The Nanotechnology Industries Association (NIA) has provided comments on California's Green Chemistry Proposed Regulation for Safer Consumer Products. A member of the California Nanotechnology Industry Network (CalNIN) Regulatory Committee, which includes the American Chemistry Council Nanotechnology Panel, California Manufacturer & Technology Association, the Semiconductor Industry Association, and SOCMA Nanotechnology Coalition, the NIA supported the CalNIN Network Regulatory Committee in the collation and submission of comments to the Safer Consumer Product Alternatives Regulation, proposed and published by the California Department of Toxic Substances Control (DTSC) on the 13 September 2010.
The CalNIN Regulatory Committee comments specifically calls for alignment of the definition of the term 'nanomaterial' with the relevant ISO publications (i.e. ISO/TS 27687, in order to achieve national and international harmonisation and facilitate interstate and international commerce. The comments particularly criticise on a scientific and technical basis the draft definition of nanomaterials up to one micron, and calls for greater clarity on the term 'nanoscale phenomena'. The CalNIN Regulatory Committee furthermore points out that the retention of the mass metric for both setting, implementation and demonstration of compliance with thresholds is critical to proposed regulations.
The comments furthermore call for consistency of policy approaches in California, specifically highlighting the recent initiative by the California Government Office of Environmental Health Hazard Assessment (OEHHA).
Registered NIA Members can download the full CalNIN Network Regulatory Committee comments. Members and non-members can follow these links to find out more about California DTSC Green Chemistry Initiative.