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Nanotechnology in Food Products: Workshop Summary 4 Educating and Informing Consumers About Applications of Nanotechnology to Food Products This chapter summarizes the presentations and discussions that occurred during the third and final session of the workshop. The first presenter, Julia Moore of the Woodrow Wilson International Center for Scholars, used polling data and results from four years of focus group work to argue that public opinion about nanotechnology being applied in the food industry is essentially “up for grabs.” A large majority of Americans know little about nanotechnology and have yet to form an opinion about its use. She identified several key lessons learned from past “ag-biotech” experience about public engagement with new technologies. The second presenter, Carl Batt of Cornell University, spent most of his time describing how he and his collaborators designed the Too Small to See: Zoom into Nanotechnology museum exhibition. He discussed the challenges faced when trying to communicate ideas about size and scale to the public and how Too Small to See overcomes some of these challenges. He briefly described production of Nanooze, a nanoscience magazine for children that is available in print and online. The third and final presenter of the session, Jean Halloran of Consumers Union, provided consumer perspective insights and responses to several of the ideas and issues that other workshop presenters and attendees had raised up until that point. She commented on the difference between knowing about a technology and accepting that technology; gaps in knowledge about the safety of nanotechnologies in food; consumers’ fear of the unknown, particularly in foods; the importance of regulation and how consumers need to know that they are being protected; and the importance of consumer choice. The session ended with a lengthy panel discussion with all 10 presenters of the day participating on the panel. Most of the questions
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Nanotechnology in Food Products: Workshop Summary and comments revolved around issues related to consumer behavior and public engagement, although the issue of regulatory uncertainty re-emerged as well. NANOTECHNOLOGY AND FOOD: THE PUBLIC KNOWS “NANO”1 Presenter: Julia A. Moore2 Moore began her talk by remarking that the public knows very little about nanotechnology in food. Within her organization, the Woodrow Wilson International Center for Scholars, the Project on Emerging Nanotechnologies, has probably done more focus group and public opinion polling on public attitudes and perceptions, as well as how to influence those attitudes and perceptions, than any other organization. That said, it was actually the National Science Foundation (NSF) that supported the first public opinion polls on nanotechnology in 2004. One of the questions posed in that initial NSF poll was: How much have you heard about nanotechnology? The question was posed again in a 2008 study conducted by Peter D. Hart Research Associates (on behalf of the Project on Emerging Nanotechnologies), and the numbers were basically the same (Moore presented the 2008 data, which involved surveying 1,003 adults nationwide3): 49 percent replied that they had “heard nothing at all”; 26 percent said they had “heard just a little”; 17 percent had “heard some”; 7 percent had “heard a lot”; and 1 percent were “unsure.” Moore remarked that most of the 17 percent who said that they “heard some” probably in fact knew nothing about nanotechnology. She said that it is easy to imagine somebody getting a phone call and being told, 1 This section is a paraphrased summary of Julia Moore’s presentation. 2 Julia A. Moore is Deputy Director of the Project on Emerging Nanotechnologies, an initiative of the Woodrow Wilson International Center for Scholars & The Pew Charitable Trusts. 3 SOURCE: Peter D. Hart Research, Inc. 2008. “Awareness of and Attitudes Toward Nano- technology and Federal Regulatory Agencies.” Available online at http://www.pewtrusts.org/our_work_report_detail.aspx?id=30539. Accessed January 26, 2009.
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Nanotechnology in Food Products: Workshop Summary “Hey, I’m going to talk to you about nanotechnology …” and the person saying, “Yeah, I’ve heard something about nano….” According to the same 2008 poll, when asked what their initial impressions were about the benefits and risks of nanotechnology (i.e., whether the benefits will outweigh the risks or vice versa), many people were unsure: 48 percent replied “not sure”; 25 percent replied “the benefits and risks will be about equal”; 20 percent replied “benefits will outweigh risks”; and 7 percent replied “risks will outweigh benefits.” Although, as shown in Figure 4-1, the percentage of people that were unsure decreases as familiarity with nanotechnology increases (i.e., 65 percent of people who had “heard nothing” were “not sure” about the benefits and risks, whereas only 10 percent of those had heard “a lot” said that they were “not sure”). FIGURE 4-1 How people perceive the risks and benefits of nanotechnology without being told anything about nanotechnology prior to being surveyed. The table on the lower left breaks the responses down according to how familiar with nanotechnology respondents said they were prior to the survey. Image courtesy of Peter D. Hart Research Associates, Inc., on behalf of the Project on Emerging Technologies.
