Nanotechnologies and Food - Science and Technology Committee Contents

Supplementary memorandum by Friends of the Earth Australia

  Friends of the Earth Australia (FoEA) suggests that a moratorium on commercial use of manufactured nanomaterials in foods is essential until:

    — validated, nano-specific risk assessments and detection methodologies are designed and implemented, and regulatory gaps are closed;

    — nanotechnology's broader implications for food and agriculture are assessed, in particular its implications for public health, and for food security and food sovereignty;

    — the public is given the opportunity to participate in nanotechnology decision making, including the right to reject the development and sales of nanofood; and

    — all nanofoods face mandatory labelling on products at point of sale.

  FoEA suggests that there are six key reasons to support a moratorium:

    — the science demands a precautionary approach to risk management;

    — the public expects governments to ensure food safety—which is not currently possible in relation to nanofoods;

    — the public has not been given an opportunity to be involved in nanotechnology decision making, but early findings suggest that people do not support the use of nanotechnology in food;

    — there is no social benefit in permitting the sale of nanofoods before they have undergone rigorous, validated nano-specific safety assessment, broader socio-economic challenges have been assessed, and the public given the opportunity to take part in decision making;

    — at a time of global food crisis, nanotechnology's broader implications for food security and food sovereignty must be assessed critically; and

    — a failure to support a precautionary, transparent and inclusive approach to decision making in this sensitive area of nanotechnology development is likely to result in a further erosion of public confidence in science and technology governance.

The science demands a precautionary approach to risk management

  The scientific justification for requiring proponents to demonstrate the safety of nano-products before they can be sold was accepted in 2004 by the United Kingdom's Royal Society and Royal Academy of Engineering. In their report they recommended that: nanomaterials be treated as new chemicals; nano-ingredients in products be required to pass rigorous safety assessment before commercial use is permitted; nano-ingredients in products be labelled; nanomaterials in factories and workplaces be treated as if they were hazardous; and the environmental release of nanomaterials be avoided as far as possible (RS & RAE 2004). Global reinsurance agent Swiss Re called even more explicitly for precautionary management of nanotechnology risks: "In view of the dangers to society that could arise out of the establishment of nanotechnology, and given the uncertainty currently prevailing in scientific circles, the precautionary principle should be applied whatever the difficulties" (Swiss Re 2004, p 47).

The 1992 Rio Declaration on Environment and Development describes the precautionary principle as follows: "Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost effective measures to prevent environmental degradation" (United Nations 1992). There is preliminary evidence of serious nanomaterial health and environment risks (UK RCEP 2008; SCENIHR 2009), acknowledgement by leading researchers that the extent of uncertainty is such that even design of reliable risk assessment systems for nanomaterials is impossible (EFSA 2009; Hansen 2009; Oberd½rster, Stone, and Donaldson 2007) and predictions that validated nano-specific risk assessment methodologies may take up to 15 years to develop (Maynard et al 2006). It is for circumstances such as these that the precautionary principle was intended.

The public expects governments to ensure food safety—which is not currently possible in relation to nanofoods

  It is perhaps self-evident, but useful to highlight nonetheless, that the public expects that the government will implement rigorous safety assessments for all food ingredients, but especially those produced by uncertain new technologies, prior to products being permitted for commercial sale. Early public engagement exercises show that key public concerns relate to the new health and environmental risks associated with nanomaterials, and the ability of governments to ensure their appropriate regulation (Macoubrie 2006; Gavelin et al 2007; German FIRA 2006; Halliday 2007). It would be a major breach of the public's trust to permit the sale of nanofoods, containing manufactured nanomaterials that may introduce serious new risks to human health and the environment, when experts including the European Food Safety Authority agree that it is as yet impossible to design nano-specific risk assessment procedures in which we can have confidence (EFSA 2009; Hansen 2009; Oberd½rster, Stone, and Donaldson 2007).

The public has not been given an opportunity to be involved in nanotechnology decision making, but early findings suggest that people do not support the use of nanotechnology in food

Public awareness about nanotechnology remains very low. However, early surveys show that once given information about nanotechnology, people do not want to eat nanofoods or foods wrapped in packaging that contains manufactured nanomaterials. Public engagement initiatives and experimental studies conducted in the UK suggest that once provided with information about nanotechnology, the public is concerned about many of the same issues identified in relation to GE food: a lack of transparency, a lack of choice about exposure, risks to health and the environment, unfair distribution of risks and benefits, a lack of socially useful applications and a lack of public participation in decision making (Gavelin et al 2007).

