Nanotechnologies and Food: Science and Technology Committee Report
(13 years, 10 months ago)
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Lord Krebs
That this House takes note of the Report of the Science and Technology Committee on Nanotechnologies and Food (First Report, Session 2009–10, HL Paper 22).
Lord Krebs
My Lords, I start by declaring two interests, as a former chair of the Food Standards Agency and as president of Campden BRI.
Nanotechnology is the study of the very small. It involves manipulating matter on the scale of atoms or molecules. If you are like me, you may find it difficult to get your mind around just how small “small” means. Let me give you an idea. It is sometimes claimed that medieval scholars such as Duns Scotus and Thomas Aquinas debated the question of how many angels can fit on the head of a pin or even the point of a needle. The authenticity of this claim is disputed, although in 1667 Richard Baxter, in his tract The Reasons of the Christian Religion, definitely refers to such a debate. If we move from angels to nanoparticles, how many could you fit on the head of a pin? The answer is 300 million nanoparticles, each 100 nanometres in diameter. Alternatively, your Order Paper is roughly 100,000 nanometres thick. A further day-to-day illustration to make the point for noble Lords present is that their beards will have grown by roughly 200 nanometres since I started speaking. That is not a personal statement but a general phenomenon.
The notion of manipulating materials at the nanoscale was first suggested in 1959 by the Nobel Prize-winning physicist Richard Feynman, who noted that at this very small scale the conventional forces that we think of as influencing materials, such as gravity, would be replaced by other forces at the atomic level. As a result of this, and the very large surface area to volume ratio, the properties of materials may change dramatically at the nanoscale when compared with more conventional scales. For example, normal silver melts at a temperature of 960 degrees Celsius, but nanoscale silver particles can be melted with a hairdryer.
The phrase “nanotechnology” was first used in 1974 by the Japanese scientist Norio Taniguchi, and nowadays the potential of nanomaterials and nanotechnologies is being explored in many areas, from electronics to materials and the self-assembly manufacturing processes. Nanotechnology has also become the stuff of science fiction. Some commentators have been influenced by Michael Crichton’s book Prey, in which nanoparticles self-assembled into free-flying swarms that attacked human brains. Unfortunately, Mr Crichton got his science wrong. The forces of Brownian motion that act on nanoparticles would prevent them from assembling into co-ordinated swarms. The grey goo of certain parts of the popular press is a myth of science fiction.
Let me turn to the specifics of our inquiry. We chose to focus on just one area—the application of nanotechnologies in the food industry. In making that choice, we wished to restrict the range of our inquiry and we were also aware of previous, more general reports, notably an excellent Royal Society/Royal Academy of Engineering report, published in 2004.
The use of nanotechnology in the food sector is projected by experts to be a growth area. One projection is that by 2012 the global market for nanotechnologies in the food industry will reach a figure of $5.8 billion. What are the current and potential applications of nanotechnology in food and food-related products? This may appear to be a simple question but, as noble Lords will hear in a moment, the answer is not that straightforward. Scientific experts advise us that the potential of nanotechnologies in food may be summarised under four main headings. First, there is the reformulation of processed food. For instance, smaller quantities of an ingredient can achieve the same flavour and mouth feel if the ingredients are nanoscaled. This is in part because of the large surface area of nanoscaled particles. You can reduce the salt content of food without affecting its taste and reduce the fat content of food, such as ice cream or mayonnaise, without affecting their eating properties. You can also deliver nutrient supplements in nanoencapsulated particles that have nutritional benefit without affecting flavour. For instance, there is a loaf on sale in Australia that contains nanoencapsulated fish oils—the long chain polyunsaturated omega-3 oils that are good for the heart and perhaps the brain.
The second area is food packaging. We heard that nanotechnology can improve the barrier properties of food or drink packaging and therefore reduce waste by enabling food to be kept longer. To give one example, one of the major manufacturers of beer in the USA produces it in plastic bottles with a nanoclay layer to prevent the gas escaping and the beer going flat. There is also the potential for so-called intelligent packaging which will detect chemical changes in the food and enable the consumer to throw it away at the right moment rather than slavishly following best-before dates.
The third area of potential application is in the manufacturing process where we heard that nonotechnology can be used to develop anti-stick and anti-microbial surfaces to increase the efficiency of food manufacture. The fourth area of potential application is in agriculture, where we heard that nanoscaled pesticides or fertilisers may enable the farmer to use smaller doses and thereby reduce potential harm to the environment as well as save money.