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Nanotechnology in Food Products: Workshop Summary When people were provided with some information about nanotechnology prior to the survey (i.e., the pollster read some sentences about what nanotechnology and its applications are), the percentage of people who were unsure dropped from 48 to 9 percent (see Figure 4-2): 38 percent replied “benefits and risks will be about equal”; 30 percent replied “benefits will outweigh risks”; 23 percent replied “risks will outweigh benefits”; and 9 percent replied “not sure.” FIGURE 4-2 How people perceive the risks and benefits of nanotechnology after being informed about the potential risks and benefits of nanotechnology. The table on the lower left breaks the responses down according to how familiar with nanotechnology respondents said they were prior to the survey. Image courtesy of Peter D. Hart Research Associates, Inc., on behalf of the Project on Emerging Nanotechnologies. The take-home message from these survey data, Moore said, is that “public opinion is really up for grabs when it comes to nanotechnology. The public really doesn’t know very much to have an opinion.” When asked about the benefits that they would like to see derived from nanotechnology, indeed from any new technology, Americans consider the potential medical applications to be the most important (e.g., “a
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Nanotechnology in Food Products: Workshop Summary cure for cancer”). More specifically, in a 2006 study, surveyed members of the U.S. public identified the following as the most important potential benefits of nanotechnology4: Medical applications (31 percent) Better consumer products (27 percent) General progress, better life (12 percent) Environmental protection (8 percent) Food and nutrition (6 percent) Economy, jobs (4 percent) Moore remarked that, interestingly, when the same question is asked in Europe, respondents generally indicate that they are much more concerned with environmental issues (e.g., environmental clean-up methods) than U.S. residents are. Of note, only 6 percent of respondents indicated that “food and nutrition” benefits are one of the most important potential benefits of nanotechnology. This is consistent with most other new technologies. While people are generally delighted to have new technologies put to use in computers, telephones, etc., even tennis racquets, the idea of having a new technology applied to a food is often viewed as “yucky.” That is something to keep in mind, Moore said, when considering or trying to project what public perceptions of this new technology (i.e., nanotechnology) will be. While one might expect most people to learn about nanotechnology in the classroom, through government education programs, or from science societies, such as the National Academy of Sciences, Moore said that this is not the case. Most people learn about nanotechnology in grocery, clothing, and drug stores. Moore encouraged workshop attendees to visit http://www.nanotechproject.org/inventories/consumer and browse the 800+ consumer products, particularly products in the “food and beverage” category that are self-identified as “nano” or nanotechnology-based. As Philbert had remarked earlier, being self-identified as nano does not mean that a product is in fact nanotechnology based. It means only that the manufacturer is making that claim. In addition to the fact that only a small percentage of people identify food and beverage benefits as an important potential benefit of nanotechnology, Moore said “another piece of bad news” is that many people are 4 J Macoubried. 2006. Nanotechnology: Public concerns, reasoning and trust in government. Public Understanding of Science 15:221-241.
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Nanotechnology in Food Products: Workshop Summary worried about the overall safety of the U.S. food supply. When asked how the food supply has changed over the last five years (as part of the same 2008 survey cited previously): 39 percent replied that it “has become somewhat less safe”; 22 percent replied that it “has become much less safe”; 22 percent replied that it “has become somewhat more safe”; 7 percent replied that it “has become much more safe”; 6 percent replied that it “has been unchanged”; and 4 percent replied that they were “not sure.” Moore emphasized that even though these responses reflect perceptions, not necessarily reality, the results are consistent with other polling data. This concern about safety raises the question, who does the American public trust, and where does it place its confidence with respect to maximizing the benefits and minimizing the risks of scientific and technological advancements? Other polling data show that the public trusts the U.S. government (i.e., the USDA, FDA, and EPA), independent scientists, and independent agencies much more than they trust businesses and companies. Basically, Moore said, the public wants to know that the FDA is taking care of the safety of the food supply. Moore emphasized that the public is not averse to nanotechnology. For example, according to the same survey data collected by Peter D. Hart Research Associates, Inc. (on behalf of the Project on Emerging Nanotechnologies), when asked if they would use food storage products enhanced with nanotechnology, 12 percent said yes, 73 percent said that they need more information about the health risks and benefits, and 13 percent said no. When asked if they would purchase food enhanced with nanotechnology, 7 percent said yes, 62 percent said that they need more information about the health risks and benefits, and 29 percent said no. But they do need more information. In summary: A large majority of Americans still have heard little or nothing about nanotechnology. A large portion of the public does not have an opinion on the trade-offs between the risks and benefits of nanotechnology. The U.S. public is more comfortable with government or independent oversight than industry self-regulation of new technologies. Moore noted that this is an important point to
