2013 NZ Councils 10 February 2013

10 February 2013

CEOs, Mayors and Councillors of all Regional, District and City Councils in New Zealand,

cc Community and Local Boards, and CEOs and Board Members of all District Health Boards

Council’s Future Community Plans

The Trustees of PSGR thank Council for their response to previous correspondence. We again ask that you take into consideration the following concerns for a sustainable district and a healthy community when establishing your 2013 Annual Plan, and in doing this draw support from the members of District Health Boards and Community and Local Boards.

Physicians and Scientists for Global Responsibility is a Charitable Trust established to provide independent scientific assessment and advice on matters relating to genetic engineering and other scientific matters including nanotechnology and synthetic biology. We offer the following:

1 Genetic Engineering (terms also used include genetic modification and transgenics)

We draw Councils' attention to the RMA Section 32 analysis for Auckland and northern councils and the work of Dr Kerry Grundy, Team Leader (Futures Planning) at Whangarei District Council and convener of the Inter-Council Working Party (ICWP) on GMO (genetically modified organisms) Risk Evaluation and Management Options.

The ICWP has investigated the nature and extent of risks local authorities could expect to face from transgenic organisms in the environment and the options available to address those risks. It has sought legal opinion on whether local government has jurisdiction under the Local Government Act (LGA) and Resource Management Act (RMA) to regulate genetically engineered organisms. The latest documents released on 5 February 2012 can be found at www.wdc.govt.nz.

We quote: “... there are significant risks to local government and their communities from outdoor use of GMOs, including environmental, economic and socio-cultural risks” and “the potential adverse effects of releasing GMOs into the environment could be significant – including possible major and long term harm. Moreover, these effects could be irreversible.”[i] The plan provisions commissioned by the ICWP “provide for a precautionary approach to the way the use of natural resources is managed for the outdoor use of GMOs in order to achieve the purpose of the RMA” and “a rationale for prohibiting the general release of a GMO in district and unitary plans pending the availability of sufficient information about the risk of any potential effects of the activities on the environment. The evaluation also reflects community values in respect of the environmental risks the community is prepared to accept at the moment.”ⁱ

Councils have a duty of care to protect their community from uninsurable long-term costs and damage that may arise given the scientific uncertainty around transgenic organisms in situations of commercial open release. We outline some of the concerns.

The terms genetic modification and biotechnology are often used the deliberate process of genetic engineering, which we take as the most accurate description of the technology. While biotechnology encompasses many other processes and offers many important non-transgenic applications that have contributed largely to support and improve agriculture, genetic engineering the main focus of our concern because of the manner in which it impinges on organisms and their ecological relationships.

The application of genetic engineering technology alters the DNA of a living organism in ways which are much more radical than what occurs due to the generally incremental, slow processes of natural evolution. It does this in a way that is inevitably disruptive to some degree as a result of the essentially random insertion of transgenic (or cisgenic) DNA into the functional DNA of a host organism. It may cause noticeable changes in the appearance of the organism and/or differences in the biochemistry and physiology of the organism. These changes are unpredictable and may result in the production of new proteins, with potential toxic effects, within the transgenic organism.

Many scientists are concerned about releasing genetically engineered organisms into the environment. That genetic engineering is of community significance for councils to address was amply determined in a 2009 Colmar Brunton Poll, to be found at http://www.wdc.govt.nz/PlansPoliciesandBylaws/Plans/Genetic-Engineering/Pages/default.aspx.

New Zealand companies are concerned. Fonterra has said there is insufficient support in this country or from overseas customers to warrant local production of food from genetically engineered sources, and food producers Heinz Watties, Goodman Fielder and others have GE free policies.[ii]

When genetically engineered organisms are released into the environment their transgenes , be transferred to other organisms and so that the engineered characteristics spread through the eco-system. Farmers in the US face having to eradicate weed species that have developed herbicide-resistant traits, including resistance to multiple herbicides. These so-named ‘superweeds’ can grow aggressively and out-compete transgenic crops. Over-application of herbicides and pesticides to transgenic crops has increased substantially the volume of agricultural chemicals used and this has aided in the development of weeds resistant to those chemicals.

