OUT OF THE LABORATORY AND ON TO OUR PLATES Nanotechnology in Food & Agriculture March 2008 A report prepared for Friends of the Earth Australia, Friends of the Earth Europe and Friends of the Earth United States and supported by Friends of the Earth Germany. 2nd edition April 2008 Written by Georgia Miller and Dr. Rye Senjen, Friends of the Earth Australia Nanotechnology Project. With contributions from Patricia Cameron, John Hepburn, Helen Holder, Guillermo Foladori, George Kimbrell, Aleksandra Kordecka, Kristen Lyons, Ian Iluminato, Arius Tolstoshev, Gyorgy Scrinis, Katja Vaupel, Jurek Vengels and many others. Design and layout by Natalie Lowrey [email protected] For an electronic copy of this report, or further Australia, Europe and U.S.A briefing papers from Friends of the Earth please refer to our websites: Friends of the Earth Australia http://nano.foe.org.au This report was funded by Friends of the Earth United Friends of the Earth Europe States, Friends of the Earth Europe, Friends of the Earth http://www.foeeurope.org/activities/ Australia and Friends of the Earth Germany (BUND). nanotechnology/index.htm Friends of the Earth Europe gratefully acknowledges Friends of the Earth Germany: financial support from the European Commission’s http://www.bund.net/ DG Environment and the 31 national member groups Friends of the Earth United States of Friends of the Earth Europe. This report does not http://www.foe.org/camps/comm/nanotech/ necessarily reflect the opinions of its funders. The This is a report by FoE Australia, FoE Europe and European Commission and other funders cannot FoE United States. Any mention of “FoE” in this be held responsible for any further use that may be report refers to the above groups and not to FoE made of the information contained herein. International OUT OF THE LABORATORY AND ON TO OUR PLATES Nanotechnology in Food & Agriculture s Executive Summary 2 t n A short introduction to nanotechnology 4 e t Nanotechnology enters the food chain 9 n o Nanotechnology and food processing 12 C Nanotechnology used for food packaging and food contact materials 15 Nanotechnology used in agriculture 19 Nanofoods and nano agrochemicals pose new health risks 22 Nanofoods and nano agriculture pose new environmental risks 29 Time to choose sustainable food and farming 32 Nano-specific regulation required to ensure food safety 37 The right to say no to nanofoods 44 Recommendations for sustainable food and farming 46 Civil society groups are already taking action to keep food nano-free 49 Glossary 50 Appendix A: List of agriculture and food products identified by FoE that contain manufactured nanomaterials 51 Appendix B: Summary of EU regulations potentially applicable to nanofood and nano food packaging 58 References 59 Executive Summary In the absence of mandatory product access to our bodies, so they are more labelling, public debate or laws to ensure likely than larger particles to enter cells, their safety, products created using tissues and organs. These novel properties nanotechnology have entered the food offer many new opportunities for food chain. Manufactured nanoparticles, industry applications, for example as nano-emulsions and nano-capsules are potent nutritional additives, stronger now found in agricultural chemicals, flavourings and colourings, or antibacterial processed foods, food packaging and ingredients for food packaging. However food contact materials including food these same properties may also result in storage containers, cutlery and chopping greater toxicity risks for human health and boards. Friends of the Earth has identified the environment. 104 of these products, which are now There is a rapidly expanding body of on sale internationally. However given scientific studies demonstrating that that many food manufacturers may be some of the nanomaterials now being unwilling to advertise the nanomaterial used in foods and agricultural products content of their products, we believe introduce new risks to human health this to be just a small fraction of the and the environment. For example, total number of products now available nanoparticles of silver, titanium dioxide, worldwide. zinc and zinc oxide, materials now used in Nanotechnology has been provisionally nutritional supplements, food packaging defined as relating to materials, systems and food contact materials, have been and processes which exist or operate at found to be highly toxic to cells in test a scale of 100 nanometres (nm) or less. tube studies. Preliminary environmental It involves the manipulation of materials studies also suggest that these substances and the creation of structures and systems may be toxic to ecologically important at the scale of atoms and molecules, the species such as water fleas. Yet there nanoscale. The properties and effects of is still no nanotechnology-specific nanoscale particles and materials differ regulation or safety testing required significantly from larger particles of the before manufactured nanomaterials same chemical composition. can