Nanotechnologies and Food - Science and Technology Committee Contents

Examination of Witnesses (Questions 300 - 314)


Ms Sue Davies, Professor Vyvyan Howard and Ms Georgia Miller

  Q300  Lord Cunningham of Felling: What about consumers being put off if it became a sort of black list?

  Ms Davies: We do not think that would be the case. The danger is more in not being open about what is happening in relation to nanotechnologies. We conducted a citizens' panel at the end of 2007 where we wanted to get a sense of what consumers thought about the use of nanotechnologies, not just in the food area but also in relation to medicines and cosmetics and other consumer products. People were not against it, if anything they were surprised it was happening because nobody had heard about nanotechnologies at all before they came along to the citizens' panel. Some people were obviously more excited than others but people were interested in it and felt that you should be open about it. I think the danger is that if you are not open about it at this early stage people will wonder why we have been hiding something and then think there is something suspicious going on.

  Q301  Lord Cunningham of Felling: Professor Howard?

  Professor Howard: I agree.

  Q302  Lord Cunningham of Felling: What about Georgia?

  Ms Miller: We also support a mandatory register. I do agree with Sue that the information required for something like that should not be too burdensome but at the same time we need to make sure that we have information that actually enables us to compare apples with apples. For example, it is not much good if someone just says that they are using nano-titanium dioxide and we do not know what shape, what size, what surface coating. We need to make sure that it is sufficiently detailed and enables rapid comparison of different known materials in use. However, I would just say this, if you are concerned about the public concern about the use of certain nanomaterials in food to be such that it did serve as a black list, I do not think that is a reason not to pursue this initiative. I think one of the things that comes through really clearly in the early public engagement around nanotechnology is that this is the most sensitive area of nanotechnology application. People feel strongly about food and should people, particularly given the early warning signs of risk and the huge safety gaps, choose not to buy food that contains manufactured nanomaterials then I would say that is their right and that is something that the government should reassure them on. That it will enable them to exercise that right because, as Sue said, I think the worse thing that could happen at the moment is that people feel they do not have access to relevant information and that is a cause for future concern.

  Q303  Lord Cunningham of Felling: What are the implications then of having such a mandatory register in one country but not in others?

  Ms Miller: I would suggest that countries everywhere at the moment are actually looking at these issues. For example, Canada has already announced a mandatory register of all companies who used a kilo or more of nanomaterials last year; they will have to provide information on the nanomaterials but also on the safety data they have. France has announced its intention to do something similar. There are calls in Australia from the unions for mandatory notification to workers. This is something that countries around the world are having to deal with right now. I do note in the recent proposals from the European Parliament they are suggesting that nanomaterials should not be permitted in foods without mandatory labelling on the product. That is something that we would support too.

  Q304  Chairman: Can I just ask a mini-supplementary to that to you, Georgia, since you have a good knowledge of the international situation. What is going on in China?

  Ms Miller: That is a good question because of course people have very limited information about what is going on in China and I would suggest that we have very limited information about what is going on in many parts of the world. I think there are serious language gaps and I also think there are serious deficiencies in governments relying so heavily on the OECD as the primary vehicle for communication about risk research and policy responses because a lot of the world is not represented in OECD and a lot of the OECD's communication is happening exclusively in English. I think we are faced with some very serious challenges.

  Q305  Lord Methuen: You have all mentioned in your evidence the need to take into account the public and society's interests and views when considering the future of nanotechnologies in the food sector. I think we all want to avoid a situation like the GM food fiasco. Could you expand on what you think these views and interests might be, and what government mechanisms should be considered as part of any approval process?

  Ms Davies: I think that the interests are quite broad ranging and it is really going to depend on the particular applications, so it kind of comes back again to the point about getting a clearer understanding of what is happening now and what we could be seeing over the next few years as well in order to have a proper understanding of what the issues are that could be raised. The obvious concern is about safety and making sure that products are not coming onto the market that could raise unacceptable levels of risk. There are issues around the sorts of claims that products are making and making sure that consumers can have confidence in them and that they are not mislead. For some products it may be that they will raise broader ethical concerns that people may have concerns about and may want to avoid for those reasons, but it is very difficult at the moment in these early stages to understand exactly what the breadth of concerns could be. We think it is important to engage with the public at this early stage but to try to actually talk about the potential applications that could be coming along to get a sense of how people would react to them. Ultimately I think you need to have much clearer information in order to actually look at it on a more specific basis in order to understand what kind of issues are going to be raised for consumers.

  Professor Howard: Certainly from discussions with people who are in the industry, they definitely want to avoid a GMO type scenario so they want to engage stakeholders. I would say that transparency at all levels is the best way forward and I think that is why I and the Soil Association would support mandatory labelling of products as well as this register so that everybody knows what is going on and awareness will be raised through that.