In December 2012, the Foundation for Arable Research confirmed New Zealand’s first case of glyphosate-resistant ryegrass in a Marlborough vineyard and blamed frequent applications of that herbicide as the cause.[iii] Introducing transgenic ryegrass, which is in development, into this country’s pastures would potentially contaminate conventional ryegrasses and would jeopardise our substantial ryegrass seed export industry.[iv] Trevor James of AgResearch is reported as saying: “There are 61 weeds all around the world resistant to glyphosate; there are six in Australia and it's a major problem with their cropping...”[v] Ryegrass (Lolium rigidum) is an acknowledged problematic weed in Australia and the first glyphosate-resistant weed was annual ryegrass which emerged in 1996.[vi] Glyphosate is the active ingredient in the widely applied herbicide marketed as RoundUp. Commercial RoundUp Ready (glyphosate-resistant) cotton was first grown in Australia in 1996 and may have contributed. Other resistant crops grown elsewhere are seen as culpable in the emergence of herbicide-resistant weed species.

Each year weeds cost Australia over AUD$4 billion in control and lost production.[vii] Recently, the Australian government committed AUD$15.3 million over four years to establish a comprehensive National Weeds and Productivity Research Programme to reduce the impact of invasive plants. Wild radish (Raphanus raphanistrum) costs the Australian grain industry AUD$140 million/p.a. for weed control and in lost production.[viii] In relation to widely grown transgenic oilseed rape/canola, Britain’s advisory committee on releases to the environment (ACRE) identified wild radish, wild turnip, hoary mustard, brown mustard and wild cabbage as species from which hybrids could be formed with the transgenic varieties. A Swedish study found transgenic canola seed could remain viable in the wild even 10 years after release.[ix] In one field trial plot, researchers found 46% of seeds in a wild turnip plant contaminated with transgenic DNA.[x] Wild radish, wild turnip and wild cabbage grow in New Zealand.

Councils will be aware of the heavy costs incurred to remove wilding pines. With experiments on RoundUp Ready pinus radiata some communities potentially face the risk of transgenic pines resistant to glyphosate becoming a superweed. (See‘2 Wilding Pines’ on page 4.)

Dr Charles Benbrook, a research professor at the Centre for Sustaining Agriculture and Natural Resources at Washington State University, US, states: “the spread of glyphosate-resistant weeds in herbicide-resistant weed management systems has brought about substantial increases in the number and volume of herbicides applied. If new genetically engineered forms of corn and soybeans tolerant of 2,4-D are approved, the volume of 2,4-D sprayed could drive herbicide usage upward by another approximate 50%.”[xi]

N.B. There is an application for approval currently before Food Standards ANZ for transgenic soy resistant to three chemicals: 2,4-D (2,4-dichlorophenoxyacetic acid), glufosinate ammonium and glyphosate. Other transgenic crops are being developed to resist 2,4-D (an ingredient in Agent Orange), dicamba (a herbicide in the 2,4-D family), HPPD-inhibiting herbicides, and glyphosate and AL (GAT).[xii]

Transgenic crops also potentially endanger the human environment. In 2009, the American Academy of Environmental Medicine issued a statement ‘Genetically Modified Foods’ that included: “GM foods pose a serious health risk in the areas of toxicology, allergy and immune function, reproductive health and metabolic, physiologic and genetic health and are without benefit.”: http://www.aaemonline.org./gmopost.html.

It is claimed transgenic crops benefit farmers. Hear from US farmers who planted transgenic crops on http://www.youtube.com/watch?v=jEX654gN3c4&feature=plcp (24 minutes) and an interview with Nnimmo Bassey, head of Friends of the Earth International speaking of farmers in India, south-east Asia, Africa and Latin America (8.18 minutes), http://www.guardian.co.uk/environment/2011/oct/19/gm-crops-insecurity-superweeds-pesticides.

The Supreme Court of India is currently considering the advice of a scientific expert panel for a ten-year moratorium on field trials of genetically engineered organisms.

The International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD), a large, comprehensive United Nations study, does not support the thesis that genetic engineering is a solution to feeding future generations, and transgenic crops could threaten food security: www.agassessment.org/docs/SCReport,English.pdf.

PSGR urges Council to apply a precautionary policy on genetically engineered organisms to meet its duty of care to its ratepayers and to protect the environment. For a guide to Council for plan development, we recommend the comprehensive analysis of the myths and truths relating to genetically engineered organisms and peer-reviewed studies found at http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf, the executive summary of which follows this letter. This document supports PSGR's recommendations.

