Nanotechnology and the Implications for Organic

By Mary C. Mulry, Ph.D.


The term “nano” (from a Greek word for dwarf) means a factor of one billionth (10-9), or for measurement of length, one billionth of a meter (1 nanometer or nm). By comparison, a red blood cell is 7000 nm wide and a human hair is 50,000 to 100,000 nm thick. In other words, nanoscale is really, really small. Nanotechnology usually involves manufacturing or manipulating materials with dimensions of 1 to 100 nm. The field of nanotechnology should properly be called nanotechnologies, however, as it crosses the fields of biology, physics and chemistry, all sciences based on molecular structures. Another relatively new term, “synthetic biology,” which refers to building new DNA from the ground up (sometimes called super biotechnology) is a type of nanotechnology. It is often thought to be used to create bacteria or new superbugs for biofuel production and other uses. Considered by many to be extreme genetic engineering, it would not be allowed in organic agriculture under the current regulations and therefore will not be addressed specifically in this article.

Why the excitement and concern about nanotechnology? Due to the dominance of quantum mechanics at these molecular levels, materials that are this small do not act the same as at macro-levels. Some notable examples to illustrate these effects:
• Carbon in the form of graphite (like pencil lead) is soft and malleable; at nanoscale, carbon can be stronger than steel.

• Zinc oxide is usually white and opaque; at nanoscale it becomes transparent, important for nonwhite sunscreens.

• Aluminum oxide is used by dentists to repair teeth; nanoscale particles of the same chemical compound can be used as explosives.

Nanostructures in Foods
Mother Nature has deftly exploited materials at the nanoscale. A glucose molecule is 1 nm in size. Food proteins are often globular structures ranging from 1 to 10 nm. The functionality of many raw materials and the successful processing of foods arise from the presence, modification and generation of many forms of nanomaterials. Examples include homogenization of milk, milling of flour, gelatinization of starches, and the stability of foams and emulsions. Understanding about nanomaterials in foods may allow for better selection of raw materials and enhanced food quality through processing. It is not “traditional” food processing where the concern lies, however. It is the growing trend of engineered materials at the molecular level that may exhibit radically different properties than those of traditional foods. Packaging with antimicrobial properties due to imbedding of nanoscale silver, nutrients with enhanced bioavailability, and food additives with dramatic increases in functionality are just some of the promises in this new world of food nanotechnology.

As with many new technologies, especially those involving our food supply, there is controversy rooted in lack of awareness, knowledge and understanding of the issue by consumers, manufacturers, and regulators. This same set of issues has been experienced with other technologies such as food irradiation and agricultural biotechnology, especially when applied to organic production. In order for public policy and regulation to be developed, an understanding of the unique benefits of a particular new technology must be weighed versus the risks, safety concerns and its effects on health and the environment. Regrettably, there is general agreement that the information available in many of these areas is woefully inadequate and there is little understanding of these issues, even among food professionals.

In addition, the “horse is already out of the barn” with an estimated 1000 total consumer products that self-identify as based on nanotechnology. Of those, 98 fall into the food and beverage category, including those involving food packaging, dietary supplements and foods, according to the Project on Emerging Nanotechnologies.

“I am trying to understand what to think about food nanotechnology and whether it is good, bad or indifferent,” writes Marion Nestle in her influential “Food Politics” blog. This seems to reflect the sentiment of many on the issue of food nanotechnology. However, when it’s discussed in the context of organic foods, the lines become more sharply drawn. Some organic standards have included bans on the technology already, including the Soil Association in the United Kingdom and the recently implemented Canadian organic standard. At the Fall 2009 meeting of the National Organic Standards Board (NOSB), the Materials Committee put forth a recommendation to ban nanotechnology in organic production. With a lack of consensus and understanding on the issue, the recommendation will be further revised for discussion and recommendation at a future meeting.

Public Opinion
It has been difficult to gauge public attitudes towards nanotechnology in recent years due to the limited number of surveys on the topic. However, according to Hart Research Associates in their 2009 report, awareness of nanotechnology has been increasing over the last 10 years, but the increases have largely stalled in the past four years. Today, three in 10 Americans say they have heard a lot or some about nanotechnology, about the same proportion as in 2006. However, more than two-thirds of Americans still have heard little or nothing about nanotechnology.

