CHAPTER 7: Effective Communication
7.1. For any new technology to succeed, the trust
of consumers is vital. In the food sector, gaining that trust
is a particular challenge - as recently demonstrated by the public
reaction to the introduction of technologies such as genetic modification
or irradiation. If the potential benefits of nanotechnologies
are to be realised (see Chapter 3), consumers will need to feel
confident that they are informed about the risks as well as the
benefits and about the balance between them. As Ms Merron said:
"consumers' fear is often about [a] lack of information"
(Q 668). As a result, as the BRASS centre suggested, the
provision of information "may be a key factor … to establishing
the social legitimacy of some uses of nanotechnologies" (p 297).
In more practical terms, Dr Kellie told us bluntly that,
when "bringing new technologies to the market, if we do not
bring the consumer with us, it is all a waste of time" (Q 198).
In this chapter, we discuss current public attitudes towards nanotechnologies
in the food sector and consider two principal activities of any
public communications strategy: informing and engaging.
7.2. We concentrate in this chapter on the value
of public engagement activities, and make recommendations about
ways in which they can be made more effective. We accept that
such activities will not settle ethical issues that can arise
in the development and marketing of foods containing nanomaterials.
While we did not consider these matters as part of this inquiry,
those relevant include: dealing with changing patterns of risk
and benefit that consumers may incur when new technologies are
introduced; the role that individual consent can play in making
certain risks ethically acceptable; and the approach required
when individual consent is not possible—for example when
food safety standards are set for all.
Background
7.3. In 2004, the RS/RAEng report on nanotechnologies
recommended that the Research Councils should fund a "sustained
and extensive programme of research into public attitudes to nanotechnologies",
and that the Government should initiate an "adequately funded
public dialogue around the development of nanotechnologies".[84]
This recommendation built on lessons learnt from past experiences
of the introduction of new technologies (see Box 2).
7.4. In 2005, the Nanotechnology Engagement Group
(NEG) was established by the Government. Its purpose was to document
the learning from a series of exercises designed to involve members
of public in discussions about the development and governance
of nanotechnologies. The final report of the Nanotechnology Engagement
Group (NEG), Democratic Technologies, was published in
2007[85]. The report
identified six engagement projects in the United Kingdom and included
a number of conclusions and recommendations to Government on how
to take forward engagement activity in future. When asked whether
the recommendations had been taken forward, Mr Simon Burall, Director
of Involve, the organisation that drafted the report, said: "My
sense is that things have not really moved very far forward since
that report was written" (Q 354).
7.5. In 2008, the Government launched an initiative,
Science and Society, in order to "improve both the
understanding and engagement of science with the general public,
and to ensure that there is a clear understanding within the science
community … of the duty … to engage with the general
public" (Q 587). Lord Drayson told us that part of this
initiative included a Government commitment to developing a dialogue
with the public on issues arising from the application of nanotechnologies
within the food sector (Q 588).
BOX 2
Learning from past experiences
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During the past 20 years there have been several
controversies arising from the way in which scientific information
has been used by policy-makers, and how this has been presented
to the public. Examples include public concern over bovine spongiform
encephalopathy (BSE), genetically modified (GM) foods and the
Measles, Mumps and Rubella (MMR) vaccine.
Lessons have been learned from these events (see,
for example, David Gee Late lessons from early warnings[86],
or the Philips inquiry into the BSE crisis). These include:
- Recognizing the limitations of
scientific knowledge and not making overconfident claims
about safety or risk;
- Acknowledging scientific uncertainties;
- Being transparent about the process
of scientific risk assessment, and the risks that the public
may be exposed to; and
- Recognising that public concerns
which extend beyond purely scientific issues have a significant
effect on the public's acceptance of new technologies.
In 1997 the Government Chief Scientific Adviser issued
Guidelines on Scientific Analysis in Policy Making which
enshrined some of these points. If policy-makers and communicators
recognise and act on these lessons, it may help enable consumers
make informed judgments about the risks and benefits of novel
technologies.
