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Application of TRI toNanomaterials
Colin Finan and Todd KuikenProject on Emerging NanotechnologiesWoodrow Wilson International Center for Scholars
•An initial review of the TRI authoritiesindicate that, in theory, the statute could beapplied to nanomaterials.•The key question is whether anynanomaterials are or will be considered byEPA to be toxic chemicals under TRI.These decisions will rest, in part, on thedevelopment of additional toxicological databy EPA and by EPA’s approach toadministering the statute. – PEN ResearchBrief #2, February 2008
Threshold Determinations
•Traditional threshold determinations are notalways a barrier for inclusion on TRI.
–Dioxin limit was set at 0.1 grams –EPA’s rationale for revising the thresholds of certainchemicals potentially could apply to nanoparticles
•Issues may surround facility size.
–10 or more full-time employee equivalents –Some small firms/labs may not meet this requirement
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