be used in food, food packaging, or Nanoparticles can be more chemically agricultural products. reactive and more bioactive than larger Early studies of public opinion show that particles. Because of their very small size, given the ongoing scientific uncertainty nanoparticles also have much greater about the safety of manufactured 2 | NANOTECHNOLOGY IN FOOD & AGRICULTURE nanomaterials in food additives, • All deliberately manufactured ingredients and packaging, people do nanomaterials must be subject to rigorous not want to eat nanofoods. But because nano-specific health and environmental there are no laws to require labelling of impact assessment and demonstrated to manufactured nano ingredients and be safe prior to approval for commercial additives in food and packaging, there use in foods, food-packaging, food is no way for anyone to choose to eat contact materials or agricultural nano-free. applications. Nanotechnology also poses broader The size based definition of challenges to the development of more nanomaterials must be extended sustainable food and farming systems. At a time when global sales of organic food • All particles up to 300nm in size must and farming are experiencing sustained be considered to be ‘nanomaterials’ for growth, nanotechnology appears likely to the purposes of health and environment entrench our reliance on chemical and assessment, given the early evidence that energy-intensive agricultural technologies. they pose similar health risks as particles Against the backdrop of dangerous less than 100nm in size which have to date climate change, there is growing been defined as ‘nano’. public interest in reducing the distances Transparency in safety assessment and that food travels between producers product labelling is essential and consumers, yet nanotechnology appears likely to promote transport of • All relevant data related to safety fresh and processed foods over even assessments, and the methodologies used greater distances. The potential for to obtain them, must be placed in the nanotechnology to further concentrate public domain. corporate control of global agriculture • All manufactured nano ingredients must and food systems and further erode local be clearly indicated on product labels to farmers’ control of food production is also allow members of the public to make an a source of concern. informed choice about product use. Given the potentially serious health and Public involvement in decision making environmental risks and social implications is required associated with nanofood and agriculture, Friends of the Earth Australia, • The public, including all stakeholder Europe and United States are calling for: groups affected, must be involved in all • A moratorium on the further aspects of decision making regarding commercial release of food products, nanotechnology in food and agriculture. food packaging, food contact This includes in the development of materials and agrochemicals that regulatory regimes, labelling systems, and contain manufactured nanomaterials prioritisation of public funding for food until nanotechnology-specific safety and agricultural research. People’s right to laws are established and the public is say no to nanofoods must be recognised involved in decision making. explicitly. Support for sustainable food and Nanomaterials must be regulated as farming is needed new substances • The assessment of food and agricultural • All deliberately manufactured nanotechnology, in the context of wider nanomaterials must be subject to new societal needs for sustainable food and safety assessments as new substances, farming, must be incorporated into even where the properties of their larger relevant decision making processes. scale counterparts are well-known. Friends of 3 the Earth NANOTECHNOLOGY IN FOOD & AGRICULTURE | A short introduction to nanotechnology What is nanotechnology? 7,000 nm and a human hair is 80,000 nm wide. If one imagines that a nanometre is The term ‘nanotechnology’ does not represented by a person, a red blood cell describe a singular technology, but rather would be 7 kilometres long! encompasses a range of technologies that operate at the scale of the building blocks of biological and manufactured Nanotechnology is a platform materials – the ‘nanoscale’. technology Nanotechnology has been provisionally The novel properties of nanomaterials defined as relating to materials, systems offer many new opportunities for the food and processes which operate at a and agricultural industries, for example as scale of 100 nanometres (nm) or less. more potent food colourings, flavourings Nanomaterials have been defined as and nutritional additives, antibacterial having one or more dimensions measuring ingredients for food packaging, and more 100nm or less, or having at least one potent agrochemicals and fertilisers. In dimension at this scale which affects many instances the same technology the materials’ behaviour and properties. can enable applications across the whole However this definition of nanomaterials