Feedback from J.J. Sama

New York State Department of Environmental Conservation

Posted on: April 15, 2007

Obviously this is past the March 30 deadline but I did have a comment/question or two: It is not immediately apparent that the protocol examines behavior of new nanomaterials potential to pass through conventional filtration media and membranes used in pollution control and worker protection equipment. This is crucial to confirming the efficacy of recommended engineering controls where historical performance data is largely irrelevant. Also, the only organic membrane penetration recognized is dermal penetration while inhalation and ingestion pathways assume normal paths and barriers in tissue systems that may not apply here. How, if at all, are these considerations addressed in the protocol? Thank you.