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Nanotechnology in Food Products: Workshop Summary consider because the U.S. public relies on industry to provide safe products (i.e., because too much regulation would stifle innovation). The current lack of awareness presents an opportunity for the government and industry to establish confidence in nanotechnology. Moore said that if those involved in the food sector think that nanotechnology is going to provide strong benefits for consumers, then they really need to get out there and start shaping that still unformed perception of nanotechnology. The U.S. public values nanotechnology medical benefits over food and nutrition. Moore remarked that a single highly beneficial application of nanotechnology, not necessarily in food but more likely in medicine, would cause people to “immediately identify” with nanotechonology. Moore listed four lessons to be learned from the “ag-biotech experience”: Build public trust in a strong, credible U.S. and international oversight process. The American public is much more likely to accept a new technology if they think someone is looking after their interest. If they don’t think that anyone is looking after their interest, they will reject the new technology. Make sure nanotechnology’s environmental and health benefits and safety are confirmed by independent research. Demonstrate concern for consumer choice and provide good consumer information. Focus group and polling studies have shown that consumers like choice. For example, people do not like being told that they have to use sunscreen with nanotechnology and that they don’t really have a choice. Consumers become upset when they find out that a product that they have been using all along has nanotechnology in it without their knowledge (i.e., there is no mention of nanomaterials in the labeling). In order to build confidence in a new technology, it is important to provide consumers with information and to make sure that they have a choice about whether to use the new technology or not. This is true even though people do not necessarily actually look at the information. But they want somebody to have the information. They want it to be transparent and available.
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Nanotechnology in Food Products: Workshop Summary Offer opportunities for public input into the technology’s development and regulation. A key issue with respect to engaging the public is that the engagement does not involve just telling people that nanotechnology is “all about controlling matter on a 1–100 nm scale.” That is not the type of communication they want. Focus group studies have shown that people want to have input into whether or not the new technology is going to be used in ways that they think are important, and they want to feel that they are being heard. Moore concluded by encouraging people to visit the Project on Emerging Nanotechnologies website, where more information on the focus group and polling studies that she discussed is posted: http://www.nanotechproject.org. Moore also provided a hand-out for workshop attendees that contained some of the same data she presented.5 CHALLENGES IN EDUCATING CONSUMERS ABOUT EMERGING TECHNOLOGIES6 Presenter: Carl Batt7 Batt began with a few comments about his scientific research on biodegradable plastics. His research team has developed a process that involves coupling a particular enzyme to a magnetic bead and growing large masses of bacterial polyester. The polymer masses stay in place in situ and are being used for cancer therapy and other therapeutic applications. Batt and his students are also doing what Batt refers to as “nanostructured prospecting,” or “reverse food science,” and they are investigating the use of chemically modified particles in pesticide detection. But the focus of his talk was not his scientific research, rather his participation in development of Too Small to See: Zoom into Nanotechnology, a 5,000-square foot traveling museum exhibition supported by 5 Awareness of and Attitudes Toward Nanotechnology and Federal Regulatory Agencies: A Report of Findings, available online at http://www.pewtrusts.org/uploadedFiles/www.pewtrustsorg/Reports/Nanotechnologies/Hart_NanoPoll_2007.pdf. Accessed February 11, 2009. 6 This section is a paraphrased summary of Carl Batt’s presentation. 7 Carl A. Batt, PhD, is Liberty Hyde Bailey Professor of Food Science and co-founder and former director of the Nanobiotechnology Center, Cornell University, Ithaca, NY.
