Here's the most "official" document I have so far by the FDA on this
subject. (I'm still trying to get a copy of the actual ruling)

www.fda.gov/bbs/topics/ANSWERS/ANS00971.html

This is a press release by FDA personnel "in responding with consistency
and accuracy to questions from the public on subjects of current interest."
It doesn't say much, but the paragraph of most interest to us (and who
knows how it will be interpreted) is--

        "According to the Final Rule, a colloidal silver product for any drug 
use
will first have to be approved by FDA under the new drug application
procedures.  The Final Rule classifies colloidal silver products as
misbranded.....their labeling falsely suggests that there is substantial
scientific evidence to establish that the drugs are safe and effective for
their intended uses."

Karen