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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