is agriculture and food supply chain. For likely to be far too narrow for the purposes example, nanoclay composites – plastics of health and environmental safety to which nanoscale clay platelets have assessment (see below). been added – are now used widely in One nanometre (nm) is one thousandth food and beverage packaging, as well of a micrometre (µm), one millionth of as in agricultural pipes and plastics to a millimetre (mm) and one billionth of allow controlled release of herbicides, a metre (m). To put the nanoscale into and have been studied for their use in context: a strand of DNA is 2.5nm wide, a controlled release fertilizer coatings. The protein molecule is 5nm, a red blood cell capacity to apply nanotechnologies across multiple sectors not only delivers greater returns on research investment, but also enables companies to expand Size based definitions of small particles Smaller than 100nm – a nanoparticle Smaller than 1,000nm (a micron, or micrometer also written as 1µm) – a sub-micron microparticle Larger than 1,000nm – a microparticle A light-conducting silica nanowire wraps a beam of light around a strand of human hair. The nanowires are flexible and can be as slender as 50 nanometers in width, about one thousandth the width of a hair. Photo: Limin Tong/Harvard University. 4 | NANOTECHNOLOGY IN FOOD & AGRICULTURE commercial activities into entirely new bioavailability of nanomaterials may also market segments and new industries. result in greater toxicity of nanoparticles For this reason, nanotechnology is often compared to the same unit of mass of called a ‘platform technology’. larger particles of the same chemical In coming years and decades, composition (Hoet et al. 2004; Oberdörster ‘next generation nanotechnology’ is et al. 2005a; Oberdörster et al. 2005b). forecast to move beyond the use of Other properties of nanomaterials that simple particles and encapsulated influence toxicity include: chemical ingredients to the development of more composition, shape, surface structure, complex nanodevices, nanosystems surface charge, catalytic behaviour, and nanomachines (Roco 2001). The extent of particle aggregation (clumping) application of nanotechnology to or disaggregation, and the presence or biotechnology (‘nanobiotechnology’) absence of other groups of chemicals is predicted not only to manipulate the attached to the nanomaterial (Brunner et genetic material of humans, animals and al. 2006; Magrez et al. 2006; Sayes et al. agricultural plants, but also to incorporate 2004; Sayes et al. 2006). synthetic materials into biological Some nanomaterials have proved structures and vice versa (Roco and toxic to human tissue and cell cultures Bainbridge 2002). Converging nanoscale in in vitro (test tube) studies, resulting in technologies are predicted to enable increased oxidative stress, production the creation of entirely novel artificial of proteins triggering an inflammatory organisms for use in food processing, response (Oberdörster et al. 2005b), DNA agriculture and agrofuels, as well as other mutation (Geiser et al. 2005), structural applications (ETC Group 2007). This field is damage to cell nuclei and interference known as synthetic biology. with cell activity and growth (Chen and von Mikecz 2005), structural damage to mitochondria and even cell death Nanomaterials have novel properties (Li et al. 2003). Nanomaterials now in and pose novel risks commercial use by the food industry, such To put it simply: small particle size equates as nano titanium dioxide, silver, zinc and to new particle properties, which can zinc oxide have been shown to be toxic to also introduce new risks. Nanoparticles cells and tissues in in vitro experiments and have a very large surface area which to test animals in in vivo studies (see Table typically results in greater chemical 9). reactivity, biological activity and catalytic Nanomaterials have such diverse behaviour compared to larger particles properties and behaviours that it of the same chemical composition is impossible to provide a generic (Garnett and Kallinteri 2006; Limbach et assessment of their health and al. 2007; Nel et al. 2006). Nanomaterials environmental risks (Maynard 2006). also have far greater access to our body The shape, charge and size of different (known as bioavailability) than larger particles can influence their kinetic particles, resulting in greater uptake (absorption, distribution, metabolism into individual cells, tissues and organs. and excretion) and toxic properties Materials which measure less than (Hagens et al. 2007). For this reason even 300nm can be taken up by individual nanomaterials of the same chemical cells (Garnett and Kallinteri 2006), while composition which have different sizes or nanomaterials which measure less than shapes can have vastly different toxicity 70nm can even be taken up by our cells’ (Sayes et al. 2006). Until we have a much nuclei, where they can cause major more comprehensive understanding of damage (Chen and Mikecz 2005; Geiser the biological behaviour