That is all about potential but what about the current applications in the food we eat now? Here the story was more confused. On the one hand the Woodrow Wilson Centre in Washington has a database of 84 food-related products, including contact materials and supplements that are on the market world wide. On the other hand the Food and Drink Federation told us that there are no current or imminent products made in the UK and only two known uses on the market in the UK. Why this apparent discrepancy? In part, it might be to do with definitions. According to international standards, a particle becomes a nanoparticle if it has dimensions of 100 nanometres or less. If, for example, food contained particles of 120 nanometres, it would not be counted as food containing nanomaterials. But in food manufacturing it is highly likely that there will be a distribution of particle sizes, whatever the manufacturer intended, so a precise cut-off of 100 nanometres may be inappropriate. Whatever the current situation, there is clearly large—perhaps very large— future potential in this sector and several of our recommendations to government are related to capturing this potential here in the UK. We have a strong science base in the area of nanotechnologies, including in relation to food, and it is important to capture that science base in application rather than allow the knowledge to drift overseas for exploitation, as has so often happened in other areas in the past.
A key question at the heart of our report is whether the use of nanotechnologies in food poses potential risks to our health. Some witnesses argued that it might; others were more confident that there is no risk. Our conclusion from the evidence we heard is that, while there is no evidence of a clear and present danger from the use of nanotechnologies in food, there are important gaps in scientific knowledge that need to be filled in order for proper risk assessments to be undertaken. The whole point of using nanotechnologies in food is that they introduce novel properties into materials. Therefore, it is crucial to know how these novel properties affect the human body. While there is a considerable amount of research on the inhalation of nanoparticles and their implications for lung disease, there is far less work on the gut. In fact, we could identify only one research group in this country at the MRC Human Nutrition Research Unit in Cambridge that was active in this field.
We urge the relevant funders—for example, the Medical Research Council and the Food Standards Agency—to build more capacity in the toxicology of ingested nanoparticles as well as carrying out the relevant research to enable proper risk assessments to be undertaken. We recognise that research in this area, as well as regulation, is an international matter. Therefore, whatever research is undertaken in this country should be properly co-ordinated and integrated with research in other countries. But this recommendation of filling the knowledge gaps in relation to risk assessment is one that was made in 2004 in the Royal Society/Royal Academy of Engineering report and we were concerned that not enough had been done to take that forward.
In our consideration of potential risks from nanotechnologies in food, we distinguished between different kinds of nanomaterials. On the one hand, a distinction might be drawn between nanoparticles that occur naturally—I hope I will not alarm your Lordships by informing you that you have been eating nanoparticles all your lives, probably without knowing it—and artificially engineered nanoparticles. On the other hand, there is a distinction between nanoparticles that are rapidly degraded in the digestive tract, whether they are naturally occurring or engineered, and those that persist and therefore may be transported around the body, perhaps even crossing the blood/brain barrier and ending up in the brain. It is these persistent particles that could be more likely to pose a potential risk.
Does the current regulatory regime ensure that food containing nanoparticles is properly scrutinised for safety? The answer we drew from the evidence we took was: in principle yes; in practice not clear. The relevant legislation is European. The general principles of food law require food sold to consumers to be safe. More specific legislation applies safety standards to novel foods, food additives, food supplements, and food contact materials. So there might appear to be a plethora of adequate legislation to protect the consumer, but there is an ambiguity. Let me illustrate. If a food is reformulated to nanoscale certain ingredients—take an ice cream that contains the same kind of ingredients as before but with nanoscaled fat emulsion and therefore less fat—this may be deemed to be a novel food and therefore require prior approval under the novel food regulations. If not, its safety is guaranteed by general food law. However, given that the nanoscaling may itself introduce new properties and therefore new ways of interacting with the body, it would not be enough automatically to assume that, because we had always eaten ice cream, a nanoscaled ice cream would be equally safe.
In the United States we heard from the Food and Drug Administration of its concept of GRAS—generally regarded as safe—which applies to all foods that have been around for a long time and not caused a problem. The question in US terms is whether a food that has been eaten before and is now nanoscaled to produce new properties should generally be regarded as safe or subject to scrutiny under the novel food regulations.
There are two difficulties with this arrangement. The first is a lack of clarity about when a novel nanoscaled food would be considered a novel food under the regulations, because it depends on definitions. The second difficulty, to which I have already alluded, arises under any food legislation, be it for general food, novel foods or the other legislation to which I have referred. It concerns whether the gaps in scientific knowledge would enable the appropriate regulator—at the European level, it is European Food Safety Authority—adequately to assess risks.