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Nanotechnology in Food Products: Workshop Summary the NSF, and the magazine Nanooze. Batt remarked that, for the remainder of his presentation, while describing these two programs, he would try to convey what he and his colleagues think are the “underlying foundations” of what people know and how they think about size and scale. Too Small to See When Batt and his colleagues began developing Too Small to See, rather than trying to get a sense of what the public knows about nanotechnology, which is essentially nothing, they formulated a set of questions designed to get a sense of what people know and how they think about size and scale. Initially, they did ask, “Have you heard of nano?” The responses, Batt said, were based largely on the fact that people would get kind of embarrassed if they had not heard of it, and so they’d say, “yeah, yeah, I’ve heard of it.” Slightly less than 30 percent (in the 18–22-year-old age range) to more than 70 percent (in the <8 years old age range) of respondents said that they had heard of nano. But when probed further and asked “What is nano?” most people referred to the iPod nano (or “that iPod thing”), an answer Batt said was “sort of meaningless.” So Batt and his team changed the focus of the questioning. Instead, they asked people, “What is the smallest thing that you can see?” But the answers were often dependent on the respondents’ environments. If someone saw a bug crawling, that would be the answer. Or if they had crumbs all over them, that would be the answer. So again, the answers were sort of meaningless. Instead, as their first line of questioning in their effort to find out what people know about size and scale and how they know it, they asked, “What is the smallest thing that you can think of?” The answers, Batt said, were interesting. Some people identified a visible organism, like a bug, as the smallest thing they could think of; others identified something cellular as the smallest thing they could think of; and then there were people who identified either something atomic or something subatomic, like a quark or proton, as the smallest thing they could think of. Batt referred to people in one of the latter two groups as “post-atomic.” The answer to this question allowed the researchers to define populations of people who thought on a macroscopic vs. microscopic vs. nanoscopic scale. The exhibitors developed a scoring system to measure people’s thinking about scale, with post-atomic people earning higher “think scores.” Specifically, people that identified a visible organism as the smallest thing they could think of were assigned a score
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Nanotechnology in Food Products: Workshop Summary of 1; people that identified something cellular were assigned a score of 2; people that identified something atomic received a 3; and people that identified something subatomic received a 4. The highest scores were among teenagers (age 16–18; see Figure 4-3). Generally, only a small fraction of people actually thinks about things “on a nanoscale world.” FIGURE 4-3 The range of “think scores,” by age, when respondents were asked to identify the smallest thing they could think of. A higher score indicates more “sub-atomic,” or nanoscopic, thinking. See text for more details. SOURCE: Reprinted from Springer, Journal of Nanoparticle Research, Volume 10, Issue 7, 2008, pp. 1141-1148, Numbers, scale and symbols: the public understanding of nanotechnology, CA Batt, AM Waldron, N Broadwater, adapted from Figure 1, Copyright © (2008), with kind permission from Springer Science and Business Media. The finding that only a small percentage of people actually think about things on a nanoscale level, combined with the reality that the average visitor to a science museum spends less than one minute in front of any individual exhibit, became the basis for Too Small to See. The challenge was to distill all of the information that Batt and his team wanted to convey into something that could be communicated in less
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Nanotechnology in Food Products: Workshop Summary than a minute (or, as Batt noted, 60,000,000,000 nanoseconds). In order to do that, they developed what they termed the “Four Concepts,” or “Carl’s Commandments”: All things are made of atoms. Molecules have size and shape. At the nanometer scale, atoms are in constant motion. Molecules in their nanometer scale environment have unexpected properties. Batt said the fourth point—that unexpected things happen—is what makes nanotechnology so interesting. The exhibitors decided that they wanted to hammer these four concepts at every opportunity. The four concepts also serve as a basis for every issue of Nanooze. Scale and Perspective Before describing the Four Concepts in more detail, Batt discussed how difficult it is for people to understand the concept of scale. It is hard enough to imagine a billion of something, let alone one billionth of something. Also, people have a difficult time with numbers, often interpreting “billion” and “1,000,000,000” differently. As an example, Batt referred to the widespread email scam whereby somebody claiming to be from Nigeria informs the recipient that “the sum of $1,000,000,000 USD (One Million Dollars Only)” awaits him or her. $1,000,000,000 is not a million dollars—it’s a billion dollars. So figuring out 109 is hard, 10−9 even harder. Thinking small is difficult, and many people, “including probably all of us,” Batt said, “can’t think on those terms.” Physicist Richard Feynman developed a helpful analogy: if an atom were the size of an apple, then an apple would be the size of the earth. Still, even that analogy would be difficult for most people to interpret while walking through a science exhibit. In Too Small to See, everything is 100,000,000 (one hundred million) times larger than it actually is. So atoms, for example, are represented as objects that are 100,000,000 times larger than actual atoms are. Batt said that many people might wonder, “Why one hundred million? Why not a million?” As it turns out, objects smaller than 1.3 inches are considered choking hazards and cannot be included. And if the scale had been made larger, then the atoms would have been very large. A human hair at 100,000,000-fold, for example, would be the width of a river. Even at