2 Wilding Pines

Wilding pines are invasive, cost New Zealand millions of dollars to control and are a threat to biodiversity, farm productivity and landscape values. Different conifers dominate in different areas of New Zealand. There are ten main ‘wilding’ species: Radiata Pine (Pinus radiata); Douglas-fir (Pseudotsuga species); Bishop Pine (Pinus muricata); Corsican Pine (Pinus nigra); Dwarf Mountain Pine (Pinus mugo); Lodgepole Pine (Pinus contorta); Maritime Pine (Pinus pinaster); Ponderosa Pine (Pinus ponderosa); Scots Pine (Pinus sylvestris); European Larch (Larix decidua).[xiii]

Forestry in New Zealand is a major export earner and a significant employer. Ninety percent of our plantation forests are in pinus radiata[xiv] which generate wilding pines to flourish from coastal areas to high altitudes. Pines seed efficiently from pinecones. Wind-blown seeds are widely distributed and readily take root. Wilding pines compete with native trees and plants and pine needles discourage regeneration of native forest floor species.

Wilding pines are aggressive colonisers and create economic and environmental consequences for Regional Councils, the Department of Conservation, National Park Boards, private landowners and others. Funding can come from such as the Ministry of Agriculture and Forestry Sustainable Farming Fund[xv], government’s Biodiversity Funds[xvi], and the Environmental Enhancement Fund from Environment Bay of Plenty.[xvii] The monitory sources used deplete the public purse.

It is our understanding that Regional Councils are taking action against wilding pines as part of The New Zealand Biodiversity Strategy (2000) which fulfils in part commitments made under the Convention of Biological Diversity to halt the decline of our indigenous biodiversity: http://www.biodiversity.govt.nz/pdfs/picture/nzbs-whole.pdf. In its 2005 Pest Management Strategy, Canterbury Regional Council advocated changes to the district plans of territorial authorities to prevent or control the planting of inappropriate conifers.[xviii]

Of concern to PSGR was the approval by the Environmental Research Management Authority (now the Environmental Protection Agency; EPA) for the New Zealand Forest Research Institute Limited, trading as Scion, to plant pinus radiata with a number of engineered traits, including herbicide-resistance: Applications GMF000032; GMF000033; GMF000034; GMF000035; GMF000036; GMF000037; GMF000038; GMF000039; all approved with controls. The experimental trees would be trialled over two decades in the open environment in the Rotorua area. The premise is that the trees will largely be engineered using what is commonly termed ‘terminator’ technology, making the trees sterile, i.e. not able to flower or replicate.

Transgenic traits are likely to be unstable and the variants of terminator technology offer no absolute guarantee of sterility. The traits can break down and the trees revert to flowering. Even if totally sterile, terminator trees can spread by asexual means. Genes can spread horizontally in soil bacteria, fungi and other organisms in the extensive root system of forest trees. There could be long-term impacts on soil biota and fertility. Sterile monocultures yield more readily to disease. Trees that do not flower and fruit cannot provide food for the organisms that feed on pollen, nectar, seed and fruit; thus, essential pollinating insects may not be available, especially for beekeepers, horticulturalists and crop growers.

One of the proposed engineered traits is herbicide-resistance. As we have shown, in the US herbicide-tolerant transgenic crops have increased the use of herbicides, rather than cause a reduction in usage. This has led to substantial numbers of weed species becoming herbicide- resistant and in turn causing major difficulties for farmers and other growers.

Herbicide-resistant pines could lead to wilding pine superweeds. Worrying is the fact that conventional pinus radiata seeds have been found viable “at least up to twenty-four years.”[xix]

council could consider its area of jurisdiction is too far away to worry about contamination or cross-pollination from genetically engineered trees grown elsewhere. In this regard, we refer you to the work of Sing el al (1993) who found that pollen from pine trees had travelled over 600 kms. Pollen is in the order of 100 to 10 microns or smaller in size. Once in the atmosphere, it can travel vast distances. It would need a failure rate of only a part of a percent for transgenes in pollen to contaminate other trees, potentially at great distances, in ways that could not easily be monitored.

