As of today, there are only 11 days left to voice your opposition to the proposal for the EPA to regulate nanosilver products – including colloidal silver – as “pesticides.”

As it stands, the main petition sponsor, the International Center For Technology Assessment (CTA) has drawn up a list of nanosilver products it claims needs to be regulated by EPA. Among that list are the four top brands of colloidal silver (Sovereign Silver, Meso Silver, ASAP Silver, Utopia Silver) as well as many lesser known brands.

This is clearly a ploy to regulate colloidal silver as a “pesticide” under the EPA’s revised FIFRA regulations, which require you to prove your silver product causes no harm to beneficial microorganisms or other creatures in the environment.

Putting Colloidal Silver Manufacturers Out of Business

If the EPA begins to regulate colloidal silver as a “pesticide” under its revised FIFRA regulations, this will, in effect, unjustly put every colloidal silver manufacturer out of business.

The costs of proving that a colloidal silver product causes no harm to “ecologically sensitive” microorganisms in the environment would be prohibitive (environmental impact reports can cost millions of dollars), and the regulatory burden on colloidal silver manufacturers would be unsustainable.

EPA is taking public comments until January 20th, after which they will make their decision.

How to Stop Them From Regulating Silver As a “Pesticide”

We need hundreds or even thousands of people to let the EPA know that colloidal silver should not be included under these new regulations.

If you have a natural health advocacy organization or a health freedom organization, or an email customer list of colloidal silver users, or an email list of natural health users, please, please let your membership base know about this dire situation, and the short time we have left to stop it.

Direct your members or email recipients to post their comments against regulating silver as a “pesticide” on the EPA comment system (see web address and further instructions below).

Or have them email the EPA Administrator Stephen Johnson directly (see below) and let him know that there is no compelling need to regulate nanosilver products such as colloidal silver as “pesticides,” since there is no evidence whatsoever of any environmental harm having taken place.

How to Contact the EPA

Anyone who wants to post to the EPA comments system can do so at this web address:

Anyone wishing to email EPA Administrator Stephen Johnson with their comments against the petition to have silver regulated as a “pesticide” can do so here:

Additionally, faxes can be sent to EPA, addressed to Administrator Stephen Johnson, at:

Fax: 202-501-1450

All comments must reference Docket # EPA-HQ-OPP-2008-0650.

Also, comments should reference the “Petition for Rulemaking Requesting EPA Regulate Nanoscale Silver Products as Pesticides.”

To Learn More

To learn more details about this important issue, please read the two blog articles preceding this one at if you have not done so already.

Don’t Fall for the False Claims

As a last minute dodge to mislead the public, some organizations backing the petition to have EPA regulate nanosilver products as “pesticides” are claiming that the petition has nothing to do with colloidal silver. That is definitely wrong.

I repeat what I stated earlier: The main sponsor of the petition to have EPA regulate silver as a “pesticide” is the International Center For Technology Assessment (CTA), and they have attached a list of nanosilver products to the petition requesting the EPA begin regulatory oversight of these products immediately under the revised FIFRA regulations.

Among the products listed on this attachment to the petition were the top four brands of bottled colloidal silver products on the market today (Sovereign Silver, Meso Silver, ASAP Silver, Utopia Silver) along with numerous less well-known colloidal silver brands.

I wrote CTA and asked why the top four brands of bottled colloidal silver were on this petition, and their lawyer, Mr. George A. Kimbrell, responded. Here is his response:

Hi Steve,

Thanks for your interest in our legal petition to EPA. I’m one of the attorneys who drafted the action and your question was forwarded to me.

To clarify and answer your question: the only consumer products that were included in our product appendix attached to our legal petition were those products that in our research we found were actively marketing their products, through labeling or advertising, as “nano” (i.e., containing manufactured or engineered nanoparticles) and that made health claims based on that “nano” ingredient.

So if there are silver colloidal solution products in the appendix, they must be marketed (or were, as of May 2008, when we filed the petition) as nano-silver and we have documented evidence of such marketing claims.

The appendix was illustrative not comprehensive. We only highlighted these products for the agency to investigate; we did not test the products ourselves. The product appendix included only those self-identified nano-silver products we could find.

No doubt there are more nano-silver products available that are unlabeled and we are calling on the agency to investigate and apply its statutorily entrusted oversight to those products as well.