Our proposal, based on the evidence we heard, was that, for regulatory purposes, the definition of nanoparticles should focus not on size alone—after all, size is not everything—but also on functionality; that is, how the nanoscaled material interacts with the human body. The key question for risk assessment and therefore for regulation is whether nanoscaling a material changes its properties in such a way as to have a potentially toxic effect on the body. We urge the Government in our report to take forward this matter of definition in Europe.
Finally, I turn to communication and transparency. We were told, both here and in the United States, that the food industry is reluctant to put its head above the parapet on developments of nanotechnology in food. There is apparently a fear that it could be a replay for the food industry of the debacle of GM foods in the 1990s. Your Lordships will recall that the food industry was at that time caught off guard by a combined campaign of certain newspapers and pressure groups and was forced in a rapid volte-face to withdraw GM products from the market, even though there had been and has still never been any identifiable health risk from approved products.
However, our conclusion was that there are a number of strong arguments against the policy of silence. First, by keeping quiet about nanotechnologies, the food industry leaves a communication vacuum into which pressure groups and/or inaccurate media reporting will happily step. Secondly, in contrast to what was said about GM products in the 1990s, there are real potential consumer benefits to be had from nanotechnologies—I have alluded to them—in producing healthier food, reducing waste and perhaps improving quality and flavour. Hence a communication narrative can be positive about developments that may be in the pipeline. Thirdly, silence and secrecy are fuel for the conspiracy theorists. One can just imagine stories that government and the food industry are conspiring to foist on the innocent consumer something that is dangerous and unwanted.
When I met leaders of the food industry recently to discuss our report, they emphasised the importance of a trusted, neutral ring-master to help with public engagement. For their money, the appropriate body is the Food Standards Agency. I hope, returning to an earlier debate in this Chamber, that the Minister will take this opportunity to confirm that newspaper reports of the FSA’s imminent demise are exaggerated. Public trust in food safety has been built by the Food Standards Agency. That would be put at risk if the agency were dismantled.
We did not see, however, an advantage in labelling foods that contain nanomaterials, as we could not see what consumers would do with such information when shopping in the supermarket. Instead, we recommended that the Food Standards Agency should keep a publicly available database of all nanofood products and food-related products.
I summarise my key points. Nanotechnology in food is forecast to be a growth industry. We recommend that the Government work to ensure that the UK is a major player in exploiting this opportunity. The Government should also work with the appropriate funders to ensure that gaps in knowledge for risk assessment are plugged. The Government should work with Brussels to improve the regulatory framework and definitions. There is a need for more openness and public debate, and the Government can play a role in this. While the previous Government accepted many of our 32 recommendations, we await a response from the present Government. I also note that with many of our recommendations, the previous Government, while accepting them in principle, did not actually say that they were going to act on them. I look forward to hearing the Minister’s response later in the debate.
In closing, I should like to put on record my thanks to a number of people. It was a privilege to chair such an excellent Select Committee, the members of which were very hard-working, enthusiastic and thoughtful as well as being delightful to work with. Secondly, the secretariat of the science and technology sub-committee provided subtle steers and excellent guidance and produced a top-quality first draft, which made our task easier in the closing stages. Our specialist adviser, Professor Stephen Holgate of Southampton University Medical School, a major international authority on allergy, kept us on the scientific straight and narrow and provided lucid technical input at key moments. As part of our inquiry, we travelled to Washington DC, where the embassy officials arranged an excellent programme and our US hosts were patient and informative in helping us to understand the position in their country. I beg to move.
The Earl of Selborne
My Lords, the whole House will be grateful to the noble Lord, Lord Krebs. It is not easy to explain just how small a nanoparticle is, but I think he put that into perspective. I am enlightened to know that you can get 300 million nanoparticles on the head of a pin; that is a useful bit of information. Noble Lords will gather that we were very well served by our Chairman; I was very privileged to serve on this sub-committee. The noble Lord, Lord Krebs, with his experience at the Food Standards Agency, could not have been better equipped to undertake the chairing of this really quite complicated but very important subject.
