Back in February of 2009, the UK House of Lords Science and Technology Committee launched an inquiry into the use of nanotechnology in food products and the food industry. Chaired by Lord Krebs (the son of Hans Adolf Krebs – best known for describing the mechanisms of energy uptake and release in cells), a small group of peers was assembled to address the potential benefits and use of nanotechnology in the food sector, arising health and safety issues, regulation, communication and public engagement. On January 8 2010, the subcommittee’s much-anticipated report was published. Concluding with 32 recommendations covering nanotechnology and food commercialization, potential risks, regulation and public communication and engagement, it is perhaps the most comprehensive and authoritative report on the subject to be published to date.
The UK House of Lords has, on occasion, been depicted as an anachronistic institution full of political has-beens who enjoy nothing more than a quiet snooze, lulled to sleep by the interminable droning of their peers. Of course, reforms brought in over the past decade have done a lot to shatter this illusion. But if there are any lingering doubts, this report should dispel them. Under the expert guidance of Lord Krebs, this group of sharp minded and well-informed members of the House of Lords has provided an insightful and balanced perspective on the opportunities and challenges of using nanotechnology (or “nanotechnologies” as they more appropriately refer to them) in the food industry.
The process was helped enormously by an extensive consultation process. Fifty written submissions from a wide range of stakeholders, a number of oral testimonies and meetings with experts and stakeholders in Washington DC all helped to support the committee in its assessment. The final document reflects the input of these stakeholders, frequently citing input from industry, academics, government agencies and Non-Government Organizations. Yet despite the breadth of information submitted, there is a strong sense that these inputs were carefully weighed and evaluated by the committee before they drew their conclusions and recommendations.
The report is clearly written and accessible, and I would recommend strongly anyone working with nanotechnology and food to read it in its entirety. I suspect that it is going to become a significant and influential factor in the development of responsible and acceptable uses of nanotechnology in food products.
For those with less time and interest, I would recommend reading the summary at least, which captures the essence of the report in a couple of pages.
Just to whet your appetite though, here’s my initial impression of the report and its recommendations in four areas – Nanotechnology and food, knowledge gaps, regulation, and communication & outreach.
Nanotechnology and Food
The report shows a remarkable level of sophistication in its evaluation of nanotechnology and food. It recognizes the long history of using technologies to modify food, recognizes consumer caution over the scientific manipulation of food products, and acknowledges the complexities surrounding the introduction of potentially beneficial new technologies. It also highlights the rather indistinct lines between nanoscale materials that have been present in foods forever (such as protein nanoparticles in ricotta cheese) compared to those more recently and intentionally introduced, and new materials that behave in unusual ways compared to those that are just small. This clarity of perception underpins many of the report’s recommendations.
The potential of nanomaterials to add value to food products is readily acknowledged in the report:
“Nanomaterials have a range of potential applications in the food sector that may offer benefits to both consumers and industry. These include creating foods with unaltered taste but lower fat, salt or sugar levels, or improved packaging that keeps food fresher for longer or tells consumers if the food inside is spoiled.”
But the authors go on to note that the number of nanotechnology-based food products on the market is currently small. To help ensure the responsible development of nanotechnologies in the food sector, recommendations are made on government actions to “ensure the potential benefits to consumers and society are supported,” including improving the effectiveness of technology transfer between researchers and industry.
Counterbalancing the technological promise of nanotechnology, the report’s authors are also highly aware of the broader social issues surrounding the use of emerging technologies in food. And as a result, the majority of the report’s recommendations are focused on addressing and responding to these issues.
Despite the promise of nanotechnology in the food sector, the report highlights a number of critical knowledge gaps to developing safe and trusted nanotech-enabled food products. Again, the discussion is informed and comprehensive.
At the outset, the report notes that the subcommittee “received no evidence, however, of instances where ingested nanomaterials have harmed human health,” dispelling fears of speculative scaremongering (although I see that early press coverage is focusing on risks and uncertainties). At the same time the report’s authors acknowledge that the
“novel properties of engineered nanomaterials may affect how such materials interact with the body and the risks they present to human health.”
Six areas of concern are flagged where novel nanomaterials might cause unexpected harm, covering the influence of particle size, solubility & persistence, chemical & catalytic reactivity, material shape, anti-microbial effects and agglomeration & aggregation. Despite these concerns – which have been raised repeatedly by researchers and others over the past few years – the report notes a dearth of research on the “impact, behaviour and interactions of nanomaterials in the [gastrointestinal] tract, including their effect on gut flora.”
Targeted research to fill this knowledge gap is a key recommendation of the report.
The report’s authors devote a large chunk of space to the issue of regulation – addressing regulatory coverage and regulatory enforcement. Although somewhat dry for a lay reader, these sections of the report tackle directly a number of issues that have plagued discussions of nanomaterial regulation for some time, including definitions, working with mixtures and labeling.
The report’s authors are very clear that a regulatory definition of nanomaterials is essential. But they are also clear that any definition should be based on functionality rather than size – throwing out the idea that there is anything special about the traditional 100 nm cut point for nanomaterials.