of nanomaterials, et al. 2005; Li et al. 2003). Unfortunately, it is impossible to predict the toxicity risks the greater chemical reactivity and associated with any one material, and Friends of 5 the Earth NANOTECHNOLOGY IN FOOD & AGRICULTURE | each new nanomaterial must be subject risk for human health (U.K. RS/RAE 2004). to new health and safety assessment prior However the suitability of the 100nm to its commercial use. Maynard (2006) definition has recently been queried, notes that “it is clear from published especially in relation to health and toxicity studies that particle size alone environmental safety assessment. There is not a good criteria for differentiating is growing international recognition that between more or less hazardous materials some particles greater than 100nm exhibit and technologies”. However particle similar anatomical and physiological size remains an obvious, if somewhat behaviour to nanomaterials. Novel, crude, criteria that could trigger more size-dependent behaviour seen in comprehensive testing and particle particles which measure a few hundred characterisation, prior to a nanomaterial nanometres includes very high reactivity, being permitted in commercial foods and bioactivity and bioavailability, increased agricultural products. influence of particle surface effects and strong particle surface adhesion (Garnett and Kallinteri 2006). Significantly, The need to broaden the provisional preliminary studies also suggest that some 100nm definition of nanomaterials particles which measure a few hundred for health and environmental safety nanometres, or even 1,000nm, can pose assessment comparable health risks to particles now The International Standards Organisation considered to be ‘nano’ (Wang et al. (ISO) and ASTM International have not 2006; Ashwood et al. 2007). yet agreed on a size-based or other definition for nanomaterials. However Governments and scientists still many government bodies and scientific uncertain about the best size to define institutions have begun using the provisional definition of nanomaterials nanomaterials as having novel, size-dependent The size at which it makes sense to define characteristics which are not seen in materials as ‘nano’ and to subject larger particles of the same material. them to nano-specific health and Typically this is defined as a particle environmental safety assessment remains having at least one dimension existing in the topic of discussion within standards the size range of 0.2 - 100nm (i.e. above bodies, in government and in the scientific the atomic level up to 100nm). This size literature. We still know very little about definition is somewhat arbitrary, but it why the properties of nanomaterials has been considered that materials of are different from larger particles and less than100nm in size are most likely to how factors such as size, shape, surface exhibit novel, nano-specific properties charge etc. interact to affect toxicity due to their increased relative surface and the particles’ biological behaviour. area and the dominance of quantum Consequently, we do not yet know effects in this size range (U.K. RS/RAE 2004). enough to determine the appropriate Altered properties can include greater size limit at which materials should be chemical reactivity, altered colour, subject to nano-specific health and safety strength, solubility, electrical conductivity assessment, although there is growing etc. Importantly, nanoparticles also agreement that 100nm is likely to be have greater access to our bodies’ cells, insufficient in at least some instances. tissues and organs than larger particles Reflecting the considerable uncertainty of the same material. In its 2004 report around what size is most appropriate to the United Kingdom’s Royal Society and consider a material to be a nanomaterial, Royal Academy of Engineering identified different government agencies, research unbound particles of less than100nm in institutions and scientists have used size as presenting the greatest potential different sizes to define them. In its 2006 6 | NANOTECHNOLOGY IN FOOD & AGRICULTURE voluntary industry notification scheme, the size and a particle’s biological behaviour, British government defined nanomaterials given the poorly understood role of as “having two or more dimensions up to other factors including shape, surface 200nm” (U.K. DEFRA 2006). In a 2006 report properties, charge, coatings etc. However the Chemical Selection Working Group we also appreciate the need for a size- of the U.S. Food and Drug Administration based trigger to ensure that particles that (FDA) defined nanomaterials as “particles may pose novel toxicological risks are with dimensions less than micrometer subject to appropriate new safety testing scale [i.e. less then 1,000nm] that exhibit and regulation prior to being allowed unique properties not recognized in in commercial foods and agricultural micron or larger sized particles” (U.S. FDA products. Given that particles up to a few 2006). Food scientists from