I see this report in a historical context. History, I suppose, is a rather rough description when this science, as noble Lords heard, is very recent, but in 2004, as the noble Lord, Lord Krebs, reminded us, the Royal Society and the Royal Academy of Engineering produced a very helpful report that set out the ground rules for how this new technology might be underpinned by appropriate research. You cannot, after all, regulate a new industry unless you have adequate research and understanding of just what is happening. Later, there was the report from the Council for Science and Technology in 2007, and the Royal Commission on Environmental Pollution in 2008 reported on novel materials. All these reports have been very significant, and there is clearly much expectation in them of nanotechnologies. We dealt only with food, which is a relatively narrow area, but the 2004 report anticipated—correctly, as it turned out, because we are already seeing it—that nanomaterials in a wider context were likely to become commonplace, and recommended that research into health, safety and environmental impacts should keep pace with predicted developments. This research is so important, again as the noble Lord, Lord Krebs, very helpfully pointed out, because, when you start using materials at this scale, they simply do not behave as you would normally expect them to. His example of melting silver with a hairdryer, as opposed to at 960 degrees Celsius normally, demonstrates that you are talking about something that is not as you would expect.
The other conclusion I came to after reading this report was that there is every reason to believe that nanotechnology, provided that health and safety issues can be addressed and quantified, will be put to some extremely helpful uses in the food industry. We are not yet there, but as we have heard already, if you can reduce salt and fats in foods, nanotechnology has obvious advantages. I recognise that ice cream with many times less fat is an extraordinarily marketable commodity; I would certainly be very interested in that. Better packaging and materials, increased shelf life, the reduced use of active ingredients and agrochemicals; it seems to me perfectly reasonable to anticipate these and many other applications.
The 2004 report, which got off to a good start a debate that is beginning to flounder, suggested that,
“the UK Research Councils assemble an interdisciplinary centre … to undertake research into the toxicity, epidemiology, persistence and bioaccumulation of manufactured nanoparticles and nanotubes, to work on exposure pathways and to develop measurement methods”.
The then Government did not adopt this recommendation. They continued to fund research into nanotechnologies through the established channels of grants through Research Councils UK and government departments, usually in response mode but with publicly funded nanotechnologies research co-ordinated through the Nanotechnology Research Coordination Group. When that body started out in November 2005, it published a helpful report that identified 19 research objectives grouped into five areas—we are talking of all nanotechnologies here—one of which was human toxicology.
It is disappointing to find that Defra sponsored a report last year that reviewed how many of these research objectives had been fulfilled by the Nanotechnology Research Coordination Group. The answer, particularly on the issue of human toxicology, is that a substantial amount of work remains to be done. The Defra review states that there have been,
“no systematic studies on the potential of different kinds of nanoparticles to get into the blood, the lymph or the brain”.
Our report comments—rather restrainedly, I think:
“We find this conclusion worrying”.
The Medical Research Council was assigned responsibility for research objective 11, which was to undertake:
“Research to establish a clear understanding of the adsorption of nanoparticles via the lung, skin and gut and their distribution in the body … identifying potential target organs/tissues for toxicity assessment”.
The Defra review concluded that,
“a … largely un-researched area is ingestion as a route of exposure … Given the potential for this route to expose very large numbers of individuals … the lack of activity in this area is surprising”.
This time our report comments:
“We find this lack of progress extremely concerning”.
It is not as if we have not had warnings in the interim. In 2007 the Council for Science and Technology’s report also drew attention to the Government’s slow progress on health and safety research, and said that this was due to an overreliance by government on responsive mode funding rather than directed programmes by government departments to deliver the necessary research. That is logical, is it not? If you wait in responsive mode and there happen to be no research workers applying for research funding in this area, you will not get your gaps filled. You need a bit of direction occasionally. That simply has not happened, which is why there is concern.
I ask my noble friend the Minister not for more money—that would clearly be unreasonable—but simply for the considerable sums of money that are spent on nanotechnology research to be partially reallocated, even in small measure, so that the health and safety issues are adequately addressed. The amount of money that we are talking about is very small compared with the development of these new technologies.
In 2007-08 I chaired a working group of stakeholders charged with drafting a voluntary code on good practice for organisations involved in the supply chain for nanotechnologies. The group included research organisations such as the Royal Society through to retailers, trade unions, consumer groups, and of course companies interested in nanotechnologies. We produced a draft nano code that was accepted with a degree of enthusiasm by all the stakeholders. The repeated mantra in all this was “Transparency, accessibility and accountability”—you cannot repeat it too often. Never hide from the public any shortcomings in the scientific knowledge—there are always some. Never try to persuade the public that the risks are less than might otherwise be thought. Be honest. This is something that the Food Standards Agency got off to a good start with after so many food scares when the regulatory authority was the Ministry of Agriculture, Fisheries and Food.
