CHAPTER 8: List of Recommendations and
Conclusions
Nanotechnologies in the food sector
ENCOURAGING THE COMMERCIALISATION OF NANOTECHNOLOGIES
IN THE FOOD SECTOR
8.1. We recommend that, as part of their commitment
to gain a better understanding of the needs of United Kingdom
industry sectors likely to use nanotechnologies, the Government
should pay specific attention to identifying the needs of the
food industry and make provision for meeting those needs in their
2010 national strategy (paragraph 3.36).
8.2. We recommend that Government should take
steps to ensure the establishment of research collaborations between
industry, academia and other relevant bodies at the pre-competitive
stage in order to promote the translation of basic research into
commercially viable applications of nanotechnologies in the food
sector (paragraph 3.37). (Recommendation 2)
8.3. We recommend that the Technology Strategy
Board reviews the state of the commercialisation of nanotechnologies
in the food sector. As part of this review it should suggest mechanisms
for improving the effectiveness of current knowledge transfer
systems (paragraph 3.38). (Recommendation 3)
8.4. We recommend that the Technology Strategy
Board includes consideration of the role that nanotechnologies
may play in helping the food industry meet societal challenges,
such as obesity and waste, in its strategies for promoting nanoscale
technologies and biosciences, and that the Technology Strategy
Board proposes ways of supporting the development and commercialisation
of these technologies (paragraph 3.49). (Recommendation 4)
Health and Safety
FILLING THE KNOWLEDGE GAPS
8.5. We recommend that the Research Councils
should establish more pro-active forms of funding to encourage
the submission of research bids to address the severe shortfalls
in research required for risk assessment of nanomaterials as set
out in the EMERGNANO report, and ensure that submissions are reviewed
by a committee with appropriate expertise in this field (paragraph 4.43).
(Recommendation 5)
8.6. We recommend that, as part of any strategy
to address the research shortfalls identified in the EMERGNANO
report, the Government should ensure that specific research is
focused on the gut and the other knowledge gaps we have identified
above (paragraphs 4.18-4.27) with relevance to the risk assessment
of nanomaterials in food or food contact materials (paragraph
4.44). (Recommendation 6)
8.7. We recommend that the Government ensure
that a breakdown of annual public spending on nanotechnology-related
environmental, health and safety research within the United Kingdom
is compiled and available when the five-year review of its progress
against the 2004 Royal Society and Royal Academy of Engineering
report is carried out (paragraph 4.48). (Recommendation 7)
8.8. We endorse the recommendation contained
in the 2008 report of the Royal Commission on Environmental Pollution
that more attention should be paid to toxicology training. We
welcome, therefore, the Government's commitment to tackling the
shortage of trained toxicologists and ecotoxicologists and also
their commissioning of an evaluation of the United Kingdom skills
base for toxicologists and ecotoxicologists. However, the policies
to address the shortfall promised for this year have not yet been
launched. We look for urgent progress on this issue and ask that
the Government update the Committee on its activity in this area
(paragraph 4.52). (Recommendation 8)
8.9. We recommend that the Government work more
closely with other EU Member States on research related to the
health and safety risks of nanomaterials to ensure that knowledge
gaps are quickly filled without duplication of effort, while continuing
to support coordinated research in this area at an international
level through appropriate international organisations including
the International Organization for Standardization and Organisation
for Economic Cooperation and Development (paragraph 4.60). (Recommendation
9)
8.10. We recommend that the Food Standards Agency
develop, in collaboration with the food industry, a confidential
database of information about nanomaterials being researched within
the food sector to inform the development of appropriate risk
assessment procedures, and to aid in the prioritisation of appropriate
research. Industry participation in this database should be mandatory,
given the failure of similar voluntary schemes in the United Kingdom
and elsewhere (paragraph 4.72). (Recommendation 10)
Regulatory Coverage
DEFINITION OF NANOTECHNOLOGIES AND NANOMATERIALS
8.11. Given the uncertainty about the potential
risks of nanomaterials, it is essential that any nanomaterial
used in a food product (with the exceptions set out in paragraph
5.32) should to be subject to a formal risk assessment process
through the European Food Safety Authority. We recommend, therefore,
that the Government should work within the European Union to promote
the amendment of current legislation to ensure that all nanomaterials
used in food products, additives or supplements fall within the
scope of current legislation. We recommend in particular that
the legislation should, for the avoidance of uncertainty, include
workable definitions of nanomaterials and related concepts (paragraph
5.19). (Recommendation 11)
8.12. We recommend that the Government should
work towards ensuring that any regulatory definition of nanomaterials
proposed at a European level, in particular in the Novel Foods
Regulation, should not include a size limit of 100nm but instead
refer to 'the nanoscale' to ensure that all materials with a dimension
under 1000nm are considered. A change in functionality, meaning
how a substance interacts with the body, should be the factor
that distinguishes a nanomaterial from its larger form within
the nanoscale (paragraph 5.24). (Recommendation 12)
8.13. We recommend that Government should work
within the European Union to clarify the phrase "properties
that are characteristic to the nanoscale" through the inclusion
in the Novel Foods Regulation of a more detailed list of what
these properties comprise. This list should be regularly reviewed,
as the understanding of nanomaterials develops, to ensure it provides
comprehensive and up-to-date coverage of relevant properties (paragraph 5.26).