In the UK, according to a Food Standards Agency (FSA) report, while the public often had concerns about aspects of nanotechnologies, this view was generally balanced by an optimistic view of the potential benefits. When questioned about applications to food specifically though, people seem less convinced about the potential benefits that food applications might bring. The FSA report states, “There appears to be much less enthusiasm towards their [nanotechnologies’] use in food than in other applications.”

Health and Safety Concerns
The unique properties of nanomaterials give rise to many concerns about health and safety because they can be inhaled and absorbed through the skin easily. After ingestion, nanoparticles may have more access to tissues and cells and could cross the blood-brain barrier, cause unpredictable immune system effects or accumulate in our bodies.

There have been a few documented studies that have shown toxicity in animals. Carbon nanotubes injected into the abdominal cavity of rats caused similar lesions to those of asbestos in the lungs. Inhalation of nanoparticles has been shown to cause abnormal immune effects and accumulation of fluid in the lungs of animals as well. So far, there have been few studies of the ingestion of nanoparticles, so it is very difficult to balance the benefits of the technology with the risks.

Environmental Risks
Similarly, there is limited information on the environmental risks of nanotechnology, but many of the potential risks have been identified. Nano-silver particles used for antimicrobial applications in food packaging might interfere with beneficial bacteria in our bodies and the environment. As with antibiotic usage in livestock, there is a risk of creating more virulent and harder to treat bacterial infections. Titanium dioxide and zinc oxide from nanotechnology have been shown to be toxic to rainbow trout, algae and water fleas.

A recent report by the House of Parliament in the UK detailed the knowledge gaps that are present when discussing food nanotechnology and called for a broad, coordinated research agenda among industry, academia and government to close these knowledge gaps as quickly as possible.

Current Regulatory Oversight
In general, nanomaterials for use in foods have no unique regulatory oversight or labeling. While the U.S. Food and Drug Administration (FDA) agrees that nanomaterials may have unique properties, they maintain that existing food laws may be sufficient for adequate regulatory oversight of nanotechnology. The European food regulations are similar in that nanotechnology is regulated under existing food laws. Some advocacy groups disagree, given the health and safety concerns. This prompted Friends of the Earth to propose a moratorium on approval of any new materials derived from nanotechnology.

Two Democratic legislators have recently introduced a bill that would create an FDA program to assess the potential health and safety effects of nanotechnology ingredients in various consumer products. Senators Mark Pryor (D-AR) and Benjamin L. Cardin (D-MD) introduced the “Nanotechnology Safety Act of 2010,” S. 2942, late in January of this year. The bill would create a program for the scientific investigation of nanoscale materials included or intended for inclusion in FDA-regulated products, to address the potential toxicity of such materials, the effects of such materials on the environment, and the interaction of such materials with biological systems. Specifically, FDA would be charged to assess scientific literature and data on general nanoscale material interactions and on specific nanoscale materials of concern to the Agency. It would also mandate the collection, synthesis, interpretation and dissemination of scientific data related to the interactions of nanoscale materials with biological systems. The bill would authorize $25 million each year from 2011 through 2015.

Nanotechnology and Organic Production
In March 2009, the Materials Committee of the NOSB put together a discussion document and requested comments on questions related to nanotechnology and its compatibility with organic production. Out of this process, a policy recommendation was put forth for public comment and discussion at the November meeting. The committee defined nanotechnology as: “Technology and the result of that technology that is intent on a) creating and using structures, devices, and systems that have novel properties and functions because of their small size, b) maintaining the ability to control or manipulate on the atomic scale, and c) researching and developing technology at the atomic, molecular or macro-molecular level, typically in the size scale of approximately 1 to 100 nanometer range.”

The recommendation then stated that nanotechnology would be prohibited as an excluded method in 7CFR205.105, as is the case for genetic engineering, irradiation and the use of sewage sludge. A minority opinion was put forth from the committee that disagreed with a complete ban on the technology and recommended that materials developed from nanotechnology be classified as synthetic and be reviewed on a case-by-case basis.

The public comments and discussion primarily centered around four issues:
1. The definition of nanotechnology

2. Whether or not it should be considered an excluded method

3. How to define it so as not to exclude ordinary food processing methods, such as flour milling or milk homogenization, which create particles in the nano- range

4. Whether or not banning nanotechnology would also include non-contact packaging technologies, such as Radio Frequency Identification Devices (RFIDs).

In general, the definition of nanotechnology was thought to be too narrow in the size range, with some advocating sizes up to 300 nm, since these larger particles may exhibit unique properties. While most standard definitions of nanotechnology use the 1 to 100 nm range, they do not exclude the possibility of larger particles also being included. The Soil Association has indicated that its licensees must not use ingredients containing manufactured nanoparticles, where the mean particle size is 200 nm or smaller.