Australia’s hundred nanometres in size share so many Commonwealth Scientific and Industrial of the physiological and anatomical behaviours of nanomaterials, including Research Organisation (CSIRO) have also the ability to be taken up into individual defined nanomaterials as measuring up to cells, and that preliminary studies have 1,000nm (Sanguansri and Augustin 2006). indicated that particles in this size range In a 2007 report on nanomaterials FDA may pose size-dependent toxicity risks, a chose not to offer a size-based definition precautionary approach is warranted. We at all (U.S. FDA 2007). recommend that particles up to 300nm in size are treated as nanomaterials for the Why Friends of the Earth recommends purposes of health and safety assessment. defining nanomaterials as less than To enable comparison of the discussion 300nm for the purposes of health and and studies cited in this report with other environmental safety assessment literature, we restrict the use of the term nanoparticle to particles which have at Friends of the Earth recognises that there is least one dimension which measures less not a clear relationship between particle Friends of 7 the Earth NANOTECHNOLOGY IN FOOD & AGRICULTURE | than 100nm. However given the evidence In this report, Friends of the Earth focuses of nano-specific biological behaviour on manufactured nanomaterials used and related toxicity risks associated with in food and agriculture. However we particles a few hundred nanometres in recognise that the presence of incidental size, Friends of the Earth urges regulators nanomaterials in foods, for example as a responsible for assessing and managing result of the wear from food processing the health and environmental risks of equipment, could also pose new health nanoparticles to require particles up risks which warrant consideration by to 300nm in size to be subject to nano- regulators. specific safety testing and regulation prior to being permitted for commercial use in The need to investigate the health and food and agricultural products. environmental implications of other small particles Manufactured vs. incidental Preliminary evidence suggests nanoparticles that although these particles may ‘Manufactured’ nanomaterials are those be thousands of times larger than which are produced deliberately. They nanoparticles, small microparticles around include nanoparticles (e.g. metal oxides 1-20µm in size (1,000 – 20,000nm) may such as zinc oxide and titanium dioxide), also pose health risks. Microparticles as well as structures created through do not have the same bioavailability nanotechnology such as nanotubes, of nanoparticles and they cannot be nanowires, quantum dots, dendrimers and taken up by individual cells. They are also carbon fullerenes (buckyballs), among comparatively less chemically reactive others (see glossary). and bioactive than nanoparticles, and In comparison, ‘incidental’ nanoparticles bioactive than nanoparticles. However are nanoparticles which are not the reactivity and bioavailability of manufactured deliberately, but either microparticles remain far greater than occur in nature or as a byproduct of that of larger particles (Sanguansri and industrial processes. Sources of incidental Augustin 2006). Studies using rats have nanoparticles, also called ultrafine demonstrated gastrointestinal uptake of particles in the study of air pollution, particles measuring up to 20µm in size, include forest fires and volcanoes, and mainly via Peyer’s Patches in the small high-temperature industrial processes intestine (Hagens et al. 2007). Pathology such as combustion, welding, grinding studies also suggest that microparticles up and exhaust fumes of cars, trucks and to 20µm in size are taken up through the motorcycles (U.K. HSE 2004). Although human gastro-intestinal tract, translocated humans have historically been exposed through the body, and accumulate in to small numbers of these incidental secondary organs where they may be nanoparticles, until the industrial revolution associated with long-term pathological this exposure was quite limited. damage, for example the development The emerging field of nanotoxicology of granulomas and lesions (Ballestri et al. (the study of the risks associated with 2001; Gatti and Rivassi 2002). Granulomas manufactured nanomaterials) is being and lesions can have serious long- informed by our understanding of risks term health effects, leading to chronic associated with incidentally produced inflammation and even cancer. Beyond nanoparticles. For example, we know the need for nanotechnology-specific that exposure to large levels of incidental regulation for nanomaterials in foods and nanoparticles in urban air pollution causes food contact materials, Friends of the increased incidence of disease and even Earth therefore also urges regulators to death among vulnerable sections of the investigate the need for appropriate new population (Yamawaki and Iwai 2006). safety assessments of small microparticles. 8 | NANOTECHNOLOGY IN FOOD & AGRICULTURE