(Recommendation 13)
8.14. We recommend that, for regulatory purposes,
any definition of 'nanomaterials' should exclude those created
from natural food substances, except for nanomaterials that have
been deliberately chosen or engineered to take advantage of their
nanoscale properties. The fact that they have been chosen for
their novel properties indicates that they may pose novel risks
(paragraph 5.32). (Recommendation 14)
DISTRIBUTION OF PARTICLE SIZE
8.15. We recommend that the Government ensure
that implementation guidelines for legislation state clearly what
proportion of a bulk material has to be at the nanoscale for regulatory
oversight to be triggered (paragraph 5.33). (Recommendation 15)
NEXT GENERATION NANOMATERIALS
8.16. Given the pace at which novel technologies
develop we recommend that, in addition to its on-going monitoring
of the state of the science, the Food Standards Agency should
formally review the suitability of legislation every three years
to ensure that regulatory oversight and risk assessment keeps
pace with the development of these technologies (paragraph 5.34).
(Recommendation 16)
REACH
8.17. We welcome the Government's decision, in
response to the Royal Commission on Environmental Pollution's
report, to recognise that functionality, as well as size, should
be the focus of required revisions to REACH (paragraph 5.36).
(Recommendation 17)
8.18. We commend the Government's commitment
to address the issue of the one-tonne threshold for considering
the potential toxic effects of substances under the REACH Regulations.
We ask the Government to update the Committee on the progress
they have made towards meeting this urgent need (paragraph 5.37).
(Recommendation 18)
SELF-REGULATION
8.19. We recommend that the Government, in collaboration
with relevant stakeholders, support the development of voluntary
codes of conduct for nanotechnologies in order to assist the continuing
development of effective legislation for this rapidly emerging
technology. The Government should work to ensure that voluntary
codes are of a high standard, are subject to effective monitoring
processes and are transparent (paragraph 5.42). (Recommendation
19)
Regulatory Enforcement
RISK ASSESSMENT
8.20. We endorse the case-by-case approach taken
by the European Food Safety Authority in assessing the safety
of products. It allows the responsible development of low-risk
products where safety data are available and is, in effect, a
selective moratorium on products where safety data are not available.
It provides consumers with the greatest security and ensures that
unless a product can be fully safety assessed, on its own merits,
it will not be allowed on to the market (paragraph 6.12). (Recommendation
20)
8.21. We welcome the participation of the Food
Standards Agency in a European Union project which will investigate
methods for detecting and measuring nanomaterials in the food.
Ensuring that this research results in practical tests that can
be used by enforcement agents will be an important step in securing
the safety of food imports (paragraph 6.15). (Recommendation 21)
8.22. We welcome the assurance from the Government
that the Food Standards Agency will ensure that enforcement authorities
are made aware of the issues surrounding the use of nanomaterials
in imported food (paragraph 6.17). (Recommendation 22)
8.23. We recommend that the Government should
ensure that research into methods of measuring nanomaterials in
food results in the development of practical tests for enforcement
authorities to use on imported food, and develop a plan to inform
and educate enforcement authorities once such tests have been
developed (paragraph 6.17). (Recommendation 23)
GUIDANCE FOR COMPANIES
8.24. We recommend that the Government work with
the European Food Safety Authority as it develops guidance on
the implementation of the Novel Foods Regulation and other relevant
legislation. We urge the Government to state what steps they will
take to ensure industry and academia are involved in the development
of this guidance (paragraph 6.21). (Recommendation 24)
8.25. We recommend that the Government continue
to push for continued international dialogue and information exchange
on appropriate approaches to regulating the applications of nanotechnologies
in the food sector, and seeks to ensure that all relevant international
organisations are aware of the emerging implications of the development
of nanotechnologies (paragraph 6.29). (Recommendation 25)
8.26. We recommend therefore that the Food Standards
Agency create and maintain an accessible list of publicly-available
food and food packaging products containing nanomaterials that
have been approved by the European Food Safety Authority (paragraph
6.37). (Recommendation 26)
Effective Communication
CURRENT PUBLIC ATTITUDES TO THE USE OF NANOTECHNOLOGIES
8.27. 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 (paragraph 7.10). (Recommendation 27)
COMMUNICATION
8.28. 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 (paragraph 7.14). (Recommendation
28)
8.29. We recommend that the Government wok 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 (paragraph
7.19). (Recommendation 29)
8.30. 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 urge also that the Government, along with consumer
groups, should consider other means through which this information
can be made available and accessible to consumers (paragraph 7.24).
(Recommendation 30)
PUBLIC ENGAGEMENT
8.31. We agree with the Royal Commission on Environmental
Pollution 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 (paragraph 7.29). (Recommendation 31)
8.32. 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 representatives 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 concerns of, and 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 (paragraph 7.31). (Recommendation
32)
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