2010 Tauranga City Council / Western Bay of Plenty District Council Nano Waste 23-7-10

23 July 2010

The Councillors

Tauranga City Council and Western Bay of Plenty District Council

Willow Street cc District Health Board

TAURANGA

Submission to Councils on the draft plan developed by the Western Bay of Plenty District and Tauranga City Councils to provide a waste management plan in the western Bay of Plenty sub region over the next six years.

Physicians and Scientists for Global Responsibility (www.psgr.org.nz) is a Charitable Trust with a primary aim of researching and disseminating information in recognition of the public's right to be independently informed. We endorse the submission presented today by Jean Andeson.

We do not wish to speak to this submission.

Further to our letters of 7 February 2008 and 10 June 2008, our concern regarding nanotechnology and the handling of waste from its products remains.

The Joint Waste Assessment Report compiled by Western Bay of Plenty District and Tauranga City Councils does not include mention of nanotechnology or its waste.

We ask that Councils make definitive moves to ensure the best handling of the waste created in manufacturing products using nanotechnology and by nano-products used in the home.

While the number of applications of this technology on a global scale is currently modest, the industry is expanding very rapidly. There is, for example, an estimated 300 plus food products worldwide that involve nanotechnology: wrapping, processing, ingredients, etc. It proposed for products for domestic, agricultural, industrial, medical and other uses. This industry is looking to or already manufacturing faster computers, cell-specific drugs, sensors to monitor everything from crops to crooks to customers, stronger, lighter, smarter and more durable materials, and much more. Virtually without regulations or safety testing, these products are on the market.

In the Bay of Plenty area, “Nanokote” was advertised in the Bay News (26 May 2010; p.8); a nanoparticle, sprayed on, “Non-stick protective treatment for ALL glass” (www.nanokote.co.nz).

The Mitre Ten Mega mailbox flyer (15-28 July 2010) included the “Whitewash Sponge” at $3.98; a nanotechnology product that cleans brilliantly, but experience shows quickly disintegrates in use. Setting aside the potential health issues faced during use, PSGR asks what happens to the remnants of the sponge when tossed in the rubbish bin?

Nanotechnology is using raw materials that are the chemical elements of the Periodic Table, the building blocks of everything living and non-living. A Reuters1 report (18 August 2009) projects the nanotechnology market will reach one trillion dollars by 2015.

Nanotechnology refers to techniques used to engineer structures, materials and systems that operate at a scale of 100 nanometres or less. 'Nano' is a measurement; one nanometre (nm) is one billionth of a metre. A virus, for example, measures about 100 nm. Nanotechnology is the manipulation of matter at the scale of atoms and molecules; particles that can only be seen by the strongest microscopes and which can obviously go undetected.

The aim of nanotechnology is to create new materials and modify existing ones. Unfortunately, at the nanoscale the properties of a material can also change; posing both advantages and difficulties. This change is known as quantum effects where the normal laws of physics no longer apply. Materials can take on new properties: e.g.,. aluminium – as used for drink cans – at the nanoscale it can spontaneously combust; gold, which in bulk is inert, can bind to human DNA at the nanoscale. The surface area of nanoparticles also increases enormously as the particle size decreases. These properties make safe handling vitally important.

In an email from Robert Hickson, PSGR were told that the Ministry for Research, Science and Technology (MoRST): “...are currently reviewing the regulations that are relevant to nanomaterials in New Zealand. This includes looking at the Hazardous Substances and New Organisms Act, the Health & Safety in Employment Act, the Waste Minimisation Act, and a range of other pieces of legislation. The purpose of the review is to identify any significant gaps associated with the regulation of manufactured nanomaterials . . . We expect the report on this review to be made publicly available in August...” Further, “New Zealand is involved in international fora, such as the OECD, to help identify priorities for research and to develop standards for testing manufactured nanomaterials. Research organisations are investigating potential risks of some manufactured materials, and reviewing health and safety procedures associated with producing, handling and disposing of nanomaterials in laboratories. MoRST's position is that we need to remain aware and vigilant of developments in risk and regulatory issues associated with manufactured nanomaterials, and we are undertaking this by sharing information on nanotechnology developments with regulatory agencies. MoRST also sees a need to support capabilities here to detect, assess and manage manufactured nanomaterials. A range of research groups are investigating potential risks associated with nanomaterials.”

