Comments of the Cosmetic, Toiletry, and Fragrance Association regarding the scientific and legal issues associated with nanotechnology in personal care products

Summited in Regard to Docket Number 2006P-0210: Petition to FDA to Amend its Regulations for Products Composed of Engineered Nanoparticles Generally and Sunscreen Drug Products Composed of Engineered Nanoparticles Specifically. Position paper provides the Cosmetic, Toiletry, and Fragrance Association views on the scientific and legal issues associated with the use of nanotechnology in personal care products in advance of the October 2006 public meeting hosted by the Federal Food and Drug Administration, and to respond to Citizen Petition submitted by the International Center for Technology Assessment and petitioners. CTFA asks the FDA to reject the Citizen Petition on the grounds that the FDA has no statutory authority to regulate nanotechnology as a technology, the lack of clear scientific justification by the Petitioners that the FDA must develop a new regulatory framework for nanotechnology, and the lack of scientific consensus that sunscreens and other personal care products containing nanoparticles pose a safety risk.