  Ms Miller: I think that the report from the UK Nanotechnology Engagement Group is worth a look; it is quite extensive but well indexed. It was published in 2007 after a couple of years of public engagement on nanotechnologies in the UK. Their key findings were that people were concerned about three key areas which were uncertainty and regulation and, in particular, whether or not regulation could deal with uncertainty and keep pace with risk management; the distribution of benefits and risks; and the question of public involvement. They made the point that these are issues that were also of concern during the GM controversy and I would suggest in relation to food a key question is: do we need nano in food? Why should the public accept any new risk at all when a lot of the applications are to improve the aesthetic properties of food or the flow properties of ketchup or to extend the shelf life of food which might be very useful for the food distributor or the food retailer but perhaps be of little use for the consumer? Why should the public accept new risks? I think these are three key areas that will be of concern to the public and I think perhaps the most challenging is the question of involving the public in decision making about nanotechnology in this very sensitive area. I think that is quite essential.

  Q306  Lord Haskel: Could I just ask Professor Howard, obviously an important part of public engagement is the way all these trials and tests that you have been urging us to carry out are carried out. For instance, are they going to be done on humans or are they going to be done on animals? How is it going to be done? Do you think this is an important part of public engagement? How do you think we tackle that?

  Professor Howard: We are not allowed to experiment on humans. The work we are going to do on Alzheimer's, for example, is in a mouse which has got a human Alzheimer gene in it—it is a well-characterised progress of that disease—and we are going to see if we can perturbate the progress of that disease by challenging it with various nanoparticles. That is the basis of the Neuro Nano EU project. When we have finished these studies they will be published in peer review journals and then after that hopefully, if they show anything, will become adopted in policy. That is a problem, in that policy obviously has to lag behind scientific knowledge. The most difficult step in a risk assessment is hazard identification. I can remember a number of us saying four or five years ago, "Well, with nanotubes they might have an asbestos-like activity" and other people said that that was just a theoretical thing, there was no evidence of that. Now we have two papers which give an indication that there might be a grain of truth in that. With these long term degenerative diseases—the protein misfolding diseases—we have the knowledge to say that that could be biologically plausible. We need to investigate it and assess it I think before we start dosing people. That is my feeling. I think all these things will feed into that risk assessment eventually.

  Q307  Earl of Selborne: I would like to continue this theme about public engagement. I would like to ask you all how you structure this public engagement dialogue. Clearly in the absence of concrete examples of nano food products the debate has to be at a fairly fundamental level. How do you engage the public in what many of us would see as a rather hypothetical exercise? Does the government have a role? Does industry lead? What role should consumer associations play? Perhaps Georgia could give us her views first on how you structure such a public engagement dialogue.

  Ms Miller: The first thing I would say is that before talking about how one does effective public dialogue (which is usually the focus of discussions in the social science literature and elsewhere), I think the primary question to ask is why. 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. I think that key question must be answered first: why? What are the objectives and what are the constraints and to be really clear about that. Secondly I would suggest there is an effective role for stakeholders such as consumers' advocacy organisations and other groups. I would suggest that there should be a broad range of community as well as industry, research and government stakeholders involved in dialogue together, but I do think that ultimately you need to hear what the general public think. There are a number of different ways that you can use deliberative models to actually resource random groups representing members of the public to consider various issues and I am sure you have all encountered different forms of consensus conferences or citizens' juries or what have you, but I would suggest that what you actually need is an oversight group which comprises stakeholders and government members and public participation practitioners to sit down once you have worked out what the goal of the objective is and to develop a programme that contains a variety of activities that has a discrete start and end point and it gives you some basis on which to start. I think that would be quite useful.

  Q308  Baroness Neuberger: Can I just follow that up with Georgia because I thought that was really interesting. You are saying that if government is not prepared to take what comes out of such public engagement seriously there probably is not a lot of point in doing it. If I were to suggest to you that even if government were not that interested maybe manufacturers and consumer groups would be, then would it not be worth doing even if government were not going to incorporate it into policy but maybe consumer groups and manufacturers would and maybe that has a value in itself?

  Ms Miller: I think it is certainly true to observe that of the many public dialogue activities which have been carried out to date and which have not resulted in any observable change to government policy, they have nonetheless had a value. I think that is certainly true and it is important to say that they have helped add to our understanding of what members of the public think about these issues, they have certainly been valuable for the groups who participated. However, I guess my point is really that for the government to back a public dialogue programme on this issue it would be of limited use if it is not seen to be genuine, so to have a genuine commitment to a two-way dialogue not just to, in a sense, engage for the sake of engaging without actually wanting to hear.

  Q309  Chairman: Sue, would you like to add anything?