PSGR has asked to be kept up to date with developments. We suggest Councils do this also.

Despite the vigilance of MoRST, PSGR believes New Zealand Councils need to be accountable in their own districts and take a lead in the issue of nano waste (and handling the products of nanotechnology in the workplace).

We suggest Councils access www.ci.berkeley.ca.us/, enter nano waste in 'search' and, further, open communications with the City of Berkeley in California. The City of Berkeley was the first worldwide to address nano waste. Their guidelines are that all facilities manufacturing or using manufactured nanoparticles should submit a “disclosure of the current toxicology of the materials reported, to the extent known, and how the facility will safely handle, monitor, contain, dispose, track inventory, prevent releases and mitigate such materials.” A Risk Management Plan may also be required.

New Zealand has experienced volcanic eruptions, forest fires, and industrial and vehicle emissions and exhaust that produce natural nanoparticles which have adverse health effects. For example, a study found an increase in acute bronchitis in people living in the ash stream created by the 1996 eruption of Ruapehu.2 In the UK, in December 1952, at least 4000 Londoners died as a direct result of a four-day dirt-particle-filled fog (smog).3 Nanoparticles do occur naturally. Our concern here is with manufactured nanoparticles and their effect on the population and environment.

Most biological and medical literature on nanoparticles focuses on the application of the technology, and some research has been carried out on the toxicity of different types of manufactured nanomaterials. We know nanoparticles can pass through epithelial surfaces (skin, gastrointestinal, conjunctiva) and the endothelial barriers lining blood vessels. They can be inhaled, and they can pass through the blood-brain barrier. What has emerged is that there are effects at cellular level that could potentially affect humans and these effects could depend on the nanoparticle base material, its size and structure, and substituents and coatings.

A study published in the respected European Respiratory Journal (ERJ)4 followed reports in 2009 from China. Seven women, exposed to nanoparticles in an inadequately vented workplace, became seriously ill. Two subsequently died. Polyacrylate, consisting of nanoparticles, was confirmed in the workplace. Pathological examinations of the patients' lung tissue displayed nonspecific pulmonary inflammation, pulmonary fibrosis and foreign-body granulomas of pleura. Using transmission electron microscopy, nanoparticles were observed to lodge in the cytoplasm and caryoplasm of pulmonary epithelial and mesothelial cells, and in chest fluid. These cases arouse concern that long-term exposure to some nanoparticles without protective measures may be related to serious damage to human lungs.

It is feasible that exposure over lengthy periods to the likes of a cleaning product that disintegrates on use could affect the user; as would the projected increase in discarded nanoproducts entering the waste system uncontained and uncontrolled, possibly dispersed by wind, rain and human traffic.

PSGR maintains that insufficient attention has been given to research by government, national and local bodies responsible for food and environmental safety, including the handling of nano waste. For example, the reduction and treatment of industrial and agricultural wastes and groundwater remediation. We do not know if nanoparticles persist and accumulate in the environment, and what may happen ecologically. Scientists know how to handle nanomaterials in the laboratory with relative safety, although the size of nanoparticles pose distinct difficulties and make this especially hazardous. What needs to be looked at is how to handle manufacturing waste as well as the ordinary waste coming from homes and shops, and to do this urgently. We list some information for your convenience. These offer useful, but not conclusive material.

