Nanotechnologies and Food - Science and Technology Committee Contents

Examination of Witnesses (Questions 280 - 299)


Ms Sue Davies, Professor Vyvyan Howard and Ms Georgia Miller

  Q280  Chairman: Thank you very much. Georgia, would you like to introduce yourself?

  Ms Miller: Thank you. My name is Georgia Miller. I have coordinated Friends of the Earth Australia's nanotechnology project since 2005 and the application of nanotechnology in food and agriculture is something we are very much interested in. Last year I was one of the two primary authors of an international Friends of the Earth report in relation to nanotechnology in food and agriculture. I guess that there are four key things that I am hoping we can talk about in this session. The first is really the scope and I want to suggest that we are looking at more than a question of food safety, we are actually looking at quite a broad issue of food policy. The second is the need for precautionary management given how little we know both about risks and also how to assess those risks. The third is the need to really critically assess claimed benefits because I want to suggest that many of these benefits actually come with significant costs. The fourth is the need for public involvement in decision making which I understand will be addressed in some of the questions later.

  Q281  Chairman: Thank you very much. That is a very helpful introduction from all of our witnesses. I would now like to kick off with opening the questioning myself and I would like to ask each of the witnesses what you feel are the potential benefits as well as the risks related to nanotechnologies and nanomaterials in food, either in food itself or in relation to packaging. You have all expressed views about this in your evidence but I would like to hear now a summary of your position.

  Ms Davies: I think one of the difficult issues in this area is that it is hard to get a sense of exactly what is happening now and what could be happening in the future in order to determine whether or not there are products that are going to offer real consumer benefits. From looking at some of the discussions in the scientific press and some of the food technology literature it seems that there is a lot of potential for things like improved nutritional characteristics, improved sensory qualities, potentially less waste in terms of improved packaging, better food safety; there are a whole range of potential benefits that could be offered by nanotechnologies. However, our concern is that it is quite difficult to work out exactly what we are going to be seeing and over what timescale. It would be nice to have a clear idea of what is on the market now and have a sense of what is going to be here in five years, ten years, 20 years and what kind of issues are those going to raise. We do think that it seems there are going to be some genuine benefits but we also think there needs to be a more proactive approach to actually make sure that the investment is really going into tackling the problems we are facing in terms of food policy. How can nanotechnology be used to help tackle obesity and diet-related disease, improve food safety, reduce the environmental impact of food production? There is not really enough transparency or enough open discussion at the moment about what is being done and what could come along. If you look at the Nanoshop website or you look at the Woodrow Wilson website, which seems to be the main source of information about nanofoods, most of the developments to start with are in the food supplement area which are making claims about improved bioavailability or absorption of nutrients, or packaging materials (EFSA has already approved one type of packaging material, for example). That seems to be where the main interest is at the moment and it seems that there could be benefits, certainly in the case of packaging materials, but we are concerned that we want to make sure that these are genuine benefits and that consumers, as Georgia said, are not being duped into buying things at the moment that are not really offering any benefits beyond conventional products and paying more for it. Of course this all needs to be balanced against the risks. Do you want to come on to the discussion about the risks now?

  Q282  Chairman: If you could briefly way what you think the main issues are about risk then we will cover it in a bit more detail later.

  Ms Davies: The interesting thing in this area is that the people who are really excited about this technology are also really open about the fact that there is an awful lot that we do not know about it at the moment; precisely the reason why nanotechnologies are going to offer lots of new benefits because of the change in properties of materials could also bring new risks that we do not fully understand. The recent EFSA opinion on this, for example, highlights that there are some really key knowledge gaps in different areas that need to be addressed urgently. We think that we need to have a clearer sense of what products are coming along so that we can get a sense of what are the benefits and what will be really useful for consumers, but also we need to get a sense of what is being developed now so that we can properly understand what kind of risks they could be posing and make sure that we have adequate regulation in place as well.

  Q283  Chairman: Thank you. Professor Howard?