  Ms Davies: I would agree with a lot of what Georgia has said and I think there has been a tendency with some of the public engagement that has been done in this area to do it in a very general sense so far and then kind of question the value of it saying, "Well, the public said what they always say about new technologies and it has not really taken us any further forward". I think it is important that you use deliberative techniques and it is as grounded in the potential applications as much as possible, and that there is a commitment to enabling it to feed into policy. It is also important to think about at what stage it actually happens as well and I think a crucial stage is looking at the type of research that is underway at the moment and what the focus of that should be, and understand what the public's views are. There are some interesting examples from the nano-medicine area, for example, where there was a citizens' panel that was held by the EPSRC (the Engineering and Physical Sciences Research Council) which directly fed into their decisions about what research to fund in this area. I think there is a role for public engagement at that kind of stage, but then there also needs to be government-funded research to understand what the public think more specifically in relation to nano-foods. When we did our citizens' panel—obviously there are limitations on what you can do—we found it very helpful to have people coming in and talking from different research associations. We had Vic Morris (who I think has given evidence) and Qasim Chaudhry come and talk about the potential applications and the regulations. It is very interesting how, over three days, the people who had no knowledge and potentially no interest in nanotechnologies at the start of the process became really, really engaged in it and by the end had developed quite sophisticated views on what they thought should be happening and what kind of regulations should be in place.

  Q310  Chairman: Could I just come back to you, Sue, on the point that Georgia made as to why one would want to start a public engagement exercise. Georgia made the point that if government is not going to take any notice of it there is no point in them initiating it, which then Baroness Neuberger put a slightly different slant on. If the government were going to take notice of public engagement, what would that notice consist of? Would it be to ban foods that the public were suspicious of? Or would it be to place public opinion ahead of science? What would the role be?

  Ms Davies: I think at this early stage where the debate is about what type of regulation we should have in place, it is to make sure that there is scope to deal with those concerns within the regulation. We talked about the Novel Foods regulation and one of the amendments that was adopted by the European Parliament was that you should have to take into account other legitimate factors, which is obviously a very vague term. As well as the scientific risk assessment there should be this scope within the regulation. If something appears to present very little risk but maybe raises some fundamental ethical concerns, then you have the scope within the regulations to say in certain cases that it is not appropriate to put that onto the market. It is partly about the regulation and it is partly about understanding how far that needs to go in terms of the type of information consumers want about nanotechnology development, but also in terms of shaping the research agenda that government is funding as well as just generally setting out a broader strategy for the way that nanotechnologies should evolve. There are obviously a lot of risks that need to be tackled but there are potential benefits and you need to make sure that it is taken forward in a way that ensures society in general benefits. That is also the purpose of public engagement. I would also agree with the points that were made about industry's role in this. Lord Selborne will know from the development of the Responsible NanoCode that one of the things that was proposed in that context was that industry should have some responsibility for doing some kind of public engagement as it develops products as well. I think one of the lessons from GM—you always have to be careful about comparing this to GM because it is obviously so very different—is that there was a real failure by the people who were developing the technology at the start of the food chain to properly appreciate the issues that were going to be raised at the end of the supply chain when products went on sale and what supermarkets' approaches would be to it as well. I think it is important to try to make sure that the people right at the very start of the food chain are actually understanding what kind of implications and what kind of expectations consumers may have, whether that is about product labelling or whether it is about the types of claims that are made as well.

  Q311  Lord Mitchell: Several organisations, in particular Which?, have suggested that there is a lack of awareness by the general public with respect to nanotechnologies, I think not surprisingly. I think all of you in your evidence have said in your evidence that products should have labels which talk about the inclusion of nanoparticles in food. I ask the question, given the plethora of information that is already on many food products, whether this is such a good idea.

  Ms Davies: I think it is a very difficult issue and it is very difficult while people know very little about the technology. We did a survey in November last year and 45 per cent of people said that they had heard of nanotechnologies—this was a representative sample of the UK—but when we actually asked them about what it meant very few people really understood what it was. I think there is the issue that any labelling has to be provided in the broader context of the need to provide more information to the public about what nanotechnologies are. It is something we asked when we did our citizens' panel just to try to get a sense of what people thought about it and the people who had been exposed to all this information about nanotechnologies for three days said that they definitely thought that they should know whether something was produced using nanotechnology, not for safety reasons (because they thought safety should be a given and you should sort out the regulatory processes and make sure you could do proper risk assessments) but because they thought it was a new development and it was something they would want to know about. They recognised that if we had asked them that on the Thursday before they had come for the weekend and had all this information it would not really have meant very much to them at all. On balance it is important in terms of transparency and it is also important in terms of having traceability not just for the end consumer but also throughout the whole supply chain, but it does need to be done and backed up with much broader information so that consumers understand what it means. I think at the moment we have a bizarre situation—I have brought a product with me—where you do have products on the market that say they are nano but there are other products that are produced using nanotechnology and they are not telling you that they are produced using nanotechnology so you are going to have an incredibly complicated situation. The other thing is that, as you probably know, the cosmetics regulation has recently been reviewed by the EU and within that there is a requirement that ingredients in cosmetics will have to say whether they are produced using nanotechnology or not. If consumers start to become familiar with cosmetic products stating whether or not the ingredients are nano then it would seem very bizarre not to give them that kind of information in relation to food.