The 2009 Nanomaterial Research Strategy released by the US Environmental Protection Agency (EPA)5 talks about “the challenge for environmental protection” and “unintended consequences of exposures to humans and ecosystems” and detecting, monitoring, controlling and cleaning up pollution. It also wants to look at preventing and mitigating risks, but does not make definite reference to the 'waste' of nanoproducts. However, the EPA has directed the federal National Nanotechnology Initiative6 to coordinate research carried out by designated agencies on nanotechnology and associated issues. Progress should be monitored regularly.
In a press release (12 November 2008), UK the Royal Commission on Environmental Pollution, said: “Urgent action needed on the testing and regulation of nanotechnology.”7 It was released simultaneously with the 27th UK Royal Commission Report, “Novel Materials in the Environment: The case of nanotechnology.” This report contained topics it felt could be covered and did include: “waste issues: some products containing novel materials have a short lifespan and may not be recyclable.”8
Cefic, the European Chemical Industry Council has produced “Responsible Production and Use of Nanomaterials: Implementing Responsible Care®”.9
The German Chemicals Industry Association developed “Guidance for the Safe Recovery and Disposal of Waste Containing Nanomaterials.”10
In 2007, the New Zealand government released a 'Nanoscience and Nanotechnologies Roadmap' which gave strategic priority to nanotechnology-related research and policy: “New Zealand needs to take a considered approach to nanoscience and nanotechnologies (both at a research and policy level) so that maximum benefit can be derived from investments and the country is well placed to appropriately adapt or adopt nanotechnologies developed elsewhere.”11 A further report, undated - “Biotechnology and Nanotechnology in the Future” compiled by Robert Hickson, Senior Adviser (Bio–issues Forums) MoRST – covers the “pluses” of nanotechnology and does not mention the word “waste”.12 However, a report from MoRST - “Nanotechnology Here and Now, Proceedings from the conversations of the Workshop 23-24 April 2009” - acknowledges that “there is a significant absence of knowledge” about the waste materials from nano products.13

The precautionary principle suggests nano waste must be identified and disposed of safely. Waste could include: nanomaterials; items contaminated with and liquids containing nanomaterials; and nanomaterials that could be released when in contact with air, soil, water or chemicals, or when subjected to forces such as natural ground movement. This would include nanomaterials moulded into a solid that would not normally be expected to rid themselves of nanoparticles when handled or cut. Indeed, aggregated nanomaterials may not be mobile, nor have the same reactivity, but what happens when they eventually break down or become damaged? When thinking about how to manage nanomaterial waste, it may be important to examine the entire life cycle of nanomaterials from synthesis to disposal.

We know some nanomaterials have so far proven safe based on their use in, say, medical applications, but what of the waste from this usage, product wastage as well as nanoparticles finding their way into waste water. On the scale needed, we currently have no way of tracking nanoparticles in the environment, or removing them from soil or water or the human body. We do not know if being absorbed by soil may reduce bioavailability or whether nanomaterials could harm soil bacteria, the engine of the ecosystem and the food chain. Nanomaterials will break down over time, but we do not know how long will it take.

We urgently need eco-responsible, health-responsible design, handling and disposal of engineered nanomaterials. The conclusion of a US Army study14 that looked at fullerenes1 manufactured using nanotechnology emphasized “the need for a global review of nano-manufacturing wastes and low-purity products.”

In the meantime, there are few published government, national or local waste management “best practices” for nano waste materials. We need those bodies to take responsible action. We look forward to your reply and hearing what action Councils will take.

Signed by the Trustees of PSGR (www.psgr.org.nz)

Paul G Butler, BSc, MB, ChB, Dip. Obst. (Auckland), FRNZCGP, General Practitioner, AUCKLAND

Jon Carapiet BA (Hons), MPhil, Senior market researcher, AUCKLAND

Bernard J Conlon, MB, BCh, BAO, DCH, DRCOG, DGM, MRCGP (UK), FRNZCGP, General Practitioner, MURUPARA

Elvira Dommisse BSc (Hons), PhD, Mus.B, LTCL, AIRMTNZ, Scientist, Crop & Food Research Institute (1985-1993), working on GE onion programme, CHRISTCHURCH

Michael E Godfrey, MBBS, FACAM, FACNEM, Director, Bay of Plenty Environmental Health Clinic, TAURANGA