The risks are environmental and economic. Terminator technology has attracted a voluntary moratorium from many countries because of the risks involved. The effect on New Zealand’s reputation overseas and exports could be damaging. These experiments are not in New Zealand’s best interests.

We refer you to our full submission to the Environmental Risk Management Authority (ERMA) on this Application (now the jurisdiction of the EPA): www.psgr.org.nz/index.php?option=co m_content&view=article&id=80: submission-on-application-erma200479-to-field-test-in-containment-pinus-radiata&catid=24:environmental-risk-management&Itemid=39.

With the tools contained in the latest release from the ICWP, Councils have the means to endorse their plans with a precautionary statement, or something more stringent, to avoid the undesirable effects of transgenic wilding pines.

3 Nanotechnology

Nanotechnology refers to techniques used to engineer structures, materials and systems that operate at a scale of 100 nanometres (nm) or less, the scale of atoms and molecules. One nanometre measures one-billionth of a metre.

Recent evidence from hydroponic plant studies showed manufactured nano-materials (MNM) can be taken up and processed by plants. Priester et al (2012)[xx] found MNM can impact on microbes and microbial processes related to nutrient cycling, to plant growth and composition if MNMs are transferred from soil to plants, and to plant-microbe interactions that affect soil fertility. The researchers propose MNM could alter the quality and yield of soil-based food crops.

A further conclusion was that dispersing wastewater biosolids which may contain MNM on paddocks growing food crops could lead to agriculturally associated human and environmental risks from MNM. It raised concern that there could be toxic effects higher up the food chain that could potentially be a threat to any form of life.

Biosolids that may contain MNM are routinely dispersed on New Zealand paddocks and into water systems. Treated sewage that may contain MNM is discharged into the sea.[xxi]

Council should be aware that MNM can potentially pose serious problems. We do not know what happens when MNM are ground up, incinerated or disposed of in a landfill, or when they are released into the atmosphere, water or soil. Studies have shown nanoparticles can move in unexpected ways through soil and can potentially carry other substances with them. Airborne MNM could travel vast distances. We do not have filters fine enough to trap MNM and we currently have no way of tracking them in soil, air or water.

Caution must also arise when we consider studies such as that detailed in the European Respiratory Journal[xxii]: “Seven young female workers (aged 18–47 yrs), exposed to nanoparticles for 5–13 months, all with shortness of breath and pleural effusions were admitted to hospital. Immunological tests, examinations of bacteriology, virology and tumour markers, bronchoscopy, internal thoracoscopy and video-assisted thoracic surgery were performed. Surveys of the workplace, clinical observations and examinations of the patients were conducted. Polyacrylate, consisting of nanoparticles, was confirmed in the workplace. Pathological examinations of patients' lung tissue displayed nonspecific pulmonary inflammation, pulmonary fibrosis and foreign-body granulomas of pleura. Using transmission electron microscopy, nanoparticles were observed to lodge in the cytoplasm and caryoplasm of pulmonary epithelial and mesothelial cells, but are also located in the chest fluid. These cases arouse concern that long-term exposure to some nanoparticles without protective measures may be related to serious damage to human lungs.” Two of the workers died.

It is known that varieties of nanoparticles can pass through skin into the bloodstream, enter an individual cell, and pass through the blood-brain barrier and into the placenta. Relatively few toxicological studies on nanoparticles have been carried out and where they have been performed on animals and fish adverse reactions have been observed, including fatalities.

Councils and District Health Boards need to work closely on developing safety measures in regard to MNM. Potential gains from nanotechnology need to be weighed against the fact that science is increasingly being privatised and patents on nano-products and -technologies are growing rapidly. Vested interest can too easily override issues of safety, regulation, and public consultation and interest. This is not a subject for the ‘too hard’ basket.

Items marketed today containing MNM include electronic, cosmetic, automotive and medical products, and packaging.[xxiii] MNM known to be in use in New Zealand are dental fillings, cleaning materials, protective and non-stick applications on glass, personal care products, veterinarian and pharmaceutical products. MNM are inadequately regulated in New Zealand. Manufacturers are not required to state on a product that it contains nanomaterials, or to notify the EPA they intend to import or manufacture products containing nanoparticles, other than cosmetics.

Despite PSGR’s repeated requests, the Ministry of Research, Science and Technology, now the Ministry of Business, Innovation and Employment (MBIE), has not updated us on their 2010 position on developments for handling nanoparticle waste material.