  Q312  Lord Mitchell: Do you not think that there is so much information that appears on things that we buy, then to have that on is a degree of overkill? Maybe the solution would be to have an internet site that people could go to to get this information.

  Ms Davies: That is often put forward as a solution for labelling problems. I appreciate there is a lot of information on the labels and there is a real move to reduce packing size as well at the moment. However, I think it still excludes an awful lot of people who are not going to actively go to a website and a lot of people want the information at the point when they are making decisions about buying products so I think that means that it should be on the label. If it is put in the ingredients list it is not too onerous. At the end of the day people are choosing to buy a particular product and people are genuinely interested in knowing what the ingredients are and if there are any new types of production processes that have been used in that product. I think it comes back again to getting a clearer picture of exactly what kind of developments are taking place and maybe further down the line there will be some applications that people are not particularly so interested in as others, but I think as a general principle it is important that consumers can have this kind of information.

  Q313  Chairman: I wonder if Georgia would like to add anything to what has been said about labelling.

  Ms Miller: I think actually that Sue's point is a really good one, that people may not care so much about labelling when they have not heard very much about nanotechnology but once they become familiar with nanotechnology and its applications, then labelling becomes something that they support quite strongly. This to me suggests that over the next few years, as public awareness about nanotechnology grows, so too will support for labelling and clear mandatory labelling at the point of sale so that people can make informed purchasing choices. If that is something that is not supported now, particularly in relation to food, I think we can expect a backlash from the community later on as public awareness about nanotechnology grows. I also just wanted to add something to the previous conversation about the ways in which public participation can inform decision making around nano because I actually think there are perhaps four or five key areas. One is around innovation policy and in a sense we need to think about both nanotechnology policy and how it relates to other innovation objectives, and technology and non-technology options to meet key areas of social and environmental need. The other is around food and agriculture, what sort of food and agriculture policy we want to support and whether or not nanotechnology actually complements or undermines other objectives we might set ourselves, for example improving the ecological sustainability of agriculture or reducing food miles or helping improve local food security and issues like this. The other is around government strategy and I think that the public should have some opportunity to be involved in setting the strategy as far as nanotechnology oversight in the UK and elsewhere. The third area is in research priorities which is something that we have talked a bit about already and where the research money should be invested. We must recognise that, like any technology development, nanotechnology is mutable and what we get at the end will be partly influenced by what we put in at the beginning in terms of research focus. The fourth area is in commercialisation. I am not so familiar with the situation in the UK but I know certainly in Australia our Government supports commercialisation of nanotechnology products; it gives grants to companies to bring to market certain products. This is quite an influential area of innovation policy but again all of these areas that I have talked about so far are outside regulation; they are outside the area that we typically focus all our attention on. I guess that the point I wanted to make is that we really need to open up innovation strategy, research priorities and some of the upstream parts of technology development to public dialogue and not just focus on regulation because if we do that then in a sense we have already committed ourselves to a certain path.

  Q314  Lord Crickhowell: Georgia has taken me to the question that I wanted to ask and I was going to address it probably to Professor Howard. In all our sessions we come up with three things: do not know, lack of research (particularly in critical areas like the gut), difficulty of validation and risk assessment. How do we get the research focus better? This is a worldwide thing, but clearly the research focus is not ideally where it should be at the moment.

  Professor Howard: I think that the EU and some of the research councils here in the UK are giving very focused research grants to look at specific problems. They are to do with uptake studies, distribution studies and toxicology. That is what we need. There is quite a large amount of money being devoted to that. If I could harp back for one second to what was being said before, I think the very term "nanotechnology" is a problem for the industry because it does encompass a large number of enabling technologies going from microscopes to nano-structured surfaces on self-cleaning glasses, many of which are not in the slightest bit threatening, but they all come under that heading. What we are addressing here with food is a specific problem of increased and inappropriate mobility of substances through the body. I think that because it is that subset it might be rather easier than we think to communicate that. That is certainly where the research is focused at the minute, mobility and toxicology.

  Chairman: Thank you very much. I would like thank all of our witnesses for helping us to explore some of the issues that we put before you. I would like to confirm that copies of the transcript will be available for you to comment on before it is finally published. Also, if there are any points that you have not been able to elaborate on sufficiently that you would like to write into us about, please feel free to do so and those points would also be published along with the rest of our written evidence and with the transcript. With that I would like to thank you all very much indeed for joining us, including Georgia from Australia. Thank you very much, Georgia.

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