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Nanotechnology in Food Products: Workshop Summary know and don’t know and how they react to information.” While consumers have a great deal of common sense, they also have enormous gaps in knowledge particularly with respect to quantitative information (as Batt elaborated during his presentation). For example, Consumers Union did some work with Alar about 20 years ago, when the pesticide was found in apple juice at parts per million (ppm) levels, exceeding EPA recommendations. When Consumers Union published that information, they received a lot of letters from concerned citizens, including a medical doctor from Rancho Cucamonga, California who asked what all the “fuss” was about, given that there “can’t be more than one molecule” of Alar in a gallon of juice. In fact, at those ppm levels, a liter of apple juice would contain an astronomical number of molecules: 1.4 × 1017. Groth said, “Even the people in this room probably couldn’t get a good grip on it intellectually.” Getting consumers to get a handle on this type of quantitative information is an enormous challenge. The second observation Groth made was that, while consumers may not be very good with quantitative information, they are good with skepticism. He remarked that Yada’s earlier comment about how the National Nanotechnology Initiative was designed to get kids excited about nanoscience and “all of the wonderful things that nanotechnology offers” reminded him of watching a Disney movie, Our Friend the Atom, as a kid, and then seeing 15–20 years later a pamphlet on nuclear power and electricity. The pamphlet, which was put out by a coalition of electrical utilities called Infinite Energy, claimed that nuclear power-generated electricity was going to be not only incredibly beneficial but also too cheap to meter and that the future would bring atomic cars, atomic airplanes, atomic wristwatches, etc. Then, 10–15 years later, there was an accident at Three Mile Island, and people realized that they had been hearing only part of the nuclear energy story. Generating this excitement serves a useful social purpose, Groth said, but consumers might wonder whether “sales pitches” like this are based on a balanced assessment of the public interest. Consumers are skeptical of both risks and benefits of new technologies. He referred to some of the data that Moore had presented which showed that many consumers think (without really knowing about the technology) that the risks are probably greater than the benefits or, at best, that the risks and benefits are the same. Groth argued that if participants in this stage of developing nanotechnology applications want to persuade consumers that there are in fact huge benefits to nanotechnology and not very big risks, they have to do it in a way that does not resemble a sales pitch. Instead, he encouraged efforts to engage
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Nanotechnology in Food Products: Workshop Summary consumers in the manner that Moore described: by inviting them to the table, finding out what they are interested in, including them in the decision-making process, and respecting their views (including their ignorance). This is very difficult and something, Groth said, “we haven’t really learned to do very well as a society.” He said that moving forward with nanotechnology “could be a big experiment in social mechanisms, as well as in new technology.” With respect to Groth’s second observation (i.e., on public engagement), Moore agreed that the United States has not done a good job of engaging the public on science policy issues. Europe, she said, has done a “little better.” In the United Kingdom, various government agencies have begun including interested citizens or consumers on oversight boards. One of the lessons learned in Europe is that unless people participate in a process and feel that their opinions and advice have some impact on the government decision-making, they feel like they are being given nothing more than a sales pitch and they become very angry. Moore expressed hope that, with new technology [i.e., not nanotechnology but new communication technology], society is developing “a new form of … democracy.” She stated that President Obama’s use of the Internet while campaigning is a manifestation of this new type of democracy, one that entails a higher level of public engagement than has been possible in the past. She said that she doesn’t think that these new avenues of communication have been explored enough as a way to truly engage the public and not just throw sales pitches. Yada was the second panelist to comment on Groth’s remarks. He commended the educational programming work that Batt is doing, but equally important will be conducting and communicating cost/benefit analyses. He remarked that the early stages of the GMO debate started with consumers stating that the technology was being imposed on them and without the public really understanding the technology. Yada followed up with a question to Moore, asking if the data she presented on consumer perception of benefit/cost might be suspect if in fact only half of those surveyed actually understood the technology. He pointed out that if he were asked about the potential benefits and costs of a new technology that he did not understand, particularly with respect to that technology being applied in food, he wasn’t sure that he could answer objectively. Moore confirmed that the one question pertaining to the benefits that people would like to see derived from nanotechnology was asked whether people knew about nanotechnology or not. She said its response was consistent with “virtually every finding” she is aware of
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Nanotechnology in Food Products: Workshop Summary with respect to the types of benefits people want from new technologies (i.e., that food and nutrition are not high priority benefits, and medical applications rank the highest). That finding is not nano-specific, she said. Moore elaborated that, in fact, most consumers don’t really make an effort to learn that much before making a decision, particularly a decision related to something scientific or technical. Sometimes they go to Consumer Reports, sometimes to a government or company website, but most of the time they turn to somebody they know who they consider reliable—it could be a cousin, a dentist or, for example when it comes to a cell phone, a 15-year-old boy. People turn to others who they think share the same values, are knowledgeable and accessible, and have your best interest in mind. Moore referred to a recent study reported in Nature Nanotechnology10 concluding that most people form their attitudes and decisions about benefit/risk, for example whether nanotechnology is safe or unsafe, based on their “cultural cognition reality” and where they have “anchored” their trust. Once people have that cultural anchor, they process all other new pieces of data by turning to whomever it is they trust and processing their decisions accordingly. For example, people in some cultural groups mistrust industry declarations that products are safe because they don’t think that industry has their best interest in mind. On the other hand, if you are in a different cultural group, for example if you are a 50-year-old white male businessperson, and GreenPeace declares that nanotechnology may be unsafe, you might automatically mistrust that declaration and believe that nanotechnology could provide a treatment for prostate cancer and that “those people don’t want me to have it” or that “those people don’t understand that we’ve got to make money in this country, that we’ve got to have a robust, technologically driven economy.” Moore encouraged those who are trying to figure out how to engage the public in discussions about nanotechnology look at this research. Philbert was the next to respond to Groth’s comment by making an observation about some of the terms that people use when discussing nanotechnology. He said that while listening to this discussion, he keeps “bumping up against a simple cognitive dissonance and that is that we keep talking about this nanotechnology as if it’s a thing.” But it’s not a single thing; nor is nanotoxicology. He also commented on use of the word “risk” and that there needs to be a careful distinction between “risk aversion” and “hazard aversion.” Too often, when people use the word 10 DM Kahan, D Braman, P Slovic, J Gastil, and G Cohen. 2008. Cultural cognition of the risks and benefits of nanotechnology. Nature Nanotechnology 4:87-94.