Public concerns about nanotechnology are greatest when nanotechnology is applied to food. Participants in a 2006 consumer conference in Germany, organised by the German Federal Institute for Risk Assessment (BfR), expressed the most serious reservations about nanotechnology when it was applied to foods (German FIRA 2006). A year later the BfR conducted a survey of 1,000 people and found that a majority of people not only do not personally want to eat nanofoods, but also think that nanotechnology should not be used in food applications at all. 60 per cent of survey respondents were against the use of nano-additives to prevent spices from becoming lumpy; 84 per cent rejected the idea of using nanomaterials to make foods look appealing for longer (Halliday 2007).

  A study conducted in the German speaking part of Switzerland also found that people did not want to eat nanofoods or foods wrapped in nano packaging (Siegrist et al 2007). Similarly, a United States survey of 1,014 adults found that only 7 per cent of respondents were currently prepared to purchase foods produced using nanotechnology. 29 per cent would not purchase food produced using nanotechnology, while 62 per cent wanted more information about health risks and benefits before they would consider buying nanofoods (Peter D Hart Research Associates 2007). Polling of 1,010 Australians commission by FoEA and carried out by Essential Research found that 92 per cent of Australians supported mandatory labelling of nanofoods, 96 per cent supported mandatory nano-specific safety testing of nano-ingredients in food and packaging, and only 15 per cent were currently prepared to purchase nanofoods (Essential Research 2008).

  Mandatory labelling of all nanofoods is required to enable people to make an informed choice about whether or not to eat them. However beyond the need for labelling to enable informed purchasing choices, the public must be given the opportunity to be involved in decision making about the use of nanotechnology in the food and agriculture sector. Given the significant implications of nanotechnology for our relationship with food and agriculture, and for food producing communities worldwide, we call for public involvement in all aspects of decision making, including the right to say no to nanofoods.

There is no social benefit in allowing the sale of nanofoods before they have undergone rigorous, validated nano-specific safety assessment, broader socio-economic challenges have been assessed, and the public given the opportunity to take part in decision making

  There have been claims by some proponents that nanofoods will deliver a social benefit that should be weighed against new toxicity risks. FoEA rejects this framing of weighing "benefits" against "risks" for three key reasons. Firstly, we recognise that such framing ignores social concerns related to nanotechnology ownership, access, controllability, equity, sustainability and other issues. These issues, which have nothing to do with risk, were all important to the UK public in relation to genetically engineered foods, and early studies suggest that they are similarly important to the UK public in relation to nanotechnology (Gavelin et al 2007). Secondly, we recognise that many of the claimed benefits are either trivial, accrue to manufacturers rather than consumers, or come with their own health and social costs. Thirdly, we think it is entirely inappropriate to use claimed benefits to counter-balance risks, particularly given that the qualitatively new types of hazards associated with nanotechnology demand a greater use of precaution than ever before (Dupuy and Grinbaum 2006; Ravetz 2005).

Beyond the need for new regulation to manage the serious new toxicity risks associated with nanofood and nano agricultural products, Friends of the Earth Australia is calling for "fourth hurdle regulation" to require manufacturers to demonstrate the social benefit of products they wish to sell. Too often, it is an entrenched and unchallenged assumption that the market release of a new functional food or antibacterial product will necessarily deliver public health benefits. In many instances, putative benefits are argued by product proponents to justify or counterbalance the potential for new risks, despite potential benefits rarely being subject to the same kind of scrutiny and scepticism to which claims of potential risks are subject. Friends of the Earth Australia therefore supports the recommendations of Wynne and Felt (2007) for the inclusion of a social benefit test, supplementing the more usual investigations into efficacy, safety and environmental risk, as part of the regulation of nanotechnology in food and agriculture.

  We would like to comment briefly on three areas of nanofood development where we believe that the potential for social benefits has been misrepresented:

(i)  Food safety

  A key claim by nanotechnology proponents is that nanotechnology will improve food safety, including by the incorporation of antibacterial nanomaterials in food contact materials and edible food coatings. There has been rapid growth in the use of antibacterial nanomaterials such as silver, zinc and titanium dioxide in food packaging, food storage containers, crockery, cutlery, refrigerators and dishwashers. We are concerned that such widespread use of antibacterial nanomaterials (additional to their use in non-food items such as clothing, cosmetics, children's toys, personal care products, household cleaners, industrial disinfectants, computer keyboards, vacuum cleaners, clothes washing machines and many other products) will actually promote dangerous antibacterial resistance. This could render ineffective the use of nano-silver and other potent antibacterial nanomaterials in a medical context (for burns victims, in wound dressings etc) where they are of most use. This is particularly concerning given that silver is experiencing a revival in hospitals across Europe, partly because of the growing bacterial resistance to commonly used antibiotics (Chopra 2007). Bacterial infections already contribute to 110,000 deaths a year in Europe.