  Professor Howard: I want to highlight some of the knowledge gaps and areas of potential hazard. Under Framework Seven of the EU Programme there are 1.4 billion euros earmarked for nanotechnology but every project must have a safety aspect to it. The two grants that we have so far total 5.7 million euros. There are also targeted funds from research councils in the UK so there is certainly an awareness that we need to know more. Indeed I and other colleagues around the world are trying to do that. There are two basic questions. One is, if you have a nano-product—a particle in a food substance—where does it get to and how long does it stay there? That is question number one and in a way that is one of the easier questions to address. The second question is, does it matter if it does get there and stay there that long? That is actually much more difficult to appraise. I think we have to think about the nature of food. If you consider how much we spend on doing toxicological testing of pharmaceuticals and agro-chemicals, where we might expect to be exposed over a lifetime to micrograms or milligrams, our consumption of food is measured in tons over a lifetime. So the potential dosage is extremely high and I think that does mean that we have to take a precautionary stand. The main area that I am worried about is that if you nanonise materials into mobile nanoparticles they become more mobile within the body. The reason for that is that there are processes going on in the cell walls which are continuous and it is the way that viruses get round it, it is a process called endocytosis. There are quite a few studies on this—Wolfgang Kreyling has done a lot of work in this field—which show that if you do expose animals or humans to nanoparticles they will travel and they will get across places like the blood-brain barrier where we have evolved methods of keeping out molecules that we do not want. So they can act as a sort of "Trojan horse". Which particular spectrum of disease do we need to think about most? Well, there are a series of diseases called protein misfolding diseases. Most of them occur in the central nervous system; there are 42 known in humans currently (including Alzheimer's, Parkinson's disease, spongiform encephalopathy). Nerve cells cannot reproduce themselves; they have to internalise any misfolded protein that is insoluble and some of these fragments can be toxic. The worry would be that if we are exposing ourselves to large doses of nanomaterials and they are able to get into areas like the brain, they might be able to increase the rate of protein misfolding and that is what our second grant is all about. We are actually studying that now.

  Q284  Chairman: I wonder, because we are short of time, if you could keep it pretty succinct. We can always follow up with more detailed supplementary evidence.

  Professor Howard: I think that is the main point I want to make, that it is chronic long-term pathology which may be rather more worrying than short-term toxicity.

  Q285  Chairman: What about potential benefits? Do you see any benefits?

  Professor Howard: I think Sue has already mentioned those: a cut in waste, a cut in bacterial contamination; those sorts of things.

  Q286  Chairman: Georgia, would you like to comment on the potential benefits and risks?

  Ms Miller: Vyvyan has just talked in some detail about potential risks and I saw the excellent presentation that the nanotoxicologists made to you a month ago, so I do not want to talk in great detail about the risks. I do want to observe that the uncertainties around nanocharacterisation and risk assessment are so great that experts anticipate that it will take us years before we can actually do a validated risk assessment, that is until we know the right questions to ask, the right tests to do. I find this very concerning so that is one thing I do want to draw to your attention. I guess the other thing that I am concerned about is the size definition. Again I heard a recurring theme when the nanotoxicologists gave evidence to you a month ago that 100 nanometers really does not capture biologically relevant nanoparticles that may be 200 or 300 nanometers in size, so I think that is something we are also concerned about. In relation to the so-called benefits, I really want to challenge the notion that widespread use of antibacterials, for example in packaging, will deliver socially useful outcomes. This is for a couple of reasons. We are very concerned that widespread use of potent antibacterials in the form of nanomaterials could actually cause a lot of unanticipated problems. We are already suffering massive problems with bacterial resistance to antibiotics in a medical setting. There is some emerging evidence that use of silver in a medical setting is also being met with resistance. What are the implications of the widespread use of nano-antibacterials in food packaging, in refrigerators, in storage containers, as well as in socks and computer keyboards and dishwashers et cetera? I think there are some very real challenges here that we need to deal with. While we do not think any illness as a result of food contamination is ever acceptable, I emphasise that in the UK there is 50 times greater illness as a result of poor diet than as a result of safety problems. I think we need to ask: will nanotechnology as a whole result, for example, in greater consumption of highly processed food and less consumption of fruit and vegetables? Will the addition of nano-additives to junk foods enable them to be marketed for health values, for example increased nano-encapsulated omega-3 or iron fortification? Will this perhaps further confuse people and lead to a further loss in terms of people's diet choices? If the answers to those things are "Yes" then it is possible that nano will actually result in poorer health outcomes. I do think we need to query a lot of these claimed benefits, really interrogate them, rather than just accepting them at face value.

  Q287  Chairman: Thank you very much. I just want to ask one supplementary question here. I think that Friends of the Earth Australia as well as the Soil Association are calling for a moratorium on the sale of nano-foods whereas I think Which? has not called for a moratorium. I wonder if Sue could indicate from the point of view of Which? why you do not think a moratorium is necessary, and then I will ask Vyvyan and Georgia briefly to say why they think a moratorium is necessary.