We refer you again to the actions of the City of Berkeley in California, the first authority to address nano waste: www.ci.berkley.ca.us/ (enter nano waste in ‘search’); title 15, pages 9 and 10 on www.ci.berkeley.ca.us/uploadedFiles/Clerk/Level_3_-_General/BMC-Part1-T1-22--091807.pdf; and www.ci.berkeley.ca.us/uploadedFiles/Planning_(new_site_map_walk-through)/Level_3_-_General/Manuffactured%20Nanoscale%20Materials.pdf.

We also refer you to the PSGR submission to Tauranga City Council on nano waste on www.psgr.org.nz/index.php?option=com_content&view=article&id=81:submission-to-tauranga-city-council--western-bay-of-plenty-district-council-nano-waste&catid=21:general&Itemid=39, and

TCC’s response on www.psgr.org.nz/index.php?option=com_content&view=article&id=83: response-to-submission-o-nanotechnology-waste-tcc&catid=21:general&Itemid=39.

Council’s Future Plans

PSGR urges New Zealand Councils to apply strong precautionary policies on genetically engineered organisms and on nanoparticles for Unitary, Local and Regional plans to meet their duty of care to ratepayers and to protect the environment; and District Health Boards to be cognisant of the risks of genetically engineered organisms and nanoparticles in terms of human health.

We look forward to your response

Yours sincerely

Trustees of PSGR

GMO Myths and Truths

An evidence-based examination of the claims made for the safety and efficacy of genetically modified crops,Michael Antoniou, Claire Robinson, John Fagan; June 2012, Earth Open Source http://earthopensource.org/index.php/reports/58

Executive Summary: Genetically modified (GM) crops are promoted on the basis of a range of far-reaching claims from the GM crop industry and its supporters. They say that GM crops:

Are an extension of natural breeding and do not pose different risks from naturally bred crops
Are safe to eat and can be more nutritious than naturally bred crops
Are strictly regulated for safety
Increase crop yields
Reduce pesticide use
Benefit farmers and make their lives easier
Bring economic benefits
Benefit the environment
Can help solve problems caused by climate change
Reduce energy use
Will help feed the world.

However, a large and growing body of scientific and other authoritative evidence shows that these claims are not true. On the contrary, evidence presented in this report indicates that GM crops:

Are laboratory-made, using technology that is totally different from natural breeding methods, and pose different risks from non-GM crops
Can be toxic, allergenic or less nutritious than their natural counterparts
Are not adequately regulated to ensure safety
Do not increase yield potential
Do not reduce pesticide use but increase it
Create serious problems for farmers, including herbicide-tolerant “superweeds”, compromised soil quality, and increased disease susceptibility in crops
Have mixed economic effects
Harm soil quality, disrupt ecosystems, and reduce biodiversity
Do not offer effective solutions to climate change
Are as energy-hungry as any other chemically-farmed crops
Cannot solve the problem of world hunger but distract from its real causes – poverty, lack of access to food and, increasingly, lack of access to land to grow it on.

Based on the evidence presented in this report, there is no need to take risks with GM crops when effective, readily available, and sustainable solutions to the problems that GM technology is claimed to address already exist. Conventional plant breeding, in some cases helped by safe modern technologies like gene mapping and marker assisted selection, continues to outperform GM in producing high-yield, drought-tolerant, and pest- and disease-resistant crops that can meet our present and future food needs.

http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf.

See also 1. The Sustainability Council of NZ www.sustainabilitynz.org/council.asp. 2. GM Watch www.gmwatch.org/. 3. Herbicide-resistant weeds www.weedscience.org/summary/MOASummary.asp and www.weedscience.org/In.asp; 4. PSGR Frequently Asked Questions on Genetic Engineering www.psgr.org.nz/index.php?option=com_content&view=article&id=54&Itemid=25. 5. A Review of the Adequacy of New Zealand’s Regulatory Systems to Manage the Possible Impacts of Manufactured Nanomaterials ( January 2011) www.msi.govt.nz/assets/Nanotechnology-review.pdf. 6. ‘Nanotechnology: safe or not?’ Organic New Zealand September/October 2010 and ‘Nano waste, how do we deal with it?’ Organic New Zealand November/December 2010. 7. The ETC Group on Nanotechnology http://www.etcgroup.org/issues/nanotechnology.