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Nanotechnology in Food Products: Workshop Summary “risk,” they are really referring to a “hazard.” He also commented on the fact that as more is learned about nanotechnologies and their various applications, much of what has been learned to date will be supervened by new information. It is therefore very important that these discussions be open and transparent and that the public recognizes that “we’re just lifting the edge of the rug.” As we lift it further, much of the new information may very well reverse what will have already been said about the safety of nanomaterials up until that point. Nanotechnology is a very “sexy word,” Philbert said, and a powerful inducer of grant funding, but it’s useless for engaging the public and empowering consumers to make informed choices. Moore agreed with Philbert “from an intellectual standpoint,” but disagreed “from a practical standpoint.” She said, “There are so many people who have embraced this word over the last 20-plus years in the vernacular, that I think its wishful thinking.” She mentioned NSF awarding its first grant with nanotechnology in the title in 1991. She predicted that nanotechology would almost certainly be a major component of the Obama administration’s economic stimulus package. Philbert agreed with Moore on the widespread use of the word but opined that the language needs to evolve and that we need to go beyond using the simple “nanotechnology” label for everything nano. His fear, he said, is that something bad will eventually happen and that all useful nanotechnology, safe and otherwise, will be lost. Moore agreed. Degnan responded next. Recognizing that biotechnology is “not the best comparator” for nanotechnology and that genetic alteration of natural materials raises a host of quite different concerns, there is a very clear practical lesson to be learned from that experience. Specifically, when biotechnology emerged, there was not single biotech product that consumers could identify with and recognize as being beneficial for them. Instead, the new technologies were benefiting the farmers, growers, and agricultural companies. After watching the biotech industry suffer injury for 15 years because of this, it is very clear that the first nanotechnology products that enter the market, whether they are medical care products or food packaging products (or something else), must possess recognizable consumer benefits. Educating the Public About Nanotechnology Food Forum member Donna Porter, who also served on the workshop planning committee, asked the panelists a series of questions,
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Nanotechnology in Food Products: Workshop Summary beginning with two questions directed at Batt. First, have Batt and his colleagues been able to test people’s knowledge after they have been through Too Small to See? Second, is there any plan to expand the exhibition into, for example, a school program that could be presented by teachers nationwide? Batt said the answer to both questions was “yes.” Regarding the first, because the exhibit receives NSF support, some sort of assessment is required, so he and his team have in fact done that. He referred workshop attendees to www.informalscience.org for a summary of what Batt and his team have learned about what people gain from the exhibit. Regarding the second question, the exhibit is currently on national tour. It rotates from one science museum to the next about every three months. Its touring schedule is posted online at www.toosmalltosee.org. Nanoooze is being distributed nationwide as well. It is being sent mostly to teachers, although anybody can request copies. The big challenge, Batt said, is that every state has their own formal education agenda/curriculum and not a single one of those curricula include nanotechnology. He said, “To try to shove that into the curriculum as a mandate is virtually impossible.” He and his team are doing what they can to distribute Nanooze as much as possible. Porter asked if it has been presented at science teacher education conferences. Batt said yes, for example the National Science Teachers Association (NSTA). He mentioned that after Nanooze was recently reviewed in a newsletter, Neuroscience for Kids, Batt asked the newsletter editor where he had heard about Nanooze and learned that it was being distributed among various language arts programs as well. Batt said that it’s very graphically pleasing, with a lot of “cool stuff,” and it is not just being read in the science classroom. Comparing Consumer Acceptance of Nanotechnology to Consumer Acceptance of Irradiation Porter then directed two questions to Moore and Philbert. First, has the consumer reaction to nanotechnology been similar to what occurred when irradiation in food was first discussed? Second, when new technological ideas are presented to consumers, for example in focus groups or through polling studies, are consumers led to believe that all food is going to be affected by the new technology (whether it be irradiation or, today, nanotechnology), or do the respondents understand that the new technologies will be used only in selected ways, at least initially? Moore