  Ms Davies: I suppose our focus has been much more on understanding what developments are taking place and could be taking place, making sure that we have an effective regulatory framework in place, making sure that nanomaterials have to be approved before they come to market and that we have enough research to enable effective risk assessment to be able to carry that out. We do not really think that a moratorium is very meaningful. We have issues around definition, it is very difficult to find out what is actually happening, so even if we thought that a moratorium was useful we do not understand how it would practically be enforced and applied.

  Q288  Chairman: Professor Howard, could you briefly indicate why you think a moratorium is necessary?

  Professor Howard: Data gaps have already been mentioned and we find it very difficult to construct a meaningful risk assessment given the level of data gaps that we have in most areas of nanoparticle fate and toxicity. Given the potential dose that people would be receiving in food, the Soil Association has come to the conclusion that they would prefer to see a hold on development while some form of risk assessment can be developed.

  Q289  Chairman: Would that apply to naturally occurring as well as engineered nanoparticles?

  Professor Howard: I think that applies mainly to engineered nanoparticles, things that we have not encountered hitherto during our evolutionary history.

  Q290  Chairman: Georgia, very briefly, reading the evidence from Friends of the Earth Australia, you wish to broaden the definition of nanotechnologies in food to include both engineered and naturally occurring nanoparticles. That is as I understand it; is that correct or not?

  Ms Miller: No, that is not correct. What we have suggested in terms of broadening the definition is that we consider, for the purposes of health and safety assessment, particles up to 300 nanometers in size as nanoparticles and I believe there is good reason given the evidence that a number of particles that are around 200 nanometers or so in size are still, for example, showing protein binding characteristics that Vyvyan referred to earlier as a cause for concern. We have focused specifically on the issue of manufactured nanoparticles and manufactured nano-additives to food. We do highlight the issue of nanoparticles which are in a sense a by-product of contemporary high intensity processing technologies as an area which does warrant further investigation, but we have not called for a moratorium to extend to those sorts of nanoparticles.

  Q291  Lord Haskel: Of course our relationship with the European Union is very important and central to this. The European Parliament has proposed that when the Novel Foods regulation is revised it should explicitly apply to all nanomaterials; it does not differentiate. Do you think the government should accept this advice?

  Ms Davies: We think that a distinction does need to be made between manufactured nanomaterials and the types of nanomaterials that have been traditionally used and may use nanotechnology, so things like custard or mayonnaise for example that have been around, not to say that these are inevitably risk free. We think that manufactured nanomaterials should be the focus of the Novel Foods regulation. We think that the definition that was proposed by the European Parliament which talks about in the order of one to 100 nanometers is probably quite useful but you need to be careful about being too strict about definitions because there is still an awful lot that we do not understand and some people are asking whether we should be talking of up to 300 nanometers for example and the surface area is obviously a crucial aspect and how do you take that into account. The proposal from the Commission takes into account the advice from the European Food Safety Authority. We think it should be focused on the manufactured nanomaterials but it is also important to look at other pieces of regulation as well as the Novel Foods regulation to make sure that they are fit for purpose as well. The European Commission has said that it feels that under the food additives legislation, for example, if something was in nano form it would have to be reassessed and, even if its conventional form had already been approved, it would have to be resubmitted and approved again. Similarly with food supplements, if you are using vitamins and minerals in a nano form they would have to be submitted. There is a lack of clarity in the regulations and with the associated guidance that all needs sorting out at the moment and we are concerned, about how you can you be sure that people who are potentially looking at producing these types of products actually understand what applies to them and what route they need to go through, and whether the enforcement people on the ground, the trading standards officers understand. It is hard to believe that looking at whether people are using nanomaterials is a particular priority at the moment given all the things that trading standards or environment health officers are looking at. We think the Novel Foods regulation needs to be focused but it needs to be broad enough to take account of all manufactured nanomaterials. But we also need to focus on the other pieces of legislation that may be relevant to make sure that they take account of the unique properties of nanomaterials. It is no good just having it in the legislation; you need to make sure that the people on the ground actually understand what the implications are as well.

  Professor Howard: I approach these problems by saying that if we have been exposed to something throughout our evolutionary history it is quite likely that we are going to be adapted to it and be able to cope with it. When something is brand new—you only have to look at some of the chemicals that we have created that bio-accumulate and persist and have hormone-disrupting capabilities—you have to take a precautionary stance and then look at where it might have unforeseen effects and do a proper risk assessment.

  Lord Crickhowell: I have one question which I think does arise from regulation and the re-examining of regulation. I would be interested to hear Georgia's comments. We have been talking entirely about food but she referred to agro-chemicals and I do wonder whether included in her concerns are fertilizers and agro-chemicals. I would like to know whether this is part of the package or not.