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Current public attitudes to the
use of nanotechnologies
7.6. Our witnesses confirmed that public attitudes
towards the use of nanotechnologies were among the most important
factors in determining their future in the food sector (QQ 198,
199, Appendix 6). Yet information about the public's views is
limited. A number of witnesses suggested that more information
about the public's views and concerns about nanotechnologies should
be gathered. A FSA report, An Evidence Review of Public Attitudes
to Emerging Technologies, published in 2009, concluded that:
"it is clear that there is a great deal more that needs to
be found out about public attitudes"[87],
while Professor Pidgeon told us "we are at a very early
stage in trying to understand public understanding and perception
on nanotechnology, both as a general concept and … [in relation
to] food" (Q 348). Which? said that there should
be "more effective consumer engagement at the earliest opportunity
specifically focused around potential food development" (p 138).
Despite this lack of evidence, witnesses were able to point us
towards some general conclusions about the public's attitudes
towards the use of nanotechnologies, both generally and in the
food sector.
NANOTECHNOLOGIES GENERALLY
7.7. The level of public awareness and understanding
of nanotechnologies generally appears to be relatively low. A
study conducted by Which? in 2008 showed that only 45 per
cent of people in the United Kingdom had heard of the term "nanotechnology"
and those who had heard of it were often uncertain as to exactly
what it was (p 138). A study in the United States, also in
2008, showed that only 49 per cent of Americans surveyed had heard
of nanotechnology (p 296). Paradoxically, whilst public awareness
of nanotechnologies is low, when asked whether the benefits would
outweigh the risks, many gave a positive answer. Professor Pidgeon
offered the following explanation: "people are bringing in
a judgement about general technological progress … we know
from other surveys of attitudes towards technology in general,
not in specific, the public remain very positive about science
and technology" (Q 349).
NANOTECHNOLOGIES IN THE FOOD SECTOR
7.8. But public attitudes towards the use of
nanotechnologies generally and public attitudes to the use of
nanotechnologies for particular applications differ (Q 349).
As a result, as Professor Pidgeon explained, food will have
"a unique risk perception signature, so you cannot necessarily
extrapolate easily from responses to … nanotechnology in
cosmetics to food" (Q 349). The FSA report on public
attitudes stated that "the overall tone of public attitudes
towards novel food technologies is one of wariness, unease, uncertainty,
and sometimes outright negativity". It concluded that;
"this can partly be explained by the fact that
food is not simply thought of in functional terms; rather it is
part of a much larger wider social and psychological setting which
includes … attitudes to health, the environment, and science,
as well as deep-seated values and fundamental world outlook, not
to mention personal and familial habitual behaviours".
[88]
7.9. According to the FSA report, whereas the
public often had concerns about aspects of nanotechnologies (particularly
the scientific uncertainty associated with them), this was generally
balanced by an optimistic view of the potential benefits. However,
when questioned about the food sector specifically, "people
seem less convinced about the potential benefits that food applications
might bring".[89]
The FSA report states, "there appears to be much less enthusiasm
towards their [nanotechnologies] use in food than in other
applications".[90]
A survey carried out for PEN in 2007 found that only seven per
cent of Americans would buy "nanofoods" and 62 per cent
would require more information on the risks and benefits before
doing so. As for food packaging containing nanomaterials, only
12 per cent were willing to purchase such packaging and 73 per
cent required further information before making a decision (p 304).
7.10. Given the importance of public opinion,
and the multitude of factors at work, we agree that more work
should be undertaken in order to understand consumer views on
nanotechnologies in the food sector. We recommend that the
Government commission a survey of public attitudes towards the
use of nanotechnologies in the food sector, with the aim of informing
debate on the subject. This work should be carried out regularly
to keep pace with evolving public opinion.
Communication and engagement
with the public
7.11. A public communications and engagement
strategy should seek to:
- provide the public with the information
they need, whether by the Government or industry or other relevant
bodies, to allow them to make informed judgements about the use
of nanotechnologies in the food sector; and
- ensure there is a mechanism in
place to allow a dialogue between the public and the major stakeholders
as this novel technology is introduced.
Communication
A GOVERNMENT COMMUNICATIONS STRATEGY
7.12. Our witnesses agreed that there was a role
for Government in communicating issues about nanotechnologies
in food. The Food Additives Industry Association (FAIA), said
that it was essential to ensure that debate remained balanced
and was not "misrepresented" or "the subject of
biased reporting in certain segments of the popular press and
broadcast media" (p 303), a view echoed by Dr Friedrichs
(Q 514). Dr Knowles told us that industry "support
any … form of education for the public about nanotechnology"
(Q 175), while Mr Opie said the benefits and risks of
nanotechnologies had to be explained to consumers and "put
in proportion in a way … they can understand" (Q 177).