Most of the consumer advocacy and environmental groups, such as the Consumers Union, Center for Food Safety, Friends of the Earth, the National Organic Coalition and the Organic Consumers Association (OCA), supported considering nanotechnology an excluded method. Other groups, such as the Organic Trade Association (OTA) and the Institute of Food Technologists (IFT) felt that excluding nanotechnology could put organic production at a disadvantage in the future. Consequently, they supported the minority opinion to treat the materials as synthetic and review on a case-by-case basis.

The Materials Committee could not reach a consensus on a new recommendation, so it was tabled. According to Dan Giacomini, chairperson, Materials Committee and consultant, Pacific Nutrition-Consulting, “The recommendation will be revised by the Materials Committee and brought back to the full NOSB at a future meeting.”

It is likely that the U.S. will look to our neighbors to the north, Canada. They recently agreed on a policy to exclude engineered nanotechnology from their newly implemented organic standard. According to Dag Falck, organic program manager for Nature’s Path Foods, and a member of the Canadian General Standards Board Committee on Organic Agriculture, “Regulating the application of nanotechnology in organic becomes a fine balance between protecting organic products from exposure to non-compatible technologies, and not restricting organic operators from using normal and safe practices.”

The definition of nanotechnology used was consistent with that of Environmental Health Canada: “Nanotechnology is a field described generally as the control and structuring of matter at dimensions typically between 1 and 100 nm to create materials, devices and systems with fundamentally new properties and functions. Nanoscale chemical substances, or nanomaterials, behave differently from their macroscale counterparts, exhibiting different mechanical, optical, magnetic and electronic properties.”

The Canadian standard bans nanotechnology, but does so without including normal food processing technologies in the ban, stating: “When producing or handling organic products, it is forbidden to use any of the following substances or techniques: intentionally manufactured nanotechnology products, or nano-processes involving intentional manipulation of matter at the nano-scale to achieve new properties or functions that are different than properties and functions of the materials at the macro-scale, except naturally occurring nano-sized particles, or those produced incidentally through normal processes such as grinding flour, or nano-sized particles used in a way that guarantees no transference to product.”

Learning from the Past
The future of nanotechnology rests on public acceptance that the benefits outweigh the risks. One of the main conclusions of the House of Lords’ report is that the development of nanotechnology should acknowledge lessons learned from the past, including issues with genetically modified foods, mad cow disease and vaccines. “If policy-makers and communicators recognize and act on these lessons, it may help enable consumers to make informed judgments about the risks and benefits of novel technologies,” stated the report.

These lessons include:
• Recognizing the limitations of scientific knowledge and not making overconfident claims about safety or risk

• Acknowledging scientific uncertainties

• Being transparent about the process of scientific risk assessment, and the risks that the public may be exposed to

• Recognizing that public concerns which extend beyond purely scientific issues have a significant effect on the public’s acceptance of new technologies.

It appears that nanotechnology is repeating some of the history and trajectory of genetic engineering. The technology has been developed with a relative lack of transparency to the public, government or industry. It has largely unknown but potentially wide-ranging effects on health, the environment and the future of food and agriculture. Some applications of the technology, such as nano-silver for water treatment and antimicrobials, may proceed for the purported benefits of clean water and safe food, but with little regard for the ubiquitous nature of the material and lack of its identification or measurement in the environment. For example, if mandated for municipal water filtration, it will be impossible to prevent its use in organic production.

However, the perceived benefits are wide-ranging as well and the industry is predicted to continue to grow and develop at a rapid pace. The organic industry and the public must insist on involvement in policy development and transparency from the food and agriculture sectors on their activities in nanotechnology in order to achieve the benefits without negative impacts on organic production.

Mary C. Mulry, Ph.D. is president of FoodWise, Inc., a natural, organic and specialty foods technical consultancy. Dr. Mulry has more than 25 years’ experience in product development, nutrition, product innovation and strategy, and quality systems. Her background has encompassed the entire food supply chain from ingredients to retailing, and she has worked on projects involving natural and organic foods, functional foods and dietary supplements for companies ranging in size from start-ups to large multi-national consumer packaged goods’ companies. She has held management positions at Kellogg, Kraft Foods, Celestial Seasonings, Wild Oats Markets and H-E-B. She can be reached at foodwise@aol.com.