  Q292  Chairman: Georgia, would you like to comment both on the European regulation but also particularly whether you think we should be concerned about the use of nanotechnologies in fertilizers and pesticides, agro-chemicals?

  Ms Miller: It was not my understanding that the new European Parliament's suggested amendments were to encompass naturally occurring nanoparticles so I do not want to comment specifically on that because that was not my understanding. I do agree with both Sue and Vyvyan that we need to focus our attention on intentionally manufactured nanomaterials which are novel materials to which we have no history of exposure. I do want to emphasise though that where manufacturers are intentionally producing nano-scale micelles or using nano delivery systems for active ingredients this may introduce new issues and so we should consider those as intentionally manufactured nanomaterials where there are intentionally putting active ingredients, for example, into 30 nanometer micelles; there may be a biological implication there. On the issue of whether we should also be looking at nano formulated agricultural pesticides and fertilizers, yes I believe we should. I think we need to engage with some of the broader framing which is going on. When we read some of the predicted uses to which nanotechnology will be put in agriculture the vision is really quite broad and encompassing, whether it is nano-automated farm systems or whether it is the use of smart interactive nano-encapsulated pesticides and fertilizers, or whether it is the use of nanoparticles to extend the reach of genetic engineering in seed manipulation. There is a broad range of proposed uses for nanotechnology in the agricultural context and I think these are very relevant to a discussion of nanotechnology in food.

  Q293  Lord Haskel: How practical is it to engage in this differentiation? For instance, we modify existing natural products into nanoparticles; are those manufactured and engineered or are those natural products? It seems to me that we are approaching a regulatory minefield here.

  Ms Miller: I think it is confusing so the approach we have taken is to focus very squarely on intentionally manufactured nano ingredients and additives, not so much to look at how nano science is informing our historical use of emulsions and production of emulsions but rather to look at things like nanoscale zinc which is being intentionally put in as a food additive or nanoscale silver which is being added to food packaging or whatever it is; to look very clearly at those intentionally manufactured nanomaterials. Having made that distinction and focusing very squarely on that range, people are going to a lot of trouble and expense to actually produce these things in nano form and then to put them into food or food packaging. We then recognise that there is a need to actually look at the things which are, for example, by-products of modern food processing technologies. We are not including these in our call for a moratorium and we are not suggesting even that they be addressed by the regulatory system, but we are recognising that contemporary food processing technologies do generate a lot of foods which have nano fragments, nanoscale emulsions within them. I think it behoves us to ask: is there any public health implication there? I do think that if we all focus very clearly on the intentionally manufactured nanomaterials both for regulatory purposes and for the purposes of this inquiry I think we will be better off.

  Professor Howard: I think that if you take a natural product and you treat it in some way by, say, encapsulating it, and you change its dynamics from the way it normally behaves, that is the time you have to look. Just harping back for a second to pesticides, as I said before I have just finished six years on the Advisory Committee for Pesticides which is where risk assessment for pesticides is done, and they can see this nano revolution coming. I did flag it up a couple of years ago and I think they are considering maybe getting someone on that Committee who has expertise in the field to maybe be able to put some input; they are certainly going to need it.

  Q294  Chairman: Before moving on to ask Lord O'Neill to introduce the next question, could I just try to nail this question of definition and what your concern is. We have heard from the expert toxicologists in previous sessions that their concern is particles that are persistent or have particular functionality or reactivity in the body on a nanoscale, not whether they are manufactured or natural. You seem to be focusing on manufactured versus natural as opposed to persistence and reactivity or functionality. Could I just be absolutely clear where you think the critical issue lies?

  Professor Howard: Persistence for how long is a good question. Clearly if they are metal nanomaterials they may persist for years but if you look at what the pharmaceutical companies are doing they are using microsomes to encapsulate drugs to increase penetration to the brain. There is a lot of research going on; it is a difficult place to get drugs but they find that if they use micro-encapsulation techniques they can increase penetration of the blood-brain barrier. That has to tell us something about what will happen in food products and if there are things that do not normally go there they may only have a half life in the body of somewhere around half an hour to an hour, but if you are taking in a very large dose of those there may be significant penetration. It really depends on what you mean by persistence and what it means for that particular set of particles. I do agree in general that long-lived metallic nanoparticles are things that we have to be very careful about.

  Q295  Chairman: Georgia, did you want to add anything on that because you have quite a broad ranging definition in your evidence?

