies that have extrapolated nanosilver's alleged environmental impact. These studies have completely ignored the fact that once returned to the environment nanosilver rapidly bonds with minerals, salts and other natural substances, forming non-nano scale conglomerate particulates, essentially returning the silver to its natural harmless state.

In other words, once returned to the environment it is no longer nanosilver. And it no longer has the attributes deemed harmful by the white coat lab researchers who have conducted their laboratory studies using nanosilver in its purest and most non-adulterated commercial form rather than looking at what actually happens to nanosilver once it returns to the environment.

By promoting lab studies that assume nanosilver somehow remains in its nano-scale commercial form once returned to the environment -- which is so demonstrably false as to be ludicrous -- the environmentalists behind the push to regulate nanosilver as a new “pesticide” have done EPA and the American public a grave injustice. They have created an environmental "crisis" where none exists.

If you carefully read the petitions and press releases put out by the environmental groups now petitioning EPA in regards to regulating nanosilver, you will see they are so full of unsupported speculations and weasel words (i.e., "might cause harm" "could impact the environment," "may be highly destructive") as to be laughable.

We respectively submit EPA ignore the rabid calls to regulate nanosilver being made by neo-Luddite environmentalist groups. It is simply and conclusively a non-issue, in terms of potential harm to the environment.

Silver has always been in the environment and always will be. And when commercially produced nanosilver is returned to the environment it does not in any way, shape or form retain its commercial nanosilver properties. This issue is therefore moot; it is the proverbial "much ado about nothing."

Respectfully,S. Spencer Jones

Positive Impact

Hopefully we can make some positive impact against the proposal to have EPA regulate nano-silver as an environmental contaminant. But we have only a short time to act. And if we fail to act we will likely see the demise of the entire colloidal silver market.