Other witnesses agreed (Q 186). Mr Burall agreed, but
stressed that the Government had to be "open about the risks"
and ensure that information was complete and not pushing "a
particular line" (Q 374).
7.13. In their response to the RCEP report the
Government stated that they had commissioned a pilot initiative
"to provide public access to a balanced source of information
on nanotechnologies". The initiative would be based around
"an interactive website … both providing information
and enabling public interaction and debate".[91]
Professor Pidgeon supported this project, and told us that:
"it is part of the process of making … the issues around
nanotechnology transparent to the public" (Q 373). The
pilot website, www.nanoandme.org, is now online.
7.14. We welcome the Government's decision
to commission a website designed to give the public a balanced
source of information on nanotechnologies, and commend the decision
to include a section specifically covering issues related to the
use of nanotechnologies in the food sector.
TRANSPARENCY AND THE INDUSTRY
7.15. Representatives of PEN in the United States
told us that, when asked the question "how can the public
be reassured about the development of nanotechnologies?",
focus groups always responded with "transparency" as
the most important factor (see Appendix 6). Other witnesses made
the same point. Mr Burall, for example, stressed the need
for "absolute transparency to build on trust" (Q 374)
and Lord Drayson told us that the most important lesson that the
Government had learnt was that "the more open an industry
and science is with the general public, the greater the confidence
of the general public" (Q 584).
7.16. We therefore found it regrettable that
evidence indicated that, far from being transparent about its
activities, the food industry was refusing to talk about its work
in this area. The Royal Society referred to "industry reticence"
(p 363) and Which? said that it was "very difficult
to gain a clear picture of the extent to which ... research is
taking place into future applications" (p 133). Mr Burall
had a similar experience with regard to public engagement activities:
the "food producers are very reluctant to participate in
any of the public engagements … we studied" (Q 351)
and Professor Pidgeon said that it had been difficult to
persuade food companies to fund any public engagement projects
(Q 357). PEN suggested that the same was true of the industry
in the United States and the GMA also told us that companies had
retreated from a public dialogue on the subject in recent years
(see Appendix 6).
7.17. Witnesses suggested that the industry's
attitude was mainly due to fear of a negative public reaction.
Dr Kampers told us: "the industry is very, very reluctant
to communicate that they are using nanotechnology in food …
because they are very much afraid of the reaction of the consumer
to the product" (Q 115), Ms Groves (Q 116), Professor Morris
(Q 125) and Professor Jones (Q 515) agreed. The
BRC shared this view and observed that public confidence in new
technology in the food sector was still recovering from the genetically
modified foods debate in the 1990s (p 81).
7.18. We acknowledge the food industry's concern,
but we consider that this is exactly the type of behaviour which
may bring about the public reaction which it is trying to avert.
Ms Davies, for example, suggested that if the industry were not
open about their work at this early stage, there was a danger
that people would become suspicious (Q 300), a view echoed
by Dr Falkner who said that if food producers "even
give the appearance of not wanting to be transparent … then
you are suspected of devious practices" (Q 342). Lord
Drayson said that "the industry in this case needs to learn
some of the lessons which were learned relating to GM foods"
(see Box 2 above) and warned that there could be no effective
public engagement "if companies are not providing clarity
about the work that is being done and potential applications"
(Q 563).
7.19. We acknowledge that some information held
by companies will be commercially sensitive and, as a consequence,
confidential. But we do not consider that this should preclude
them from taking significant steps towards being more open. Ms
Merron said that her wish was to see "greater transparency
from the companies" (Q 669). We agree. We recommend
that the Government work with the food industry to secure more
openness and transparency about their research and development
and their future plans for the application of nanotechnologies
in the food sector.
LABELLING
7.20. While transparency is important, it does
not, in itself, ensure effective communication. Information must
not only be available, it must be accessible and relevant. Some
witnesses proposed improving transparency by requiring food products
manufactured using nanotechnologies to be labelled as such. Ms
Davies, for example, felt that although it was a "difficult
issue", "on balance it is important in terms of transparency"
(Q 311); and BRASS said that providing information to the
public through labelling might be key factor in establishing the
"social legitimacy" of nanotechnologies in food (pp 296-297).