The argument is made that, from a regulatory perspective, what is important is when a material starts to behave differently from what is expected – when the way that it interacts with the body is no longer the same as what is observed with a larger lump of material with the same chemistry. This may happen at very small particle diameters with some materials – just tens of nanomaters. But it may also occur at relatively large particle diameters for other materials. As a result, the report recommends that regulatory definitions of nanomaterials
“should not include a size limit of 100 nm but instead refer to the ‘nanoscale’ to ensure that all materials with a dimension under 1000 nm are considered.”
This placement of the upper limit of the nanoscale at 1000 nm may well be the most controversial aspect of the report. But the emphasis on functionality is a welcome one – as long as we can define what functionality means!
In the report’s recommendations it is also very clear that, for regulatory purposes, any definition of ‘nanomaterials’ should exclude those created from natural substances, “except for nanomaterials that have been deliberately chosen or engineered to take advantage of their nanoscale properties.”
The report also touches on the contentious issue of mixtures – powders that contain some fraction of particles which are nanometer-sized. What do you do if you use a powder in a food product that also contains a small number of nanometer-scale particles (as most powders invariably will)? There isn’t much insight into how to resolve this issue in the report (or elsewhere for that matter), but the report’s authors do recommend that the UK Government develops guidelines that clearly state what fraction of a powder needs to be at the nanoscale before nano-specific regulatory oversight is triggered. This is critical to the effective regulation of nanomaterials in food products if products are not to be inappropriately under- or over-regulated. (Imagine a scenario where a manufacturer could claim exemption from nano regs because a small fraction of a material was larger than the nanoscale, or a regulator over-zealously applied regulations by insisting that a conventional material containing a small fraction of nanoparticles was a nanomaterial. The only thing worse would be a complete lack of clarity on when a product containing a range of particle sizes was considered nano and when it was not – which unfortunately is where we are at the moment!)
On labeling, the report states
“Consumers can expect to have access to information about the food they eat. But blanket labeling of nanomaterials on packages is not, in our view, the right approach to providing information about the application of nanotechnologies.”
Rather, the report’s authors recommend a public registry of foods containing nanomaterials.
Communication & Outreach
Six of the report’s recommendations deal directly with effective communication and public engagement. From the outset, the report’s authors recognize the importance of public attitudes towards food, and the need to engage consumers in the use of nanotechnologies in food products. The report’s summary opens
“People are understandably sensitive about changes to the food they eat. In the past the introduction of novel technologies in the food sector has sometimes met with resistance or even holstility. The public’s attitude toward food is influenced by a number of considerations including a fear of novel risks, the level of trust in the effectiveness of regulation, and other wider social and psychological factors (shaped by views on health, the environment and science). The development of nanotechnologies in the food sector may well elicit some of these concerns.”
Later on, the report states that “our witnesses confirmed that public attitudes towards the use of nanotechnologies were among the most important factors in determining their future in the food sector.”
Transparency within the industry was seen as critical to addressing potential public fears and concerns. Yet after talking with stakeholders, the subcommittee came to the conclusion that the food industry are being far from transparent at the moment, and that this may potentially damage the responsible use of nanotechnologies in foods in the long run. They “found it regrettable that evidence indicated that, far from being transparent about its activities, the food industry was refusing to talk about work in this area.”
A number of witnesses stressed the reticence of food companies to talk about nanotechnology openly, for fear of a loss of consumer confidence. Franz Kampers from Wageningen University told the subcommittee
“the industry is very, very reluctant to communicate that they are using nanotechnology in food … because they are very much afraid oof the reaction of consumers to the product.”
Yet after hearing evidence from a number of quarters, the subcommittee concluded that
“this is exactly the type of behaviour which may bring about the public reaction which it is trying to avert.”
As a result the subcommittee recommended that the UK Government work with the industry to ensure greater openness and transparency about what they are developing, and what their plans are for using nanotechnology in food products.
The subcommittee also stressed the need for a robust Government communication strategy. They praised the Government for establishing the Nano & Me website, which provides anyone who is interested with accessible information on nanotechnology – including its use in food. Unfortunately, they failed to note that Nano & Me is under threat because the UK government isn’t stumping up paltry sums of money to ensure its upkeep!
Finally, the report emphasizes the need for public engagement, which provides people with the opportunity to participate in decision-making processes. They acknowledge that this is a complex task, and have some interesting perspectives on how to proceed here. In particular, the suggest that the provision of engagement opportunities might in itself be sufficient – that people will be reassured that someone has the opportunity to engaging on their behalf – and that the voice of the public”is often most effectively mediated by representative groups such as consumer groups, non governmental organisations (NGO’s) and individuals with a particular interest in this topic.”
I’m not sure how far I agree with these suggestions. But perhaps the most important thing here is that the subcommittee recognize that engagement is about giving people a voice and a place at the table, not just about communication.
These are just some of the things that jumped out at me as I read through this report today. There are many other aspects to it which deserve greater attention. Not all of the comments and recommendations will meet with universal approval I am sure. But without a doubt, this is the most thoughtful, informed and insightful piece on nanotechnology and food I have read in a long time.
The full House of Lords Nanotechnologies and Food report is available here.