  Ms Miller: I did not actually see that distinction in the evidence that the nanotoxicologists gave you; I did not see them suggesting that we encompass naturally occurring nanomaterials in the sort of dialogue that we are having right now. In fact it seemed to me that they were talking about their concern about nanomaterials to which we do not actually have a long history of exposure. However, I do agree that persistence and functionality are obviously going to have biological implications for the impacts that nanomaterials may have when introduced to our bodies. The thing that concerns me is that when we talk about persistence that presupposes a level of knowledge about the biological behaviour of nanomaterials that we just do not have. I think that is one of the reasons that we have made this strong emphasis on focusing on intentionally manufactured nanomaterials because these are things which we are producing in this very tiny form and, as Vyvyan says, sometimes in this very tiny form there are unique biological availability and behavioural characteristics of these materials. I do think it is useful to focus on manufactured nanomaterials and I would include in manufactured nanomaterials things which have been nano-encapsulated for the purposes of altering their bioavailability or their behaviour in the body. I do think there is a danger in defining nanomaterials by biopersistence when we have so little understanding of their biological behaviours.

  Q296  Lord O'Neill of Clackmannan: Perhaps I could come back to Vyvyan Howard. We have been talking about problems of definition and we have been saying that there are categories in which there is a reasonable degree of consensus, but then when it comes to issues of control you would apparently favour, as it were, a one size catches all approach; you would favour the generic approach rather than a case by case element of control. Could you perhaps say how that sits alongside the categorisations which you have been groping towards in the previous questions?

  Professor Howard: I feel there are many generic aspects to this. Clearly size is something which is associated with mobility, whatever the material. If you consider the amount of money that is being pumped into grants for labs like Ken Donaldson's (who was here) and my own to actually look into these generic problems where we have vast areas of ignorance and are trying to find out the way they perform and what the consequences are likely to be, I think to ask individual manufacturers to go and do that level of research is going to be impossible for them really, it is much too expensive and they would not have the expertise. My feeling is that we need to fill in some of these boxes in the hazard assessment of these materials so that we can start to categorise them and know that this size range looks as if it is relatively safe or this size range is to be avoided because it gets to certain places. I think there is a lot more spade work to be done before we start to put the onus on manufacturers.

  Q297  Lord O'Neill of Clackmannan: Are there difficulties or dangers implied in a box ticking exercise which does not get behind the questions in quite the way that the safety considerations that we all have would seem to require addressing?

  Professor Howard: In 2004 I sat on a committee which met in DG SANCO and as part of that exercise we tried to construct a comparative hazard assessment with hazard triggers (which can be done with pesticides where there is a lot of toxicological information; you can actually make a sensible stab at it) and all the boxes that we made for hazard triggers we realised very rapidly were unknown; we did not know the answers. That is the main thrust of the research that is going on now, to try to actually get that knowledge so that we can attempt a meaningful risk assessment, but we are not there at the minute. It is a very expensive avenue of research; it requires extremely expensive instruments (electron microscopes and things like that). My feeling is that we are at the stage still where we want to learn more before we potentially expose a population to high dose.

  Q298  Lord Cunningham of Felling: I address my question to all three witnesses, if I may. What would be the merits of a register of nano-derived foods and food contact materials as part of a comprehensive regulatory framework?

  Ms Davies: We think it is something that is essential because at the moment—I think for the last few years—we seem to have been going around in circles where it is very difficult to get a sense of exactly what is happening in this area. A few years ago there was a lot of talk, as we put in our written evidence, in some of the food technology press about all the potential applications and research that was going on, that leading food companies were conducting, but now the food industry says that in general it is not using nanomaterials in its products. If you look on the internet you will find various products: you will find cooking oil, you will find food supplements that are on sale coming from different countries claiming to be using nanomaterials. It also seems that some of the kind of intermediaries like the chemical manufacturers are also producing some food additives that are produced in nano form. It is very difficult to get a sense of exactly what is on the market. We think the regulators—mainly the Food Standards Agency—need to be much more proactive in actually going out and seeking the information and finding out what is happening in this area, including talking to the chemical companies who are producing food additives or food pesticides and understanding exactly how much they are producing and who they are supplying to. We also think there needs to be a requirement that you should register if you are going to use manufactured nanomaterials in your products and that should apply to food but should also apply across the board in relation to nanotechnologies and nanomaterials.

  Q299  Lord Cunningham of Felling: Do you think the FSA is the appropriate regulatory body?

  Ms Davies: For food definitely and we think it should be mandatory because, as I am sure you know, Defra has had this voluntary reporting scheme that was launched over two years ago and has only had 11 submissions on a voluntary basis. I think it has to be mandatory but you also need to think carefully about what the information requirements are so that companies are not put off by something that is incredibly onerous and complicated to fill in but gives the regulator the key information that they can then follow up if they need to.

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