Other witnesses also supported labelling (QQ 305, 458).
7.21. Other witnesses expressed reservations.
PEN, for example, told us that "the current state of [the]
science suggests that there are no underlying mechanisms of action
that would justify blanket labelling of food items containing
engineered nanomaterials … such labelling would obfuscate
evidence-based decision-making" (p 334). The Novel Foods
Regulation requires that the labelling of each product is assessed
on a case-by-case basis. This provides the flexibility to require,
for example, that a particular ingredient is labelled. The Minister,
Ms Merron, said:
"For me if blanket labelling of what something
contains does not tell me something that is going to assist me
to make a sensible decision then it may simply mislead me. That
is why I think blanket labelling is not helpful and that is why
I think it should be case-by-case" (Q 659)
She continued:
"I am not seeking to withhold information; I
am seeking to ensure that we have the right amount of information
in the right form that consumers want and will be able to use"
(Q 665).
7.22. The NIA took a similar view: "consumers
need to be provided with information … labelling is not necessarily
the best way to provide balanced information—it often raises
concern and causes confusion" (p 245). Professor Pidgeon
agreed (Q 369). Mr Opie suggested that the industry's
approach to labelling would depend on whether it was felt labels
would be helpful to consumers: "we would do it if we thought
it was necessary … we put [information] on to help consumers
make a choice" (Q 204). Dr Knowles agreed (Q 205).
7.23. In the United States, the FDA told us that
it had no plans to introduce labelling for nanotechnologies. The
FDA only requires information to be included on a label if it
is necessary in order for the consumer to use the product safely
(see Appendix 6). This contrasts with the approach in the European
Union, where certain information is included on the label because
the public has a presumed right to be informed (for example, genetically
modified foods are labelled in the European Union but not in the
United States).
7.24. Consumers can expect to have access
to information about the food they eat. But blanket labelling
of nanomaterials on packages is not, in our view, the right approach
to providing information about the application of nanotechnologies.
We believe the primary mechanism should be a public register of
foods containing nanomaterials, as we have recommended in Chapter
6 above. We also urge that the Government, along with consumer
groups, should consider other means through which this information
can be made available and accessible to consumers.
Public engagement
EFFECTIVE DIALOGUE
7.25. A number of witnesses argued in favour
of a public engagement strategy to complement mechanisms for providing
information. Without an engagement strategy, the public might
feel, according to Mr Burall, that the Government were simply
providing information with the intention of "pushing the
acceptance of nanotechnology" (Q 368). Which?
said that the "lessons from the introduction of other new
technologies … has been that it is essential to engage the
public at the outset and ensure that there is a two way exchange"
(p 138). Ms Miller referred to the importance of providing
the public with a voice in Government decision-making in areas
such as innovation strategy and research priorities (Q 313);
and Lord Drayson said that it was "very important to be engaging
with the general public and consumer groups" in particular
about the "perceived risks and potential benefits of …
technologies" so that the development of the technologies
and their application did not get ahead of public confidence in
them (Q 562).
7.26. In 2000, we published our report Science
and Society which concluded that, in order to meet a need
for more effective dialogue with the public on science issues,
the Government should be open to "substantial influence and
effective inputs from diverse groups".[92]
Witnesses in this inquiry made a similar point. Ms Miller, for
example, told us:
"Unless the Government is in a situation where
it is prepared to really commit to taking on board findings, not
to being led by them but certainly being informed by them and
really committing to integrate the outcomes of public dialogue
in its own process of policy development, then I would suggest
that public engagement is actually of little value" (Q 307).
7.27. Ms Davies said: "it is important …
that there is a commitment to enabling it [public engagement]
to feed into policy (Q 309); and Dr Chris Groves, Research
Associate at the BRASS centre, said that "engagement needs
to have some degree of input into shaping research agendas and
regulatory policy" (p 304). The 2007 report of the NEG
(see paragraph 7.4 above) concluded that "there is an aspiration
on all sides that future public engagement processes should be
better connected to institutional decision-making" and suggested
a series of measures to improve this connection.[93]
The RCEP report called for "on-going opportunities for public
and expert reflection and debate" and stressed that this
should be a continuing activity.[94]
Dr Groves felt that it was "necessary to support …
systematic and iterative dialogue, with the possibility of allowing
its focus to evolve as potential applications become more concrete"
(p 305).