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Nanotechnology in Food Products: Workshop Summary said that, based on four years of focus group work, her informed opinion is that people generally react to nanotechnology as being something “cool.” It sounds “hip and edgy,” particularly to the younger generation. But there is not a lot of awareness about what nanotechnology is. In the first focus group she conducted (four years ago), when asked if anybody had ever heard about nanotechnology, only a few participants responded, and somewhat tentatively. In the last series of focus groups, conducted in August 2008, 10 of 12 pairs of hands shot up when the same question was asked. However, when further asked how they had heard about it, many people mentioned the iPod nano. But, Porter said, “at least they got that it was small. They got the first ‘Carl Commandment’ down.” So awareness of nanotechology remains the same (i.e., low). The reaction to synthetic biology, Moore said, has been more similar to what occurred with irradiated food. The word “synthetic” brings to mind nylon and other images of things that were “new and great and wonderful” decades ago but are not thought of that way today. Today, consumers want things that are “organic” and “natural.” When “synthetic” is combined with “biology,” people who know even less about synthetic biology than they know about nanotechnology don’t like it. There is a “yuck factor” associated with synthetic biology, as there was with irradiated food, that many people “are just not going to get over.” Use of the word “nanotechnology” does not elicit that same response. Just with the nomenclature, she said “you’re starting off at a better point than you might think you are.” Halloran agreed that nanotechnology is starting out with a “good rap” and that the iPod nano had done the technology a “huge favor.” Irradiation in food, on the other hand, started out as being associated with an effect of the atomic bomb and, as such, had to cross a huge hurdle. Either way, the public does not get enough credit for the “reasonable and rational way” they make their back-of-the-envelope risk/benefit analyses. With irradiated food, public perception was also influenced, for example, by a Consumer Reports project on irradiated food showing that irradiated meat did taste differently, that the irradiation did not kill all bacteria and potentially created a false sense of security, and that there were other ways to make meat safer. That was how Consumer Reports came to their conclusion about irradiated meat (i.e., not by associating it with effects of the atomic bomb), and that is how the average consumer forms his or her opinion as well. Halloran remarked further that not only do these technologies (irradiation and nanotechnology) involve complex decisions, those decisions are often made within the context of individual applica-
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Nanotechnology in Food Products: Workshop Summary tions and on a case-by-case basis. This is particularly true of the use of nanotechnology in food. Not only does each nanotechnology have different benefits, those benefits depend on the (food structure) matrix and all of the other variables that must be taken into consideration when conducting safety analyses. We can’t make broad generalizations about whether nanotechnology is good or bad. Naturally Occurring Nanosystems Food Forum member Eric Decker interjected with a comment on the common perception that processed foods are “evil” and that the addition of synthetic nanotechnology-derived compounds to foods would make consumers even more wary of processed foods. Yet, as Aguilera discussed during his presentation, many nanostructures naturally exist in foods. Not only do we consume nanostructures all the time, but also these nanostructures are often what make foods “good for us.” Casein micelles, which deliver calcium, are just one example. Decker stated that there has not been enough scientific exploration of naturally occurring nanosystems and the benefits they provide and that conducting more of that type of analysis would provide the means for telling a very positive story about a technology that “could be beneficial to everybody.” The Use of Nanotechnology to Treat Cancer Recognizing that the question was slightly off-topic, Porter then asked Philbert about the current status of using nanotechnology to treat cancer. Philbert said, “It is here.” There are at least two nanotechnology-derived formulations for anticancer therapeutics that are already FDA approved. Both are smaller reformulations of existing drugs. There is also a second wave of nanoscale approaches being applied in medicine where “nano” is no longer the “watchword” and where FDA “is going to hit the wall.” Philbert described these second-wave approaches as “nano-bio.” He and his colleagues, for example, are working on nano-bio hybrids of polymers and bioactive peptides for use in drug and contrast agent delivery. Philbert predicted that the FDA will not only have a difficult time categorizing some of these second-wave products, which fall somewhere between drugs and devices, but the agency will also have a difficult time evaluating their safety. It is very difficult to predict how the various components of many of these products break down.
