One of the groups responding the US Environmental Protection Agency’s (EPA) request for comments (the deadline for comments was July 6, 2015 as per my April 8, 2015 posting about the consultation) on its proposed rule on reporting nanomaterials has publicized its comment/critique in a July 3, 2015 article by Caitlin Nordahl for EP Newswire,

“EPA’s proposed rule requiring recordkeeping and reporting rules for nanomaterials is premature in the absence of 1) recommended characterizations; 2) recommended test guidelines (or standards) and guidance; and 3) recommended reference materials,” Ryman-Rasmussen [Jessica Ryman-Rasmussen of Atlas Regulatory Toxicology, Inc., a human health regulatory toxicology and risk consulting firm] said …

Points well taken. Still, there is a ‘which came first, the chicken or the egg?’ situation with nanomaterials. There have been a few recent announcements about new protocols and characterization efforts which suggest that these are still very early days and there is much to be done. Meanwhile, the regulatory agencies are being pressured to do more where nanomaterials are concerned. The agencies are grappling with the problem of making a decision which could have a major impact, positive or negative, when there is little data. Hopefully, comments from Atlas and others (pro and con) will help policymakers to arrive at the best possible regulatory outcome.

For anyone interested in more detail about this consultation and some of the nanomaterial reporting history with regard to the EPA, Joshua Bloom had some interesting comments as per my excerpts in an April 22, 2015 posting.