[i] ‘Managing Risks Associated with the Outdoor Use of Genetically Modified Organisms Proposed Plan Change, Section 32 Report, and Legal Opinion’ cover note by Dr Kerry Grundy, Convener of the Inter-council Working Party on GMO Risk Evaluation and Management Options. Documents on www.wdc.govt.nz.

[ii] The Greenpeace GE Free Food Guide is to be updated in 2013 http://www.gefreefood.org.nz/.

[iii] www.far.org.nz/index.php/media/entry/glyphosate-resistance-confirmed-in-new-zealand

[iv] www.nature.com/hdy/journal/v88/n5/full/6800071a.html.

[v] http://www.3news.co.nz/Weeds-herbicide-resistance-a-big-concern/tabid/1160/articleID/280328/Default.aspx.

[vi] Sydney Morning Herald, 8 May 2012.

[vii] http://www.csiro.au/en/Outcomes/Safeguarding-Australia/Aust-Weed-Management.aspx

[viii] http://www.daff.gov.au/natural-resources/invasive/national_weeds_productivity_research_program

[ix] ‘Long-term persistence of GM oilseed rape in the seedbank’, D’Hertefeldt T et al, Biol Lett. 23 June 2008; 4(3): 314–317. www.ncbi.nlm.nih.gov/pmc/articles/PMC2610060/.

[x] www.guardian.co.uk/science/2003/jul/10/gm.sciencenews

[xi] http://www.nlpwessex.org/docs/benbrook.htm.

[xii] www.soils.wisc.edu/extension/wcmc/2012/ppt/Davis_2.pdf

[xiii] ‘Wilding conifers - New Zealand history and research background’, a presentation by Nick Ledgard at the "Managing wilding conifers in New Zealand - present and future" workshop (2003).

[xiv] ‘Situation and outlook for New Zealand agriculture and forestry’, NZ Ministry of Agriculture and Forestry, 2007.

[xv] ‘The Project’. South Island Wilding Conifer Management Group; retrieved 17 January 2009.

[xvi] ‘Mid Dome project receives biodiversity funding’, New Zealand Government, 19 October 2008.

[xvii] http://www.boprc.govt.nz/news-centre/media-releases/july-2011/environmental-projects-secure-regional-council-funding/.

[xviii] Canterbury Regional Council (June 2005), Canterbury Regional Pest Management Strategy (2005), Christchurch, New Zealand: Canterbury Regional Council. ISBN 1-86937-563-7.

[xix] ‘The Fire Pines’, Richard Warren and Alfred J Fordham, http://arnoldia.arboretum.harvard.edu/pdf/articles/1040.pdf

[xx] ‘Soybean susceptibility to manufactured nanomaterials with evidence for food quality and soil fertility interruption’, 2012, www.pnas.org/content/early/2012/08/14/1205431109?utm_source=HEADS-UP+24-30+AUGUST++2012&utm_campaign=SMC+Heads-Up&utm_medium=email (A)

‘UCSB Scientists Demonstrate Biomagnification of Nanomaterials in Food Chain’

http://ucsb.imodules.com/s/1016/indexNL.aspx?sid=1016&gid=1&pgid=252&cid=1417&ecid=1417&ciid=1790&crid=0

[xxi] Mangere www.bvsde.paho.org/bvsaar/cdlodos/pdf/beneficialuse941.pdf; Guidelines for the Safe Application of Biosolids to Land in NZ, August 2003 www.waternz.org.nz/documents/publications/books_guides/biosolids_guidelines.pdf; The Cost-Benefits of Applying Biosolid Composts for Begetalbe, Fruit and Maize/Sweetcorn Production Systems in NZ 2004 www.mwpress.co.nz/store/downloads/LRSciSeries27_Cameron2004_4web.pdf

Christchurch http://researcharchive.lincoln.ac.nz/dspace/bitstream/10182/1747/1/ssd_sewage_sludge.pdf

[xxii] ‘Exposure to nanoparticles is related to pleural effusion, pulmonary fibrosis and granuloma’, Song Y et al. http://erj.ersjournals.com/content/34/3/559.short 2009

[xxiii] www.nanotechproject.org/inventories/consumer/

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