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Nanotechnology in Food Products: Workshop Summary The Starting Point for Regulatory Guidance The focus of the discussion shifted back to issues related to safety and regulatory guidance when Porter asked Degnan and Tarantino if the FDA would be providing initial guidance with an Advanced Notice of Proposed Rulemaking (ANPR), commenting that this is how many other issues without proposed rules were started. Degnan replied that an ANPR is more time-consuming than guidance. If the guidance is structured as preliminary but thought-provoking, it could serve the same purpose as an ANPR with respect to “attracting attention, scrutiny, comment, and a level of thoughtfulness and attention that at least I haven’t seen to date.” Tarantino agreed. She said that guidance makes more sense than an ANPR if for no other reason than it is easier to change than a regulation, at least at this point. She referred to Degnan’s earlier comments about the importance of including questions about safety in the initial guidance and suggested that some of the questions asked at the public meeting on September 8, 2008, might serve as a good starting point. If a regulation in a certain area were to become useful, however, an ANPR would be a good way to solicit maximum input and ensure transparency. The goal, Tarantino said, is to encourage as much dialogue and involvement as possible. Degnan followed up by remarking that FDA in fact has a number of options and that multiple routes could be taken. Historically, FDA has simply used notices in the Federal Register to post questions. In the late 1980s, for example, prior to passage of the Nutrition Labeling and Education Act (NLEA), FDA issued a number of questions about how to regulate nutrition (e.g., whether mandatory nutrition is necessary and what authority FDA would have). As another example, about five or six years ago, FDA issued a similar notice asking questions about over-the-counter (OTC) drugs (e.g., Is this an appropriate way to proceed?). Finally, just a couple of months ago (in July/August 2008), FDA issued a notice in the Federal Register asking questions about the newly enacted section 912 of the FDC Act. So rather than taking a position one way or the other, the agency asks some “very probing questions.” Publishing a notice of this nature would be another way to initiate dialogue.
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Nanotechnology in Food Products: Workshop Summary How Other Governments Are Dealing with Nanotechnology Regulation Porter asked Yada and Aguilera how their governments were proceeding with nanotechnology regulation in food. Aguilera said that the Chilean government is only just beginning to talk about nanotechnology and that there is no specific initiative dealing with nanotechnology applications in food. It will become an important issue in the near future, however, since Chile exports more foods than most other Latin American countries. Yada replied that the situation in Canada is similar to that of the United States, with regulatory authorities still struggling with the issue. Many questions are being debated: Are we going to regulate the technology? Are we going to regulate the products? What guidelines will we use? Will we use the precautionary principle? Will we use substantial equivalencies? Yada noted that he had recently visited Ottawa, where he consulted with Canadian food inspection agency regulators who were “really probing” to identify the issues needing attention. Finally, Porter asked the other panelists if they knew of any other government that has moved ahead with respect to regulation of food nanotechnology. Halloran commented that the European Union (EU) had requested information on sunscreens with nanomaterials, which Halloran interpreted as an encouraging sign. More specifically, the EU requested that manufacturers provide safety data within a year (of the request). Wolf Maier of the EU commented that the UK Parliament was considering a motion to regulate all foods that contain particles derived from nanotechnology as normal foods, which would mean that they are subject to pre-market authorization. While the issue is not yet decided, the questioner remarked that pre-market authorization seems to be the direction headed. Tarantino offered a final remark: The EU food safety authority had issued a call for data and information to aid in its review process and also was receiving expert advice from the World Health Organization (WHO) and Food and Agriculture Organization (FAO). So agencies worldwide are gathering information in an effort to decide how best to proceed. Importing Food Products That Contain Nanomaterials Doyle noted that the first four speakers of the day were from outside of the United States and that obviously there is a lot of international ac-
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Nanotechnology in Food Products: Workshop Summary tivity in the area of food nanotechnology. He asked, how will the United States address the import of nanotechnology-derived foods? Degnan responded by stating that FDA’s authority over imports is its broadest authority and that the agency can detain a product based simply on the appearance of a violation. It is a very tough standard—appearing to be a violation is very different than having been proven to be a violation. But the FDA needs to be prepared, he said, so that regulatory decisions are not being made in an enforcement context. Regulatory decisions need to be made in a deliberate, meaningful, structured way with respect to both statutory standards and available science. Tarantino said that the easy answer is that all imported foods must meet U.S. safety standards, “whatever those are.” The bigger issue is how do you do that? She agreed with Degnan that the FDA needs to be prepared. She said, “I think trying to stay abreast of what actually is happening not only in this country but elsewhere is, right now, the best we can do to … anticipate what we are likely to be seeing.” The workshop was then adjourned.
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