April 24, 2018

April 24, 2018

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April 23, 2018

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EC Committee’s Preliminary Opinion on Colloidal Silver (Nano) Available for Comment

The European Commission (EC) Scientific Committee on Consumer Safety (SCCS) announced on March 20, 2018, that its preliminary opinion on colloidal silver (nano) is available for comment.  According to the preliminary opinion, the EC received 63 notifications of cosmetic products containing colloidal silver in nano form.  According to the applicants, the ingredient is used in nano uncoated form both in leave-on and rinse-off oral cosmetics products, including toothpastes and skin care products, with a maximum reported concentration limit of one percent and certain specifications.  The EC asked SCCS for its opinion on the safety of the nanomaterial colloidal silver as used in the notified products, taking into account reasonably foreseeable exposure conditions.  SCCS states that the applicants provided only a limited amount of data that corresponded to the SCCS Guidance on Safety Assessment of Nanomaterials in Cosmetics (SCCS 1484/12).  According to SCCS, the provided data were also not in line with the SCCS Memorandum on Relevance, Adequacy and Quality of Data in Safety Dossiers on Nanomaterials (SCCS/1524/13).  Although other information is available in open literature relating to the toxicity of nanosilver, their relevance with respect to the materials of the submission has not been considered by the applicants.  Due to a number of major data gaps, SCCS states that it is not able to draw a conclusion on the safety of nanosilver when used in oral and dermal cosmetic products.  The EC asked SCCS to address any further scientific concerns with regard to the use of colloidal silver in nano form in cosmetic products.  SCCS states:  “In addition to safety assessment of nano silver, consideration should also be given to the likely presence of ionic silver in different type of final products.”  Comments are due May 15, 2018.

©2018 Bergeson & Campbell, P.C.

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Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Owner of Bergeson & Campbell, P.C. (B&C®), Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy...

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Carla Hutton, Bergeson Campbell PC, global regulatory attorney, public health activists lawyer, metals industry legal counsel, Toxic Substances Control Act law
Regulatory Analyst

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client initiatives. These tasks have proven invaluable to many clients, keeping them aware and abreast of developing issues so that they can respond in kind and prepare for the future of their business.

Ms. Hutton brings a wealth of experience and judgment to her work in federal, state, and international chemical regulatory and legislative issues, including green chemistry, nanotechnology, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), Proposition 65, and the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program.

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