MEETING THE NEEDS OF DIFFERENT AUDIENCES
7.28. There is general support for public engagement
activity. But the concept of "public" is a complex one.
We recognise there are many different audiences within the public
and that activities should be tailored to these different audiences.
Professor Pidgeon, when discussing the benefits of a register
of nanotechnologies, provided an illustration of this. He suggested
that although people were in favour of information being placed
in the public domain, in general they tended not to look at the
information themselves but instead were reassured by the fact
that someone else had access to the information and could perform
a watchdog function—the availability of information, he
suggested, provided an "opportunity for others in civil society
to look on your behalf" (Q 379). We see a parallel between
this example and the role of public engagement activities. We
acknowledge the importance of giving individual members of the
public a voice. But we—and, it seems, members of the public—recognise
also that this voice is often most effectively mediated by representative
groups such as consumer groups, non-governmental organisations
(NGOs) and individuals with a particular interest in this topic.
Framing effective public engagement strategies needs to take into
account these different audiences within the public—as Mr Burall
told us, "what you are trying to do" should determine
what type of audience you should engage with (Q 366).
A DELIBERATIVE FORUM
7.29. In addition to a more general public engagement
strategy with members of the general public there is, as Ms Miller
suggested, "an effective role for stakeholders … I would
suggest … there should be a broad range of community as well
as industry, research and Government stakeholders involved in
dialogue together" (Q 307). The RCEP report, in the
context of a range of nanotechnology applications, considered
the possibility of a "standing deliberative forum, designed
to inform policy on nanotechnology development, regulation and
research" and suggested that the Nanotechnologies Stakeholder
Forum currently organised and funded by DEFRA might be a suitable
starting point.[95] We
agree that the Nanotechnologies Stakeholder Forum provides a useful
model on which to base a public engagement group to discuss the
issues surrounding the use of nanotechnologies in the food sector.
7.30. As for who should participate in such a
forum, we believe that it is important that the food industry,
as well as the Government, the academic community and consumer
groups, should play an active role in any public debate (Q 357).
We acknowledge that, as Mr Burall told us, industry cannot
lead the debate since it is seen by the public as promoting a
particular commercial line (Q 352). We believe that this
is a role for Government.
7.31. We recommend that the Government should
establish an open discussion group, along the lines of the DEFRA-sponsored
Nanotechnology Stakeholder Forum, to discuss issues surrounding
the application of nanotechnologies in the food sector. This group
should contain representatives from Government, academia and industry,
as well as from representative groups from the public such as
consumer groups and non-governmental organisations. Meetings should
take place on a regular basis as nanotechnology applications are
developed and enter the United Kingdom food market. The Government
should ensure that the concerns of, and the suggestions made by,
the group are published and taken into account in policy decision-making
processes. The Government should report on how these concerns
are being met at regular intervals.
84 RS/RAEng Nanoscience and nanotechnologies,
op.cit., p 87, paras R18, R19. Back
85
Involve, Democratic Technologies?: The final report of the
Nanotechnology Engagement Group (NEG), 2007. Back
86
Gee D et al., The Precautionary Principle in the 20th Century-Late
lessons from early warnings, European Environment Agency Earthscan
Productions, 2002. Back
87
Food Standards Agency (FSA), An Evidence Review of Public Attitudes
to Emerging Technologies, 2009, p 53. Back
88
FSA, An Evidence Review, op. cit., p 6. Back
89
Ibid., FSA, An Evidence Review, p 28. Back
90
Ibid., FSA, An Evidence Review, p 27. Back
91
Government response to RCEP report Novel Materials,
op. cit., p 23. Back
92
Science and Technology Committee, 3rd Report (1999-2000): Science
and Society (HL Paper 38), p 7. Back
93
Involve, Democratic Technologies?, op. cit., pp
99-101. Back
94
RCEP, Novel Materials, op. cit., p 73, para 4.95. Back
95
Ibid., RCEP, Novel Materials, p 74, para 4.99. Back
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