Biocidal nanomaterials could also interfere with beneficial bacteria in sewage and waste water treatment plants, and could contaminate water intended for re-use. There are also serious concerns that nano-antibacterials will pose unacceptable toxicity risks to human health and to environmental systems in to which waste products are released. A recent study by imminent UK nanotoxicologists advised that there is sufficient evidence to suggest that silver and titanium dioxide nanomaterials may be harmful to the environment and therefore the use of the precautionary principle should be considered (IOM 2009).

  While any illness as a result of food contamination is unacceptable, it is important to remember that for every person in the UK who suffers illness as a result of food poisoning, there are 50 who suffer ill health as a result of poor diets and inadequate consumption of fruit and vegetables (Lang and Rayner 2001). If processed, nano-packaged food is marketed successfully as safer than eating fresh, unpackaged foods, and consumption of fresh foods declines further, it is possible that the net outcome will actually be poorer health.

(ii)  Nutrition and obesity

  We are concerned that nanotechnology will enable manufacturers to promote nano-reconstituted, nano-fortified or nano-packaged foods as delivering superior health benefits, hygiene or convenience than minimally processed "fresh foods". If this proves true, it is likely that nanotechnology will encourage even greater consumption of highly processed foods at the expense of fruits and vegetables. Beyond the need to ensure the safety of nanofood additives, it is also useful to question whether or not fortifying food with nano nutrients, or using nanotechnology to reduce the fat or sugar content of junk foods, is actually desirable from a public health perspective.

There is a growing number of manufacturers prepared to claim that their nano-fortified beverages or foods will meet a large part, or even the entirety, of an individual's dietary needs. For example Toddler Health's range of fortified chocolate and vanilla milkshakes ("nutritional drinks"), which include 300nm particles of SunActive®iron, is marketed as "an all-natural balanced nutritional drink for children from 13 months to five years. One serving of Toddler Health helps little ones meet their daily requirements for vitamins, minerals and protein" (Toddler Health undated). Yet we challenge the claim that fortification of highly processed foods using nano-encapsulated or nano-scale vitamins or health supplements can deliver the same health benefits as improving peoples' diets. Rather than settling for the risky techno-fix of nano-fortification, the nutrition challenge requires government intervention to encourage better eating habits and more affordable healthy foods. This should involve action at the level of pricing policies and subsidies, school lunch programs, junk food advertising and other social policies.

  We are similarly concerned that the use of nanotechnology to reduce the fat or sugar content of junk foods may simply entrench and expand poor eating habits. Even a fat-reduced chocolate bar or donut will have inferior health and nutritional habits compared to fresh fruit or a "real" meal. The most straightforward to reduce the growing problem of obesity in our community is to promote healthier eating habits and more active lifestyles. Using nanotechnology to reduce the fat content of chips, donuts and chocolate will not address the root causes of obesity in our community, nor will it deliver the public health benefits associated with reduced consumption of highly processed junk foods, greater consumption of fruit and vegetables, and a more active lifestyle.

  We suggest that the food industry's key motivation in using nanotechnology to fortify or reconstitute highly processed foods has less to do with a public health concern and more to do with the significantly greater profit margins on processed foods compared to fruit and vegetables.

(iii)  Reducing the environmental footprint of food production

  We challenge the assertion that nanotechnology will necessarily reduce the environmental footprint of food production. Even if, because of their greater potency, the quantities of nanomaterials used in agrochemicals, food ingredients and production inputs are far smaller than the usual quantities of their bulk counterparts, the environmental impact could be far greater. The Project on Emerging Nanotechnologies at the Woodrow Wilson International Center for Scholars has suggested that the toxicological impact of 58,000 tonnes of manufactured nanomaterials might be the equivalent of 5 million or even 50 billion tonnes of conventional materials (Maynard 2006).

We also note that the manufacture of nanomaterials has a very high environmental footprint (S"engül et al 2008). This is related to the highly specialised production environments, high energy and water demands of processing, low yields, high waste generation, the production and use of greenhouse gases such as methane and the use of toxic chemicals and solvents such as benzene. In a life-cycle assessment of carbon nano-fibres, Khanna et al (2008) found that producing carbon nano-fibres may have the potential to contribute to global warming and ozone layer depletion, and cause environmental or human toxicity that is as much as 100 times greater per unit of weight than those of conventional materials like aluminium, steel and polypropylene. Early nanomaterial life cycle assessments led the scientists to conclude that any environmental gains of nanomaterials (for example through greater potency enabling smaller quantities of materials to be used) may be outweighed by the environmental costs of their production.