If said products in the appendix are not “nano,” then they need to remove the misleading and illegal claims on their advertising and marketing. If the products are composed of nano-silver, then yes, they are different than other larger particles of silver and need to be regulated separately.

As we explain in the petition, engineered and manufactured nanomaterials like nano-silver are new types of materials that required new forms of toxicity testing and data to properly assess their novel properties and associated potential risks. In our petition we are requesting that EPA properly analyze the health and environmental safety of these materials before permitting them to go to market.


George A. Kimbrell
Staff Attorney,
The Int’l Center For Technology Assessment & The Center For Food Safety
660 Pennsylvania Ave., S.E. Suite 302
Washington, D.C. 20003
202-547-9359 fax 202-547-9429

Please note that he did not in any way, shape or form deny that his organization includes colloidal silver as a “nanosilver” product. He was very clear that as long as a colloidal silver product meets the standards for nano-silver, then he intends to have EPA regulate it.

Note also his comments, “No doubt there are more nano-silver products available that are unlabeled and we are calling on the agency to investigate and apply its statutorily entrusted oversight to those products as well.”

In other words, they are petitioning EPA to go after any colloidal silver product that fits their overly-broad definition of “nanosilver.”

The Clincher

Now here’s the clincher: In other literature, CTA and its supporting coalition of organizations claim “nanosilver” is defined as silver particles of “100 nm in size or smaller.”

This effectively brings just about every brand of colloidal silver on the face of the earth under the “nanosilver” umbrella.

Is EPA Regulation of Colloidal Silver It a Foregone Conclusion?

I think the EPA has already decided in advance that they are going to take on this “regulatory oversight,” which means they are ultimately going to stop production and sales of anything containing silver “nano particles” (under their definition of 100 nm or less) until it can be proven these particles won’t cause harm to “ecologically sensitive” microorganisms and other creatures in the environment, which is basically impossible.

The only way to stop it is by a massive outpouring of opposition from the American public. The EPA does strongly take into account public comments in their decision-making process. We must turn up the heat and let the EPA know we are not happy with this ruse to destroy the colloidal silver market by regulating nanosilver as a “pesticide.”

The Anti-Silver Propaganda Machine

This ridiculous petition to the EPA was preceded by months of propaganda against “nanosilver” in the online “science news” media, such as at and, both of which carried numerous stories about the alleged “dangers” of allowing “nanosilver” to get into the environment.

These “the-sky-is-falling” science news stories were then re-translated for the popular media, resulting in articles like “Nanotechnology sparks fears for the future” and “Scientists Think Small to Find ‘Nano’ Dangers,” and the worst of all of the chicken little articles “Nanosilver fad poses ‘serious risk to health‘” – and dozens like this, all of these appearing in various popular online news media.

These guys are pretty smart in how they go about building justification for their position over a period of many months before unleashing their campaigns for “regulatory oversight.” I’m afraid they have us out-maneuvered. We really need to swamp the EPA comments system on this petition to regulate “nanosilver” as a “pesticide” with rational, well-constructed comments against the idea.

Right now, the environmental groups and fake “consumer protection” groups have been stacking the EPA comments system with comments favorable to the idea of further EPA regulatory oversight of “nanosilver.” They’ve done this by emailing their membership bases, and asking them to send in anti-silver comments to the EPA.

Get On the Ball and We Can Win!

The various natural health organizations and the health freedom community at large has been woefully behind on countering this massive anti-silver propaganda campaign.

That’s why we need you to get involved in this right away.

If you belong to a natural health advocacy group or health freedom organization, please contact the membership base and let them know what’s going on. Give them the EPA contact information above. Urge them to email, fax, or post comments on the EPA web site, urging the EPA to reject the petition to regulate nanosilver products.

If you are in the natural health business and you have an email customer base, email your customers and explain the situation to them, as well as the dire need to act quickly. Give them the contact information above.

If you are simply a natural products user, go to the EPA web site above and post your comments in opposition to the petition to regulate nanosilver products as “pesticides.” And pass this information along to all of your like-minded friends right away.

Anything you can do to help get the ball rolling in this direction will be a huge benefit. Unfortunately we have so little time. But that is the hand we’ve been dealt.

S. Spencer Jones

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