Elizabeth Harris MBChB, Dip.Obst, Cert. NZ Sports Med., Cert. Proficiency in Child Health, Cert. NZ Family Planning, Dip. Musculoskeletal Med., FRNZCGP, General Practitioner, DUNEDIN

Frank Rowson BVetMed, Veterinarian in a large animal practice, MATAMATA

Peter R Wills, BSc, PhD, Associate Professor, University of Auckland, AUCKLAND

Damian Wojcik BSc, MBChB, Dip.Theology, Dip. Obstetrics, Dip.Child Health (DCH), FRNZCGP, FIBCMT (USA), Director, Northland Environmental Health Clinic, WHANGAREI

Jean Anderson, Businesswoman retired, TAURANGA.

References

1. www.reuters.com/article/scienceNews/idUSTRE57I1Y720090819?sp=true;

http://2020science.org/2009/08/18/is-nanotechnology-posed-for-the-ride-of-its-life/

Is nanotechnology poised for the ride of its life? by Andrew Maynard on August 18, 2009

2. www.informaworld.com/smpp/content~content=a713671532&db=all

'Acute health effects of the Mount Ruapehu (New Zealand) volcanic eruption of June 1996', Jeremy

Hickling ; Mark Clements ; Philip Weinstein ;Alistair Woodward, Journal of Environmental Health

Research, Volume 9, Issue 2 June 1999 , pages 97 – 107.

3. http://en.wikipedia.org/wiki/Air_pollution, The Great Smog of 1952.

4. Eur Respir J 2009; 34:559-567 doi: 10.1183/09031936.00178308

'Exposure to nanoparticles is related to pleural effusion, pulmonary fibrosis and granuloma',

Y. Song, X. Li and X. Du, http://erj.ersjournals.com/cgi/content/abstract/34/3/559maxtoshow

=&hits=10&RESULTFORMAT =&fulltext=Nanotechnology&searchid=1&FIRSTINDEX=0&sorts

pec=relevance&resourcetype=H WCIT.

5. www.epa.gov/nanoscience/files/nanotech_research_strategy_final.pdf

6. www.nano.gov/.

7. www.rcep.org.uk/reports/27-novel%20materials/documents/Novel%20materials%20press

%20release.pdf.

8. www.rcep.org.uk/reports/27-novel%20materials/27-novelmaterials.htm

27th report: Novel Materials in the Environment: The case of nanotechnology (2008); The European Union, European Commission Research Directorate General: http:/europa.eu.int/comm/research/growth/gcc/ga01.htm.

9. http://webcache.googleusercontent.com/search?q=cache:KR-LulO8FIEJ: www.cefic.org/files/downloads/Cefic-RC-Guidelines-for-nano-March2010.doc+%22best+practice%22+guidelines+nano+waste+disposal+2010&cd=2&hl=en&ct=clnk&gl=nz&client=firefox-a

10. www.vci.de/template_downloads/tmp_VCIInternet/126414Handling_Nanomaterials_being%20Wastes_7_October_2009.pdf?DokNr=126414&p=101.

11. Robert Hickson, 'Setting directions for nanotechnology in New Zealand', International Journal of Nanotechnology, Volume 6, Number 3-4 / 2009, pp 288 – 297.

www.inderscience.com/search/index.php?ction=record&rec_id=22920&prevQuery=&ps=10&m=or.

12. www.ermanz.govt.nz/tehautu/may08hui/14%20-%20Biotech%20&%20Nanotech%20in%20the%20Future%20%28Hickson%29.pdf

13. www.morst.govt.nz/upload/Nanotechnology%20here%20and%20now.pdf

14. http://pubs.acs.org/doi/abs/10.1021/es802483p

Matthew S Hull et al, Environ. Sci. Technol., 2009, 43 (11), pp 4169–4174 DOI: 10.1021/es802483 p, US Army Engineer Research and Development Centre.

1 Fullerenes are a form of carbon molecule and occur only in small amounts naturally. www.wisegeek.com/what-are-fullerenes.htm

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