  Furthermore, many applications of nanotechnology in food packaging and edible food coatings are specifically intended to increase the shelf life of foods. It appears inevitable that one result of this will be the transport of foods over longer distances, increasing the "food miles" travelled, and increasing the climate costs of food transport.

  In short, we recognise that there are many potential social "costs" and new health and social challenges associated with nanotechnology's use in food and agriculture that require careful assessment. There is certainly no reason that the public should accept exposure to poorly understood risks posed by nanofoods, on the basis that there is a social benefit to be obtained from their sale prior to validated, nano-specific risk assessments being developed and implemented, full product labelling introduced, social assessment carried out, and the public given an opportunity to be involved in decision making.

At a time of global food crisis, nanotechnology's broader implications for food security and food sovereignty must be assessed critically

  Nanotechnology in food and agriculture is emerging at a time when global food systems are under unprecedented stress. Recent decades have revealed the high environmental costs associated with industrial scale chemical-intensive agriculture, including biodiversity loss, toxic pollution of soils and waterways, salinity, erosion, desertification and declining soil fertility (FAO 2007). The escalation of the global food crisis has also underscored the fundamental failure of global food and agriculture systems to meet the food needs of nearly a billion people. Price rises have had the worst impact on poor people reliant on buying food. Food riots occurred in over 30 countries where the world's poorest people could no longer afford basic food.

Around 75 per cent of the world's hungry people live in rural areas in poor countries (FAO 2006). If rural communities can meet more of their own food needs via local production, they will clearly be less vulnerable to global price and supply fluctuations. Global small farmers' advocacy organisation La Via Campesina has argued that: "Small-scale family farming is a protection against hunger" (La Via Campesina 2008). This view was supported by the four year International Assessment of Agricultural Science and Technology for Development which emphasised that to redress rural poverty and hunger, a key focus of agricultural policy must be empowering small scale farmers to meet their own food needs (IAASTD 2008).

  The potential role of new technologies in responding to the food crisis is controversial. As with genetically engineered (GE) crops, proponents have argued that nanotechnology will redress food shortages by promoting greater agricultural productivity (IFRI 2008). However the IAASTD (2008) report notes that whereas GE crops have had highly variable yields, they have also had negative broader economic consequences for farmers by concentrating ownership in agricultural resources and introducing new liabilities for farmers (IAASTD 2008). Similarly, FoEA suggests that nano-agriculture is not required to achieve strong yields, but will add to the capital costs faced by small farmers and increase their reliance on technology, seed and chemicals sold by a small number of global agri-business companies.

  By underpinning the next wave of technological transformation of the global agriculture and food industry, nanotechnology appears likely to further expand the market share of major agrochemical and seed companies, food processors and food retailers to the detriment of small operators (Scrinis & Lyons 2007). By dramatically increasing efficiency and uniformity of farming, it appears likely that nano-farming technologies could accelerate expansion of industrial-scale, export oriented agricultural production which employs even fewer workers but relies on increasingly sophisticated technological support systems that have increasing capital costs (Scrinis & Lyons 2007; ETC Group 2004). Such systems could commodify the knowledge and skills associated with food production gained over thousands of years and embed it into proprietary nanotechnologies (Scrinis & Lyons 2007). It could also result in the further loss of small scale farmers and further disconnection of rural communities from food production, undermining efforts to achieve sustainable, relocalised food production.

A failure to support a precautionary, transparent and inclusive approach to decision making in this sensitive area of nanotechnology development is likely to result in a further erosion of public confidence in science and technology governance

  The House of Lords Select Committee on Science and Technology is already very familiar with the crisis of public confidence in science and technology governance that emerged in the late 1990s in the UK. We note that in the Committee's 2000 report you recommended that: "direct dialogue with the public should move from being an optional add-on to science-based policy making ... and should become a normal and integral part of the process". We are grateful for the opportunity to present evidence to you as part of the current Inquiry and recognise the Committee's efforts to actualise its recommendation. Nonetheless, we observe that despite initial efforts to engage the UK public in a dialogue on nanotechnology development, this has to date not been specifically undertaken in relation to food and agriculture, nor has it been attached to a policy or governance decision making process.

We suggest that as the public awareness about nanotechnology grows, and specifically in relation to its use in food and agriculture, it will be essential for the government to demonstrate that it has taken a strongly precautionary approach to risk management, that it has considered broader social challenges alongside scientifically measurable risk issues, and that the public has had a genuine opportunity to be involved in decision making. A perceived or actual failure in relation to any of these issues risks further eroding public confidence in science and technology governance, and taking us back to the BSE and GM controversies.

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