It is disappointing to find that this fundamental lesson does not appear to have been adopted by the food industry, either here or in America. The noble Lord, Lord Krebs, talked about the food industry not putting its head above the parapet. Somebody has to put their head above the parapet. I understand why the food industry would like a ringmaster—someone to co-ordinate the dialogue—but it is absolutely essential that such a dialogue takes place. It is essential that all stakeholders participate. It would be fine if the Food Standards Agency could be the ringmaster, but my main plea is that this public dialogue should be engaged in quickly.
Baroness O'Neill of Bengarve
My Lords, I, too, was privileged to serve on the Sub-Committee on Nanotechnologies and Food. Not being a scientist, I found it challenging. Being chaired by the noble Lord, Lord Krebs, it was also fun. With the excellent support that we received both from the Clerks and our specialist adviser, Professor Stephen Holgate, I think that I ended up understanding a certain amount about nanotechnology. What I think I understand very clearly is why this is an important topic, and one where the new Government will have reason to take action on various fronts.
The debate takes place at a moment that may be either awkward or advantageous—I am not sure which—but it is at the very least unplanned. The Select Committee’s report on nanotechnology and food addressed a world in which the Food Standards Agency was the UK’s lead body with responsibility for food standards and safety. The Government’s response to the Select Committee’s report is the response of the previous Government, who showed considerable confidence in the Food Standards Agency, which they asked to co-ordinate that response.
It is far from clear that this confidence is shared by the coalition Government. Over recent days there have been numerous reports that the Government plan to abolish or dismember the Food Standards Agency. Headlines have ranged from the Mirror’s rather trenchant:
“Food Standards Agency watchdog is chewed up by ConDems”,
to the Atlantic’s more political—indeed, conspiratorial —revelation:
“How the Food Lobby Killed Britain’s FDA”.
That is of course not a misprint, and it is inaccurate to think that the Food Standards Agency corresponds exactly to the Food and Drug Administration in the US.
Perhaps inevitably, some commentators have begun to wonder whether the Government are unsure which FSA they want to reform and which they want to abolish. We are tonight concerned only with the Food Standards Agency. The Government have indicated that they have not yet reached a decision on what might be done. The Minister confirmed that this afternoon in responding to a Question from the noble Lord, Lord Krebs. However, there is a widespread sense that the Food Standards Agency may be in some danger. The main question—which I hope the noble Earl can answer—is: how far do the Government plan to stand by a response that is not of their making? Which commitments do the new Government seek to shed and which do they seek to strengthen? The coalition Government should welcome many of the committee’s recommendations and endorse much of the previous Government’s response. This was, after all, a report about cutting-edge research, emerging technologies and their application in a domain of daily concern to everyone. It is not an area from which any Government would wish to bow out.
The questions that are raised by the introduction of new technologies—in particular very novel technologies that are not well understood—into food processing link basic and applied scientific research, knowledge transfer, innovation in manufacturing, the fate of a very large part of the British economy and the daily consumption of food by each one of us. The human and economic consequences of getting matters wrong could be large, ranging from failure to adopt food technologies that may be useful for human health, to failure to co-ordinate work on the scientific basis of nanotechnologies, to failure to build on the achievements of UK scientists, to a considerable loss of competitive advantage by the UK food processing industry, not to mention the possibility of failure to adjust regulation to focus accurately on the risk assessment that will be needed.
I am no friend of excessive regulation, and like many who have run a small institution, I know its costs all too well. However, there are cases in which laissez-faire and market solutions will not work. Public health is a public good, often not achievable by the interplay of market forces and consumer choice alone. The long-running battle between the FSA and the food industry over labelling illustrates—if it illustrates nothing else—that there are those in the food industry who prefer to communicate, or at least pretend to communicate, in ways that demonstrably are not understood by many consumers and indeed may not be comprehensible to many consumers. Mere labelling will not be enough to secure public acceptance of food products containing nanoparticles, despite the fact that nanoparticles are found in many naturally occurring products, including traditional foods—and the sub-committee was told that ricotta cheese contains many of them. We need a more thoughtful approach.
I have mentioned some examples of matters that bear on success or failure in the use of nanotechnologies, in particular in the food industry, where, it seems to me, only Government and regulatory action can hope to be effective either in protecting consumers or in supporting the British food industry. First, there is the matter of securing agreement, including international agreement, on definitions. The noble Lord, Lords Krebs, has already mentioned this topic with his great expertise. There are those who seek to define nanoparticles simply in terms of their dimensions. Nanoparticles, they propose, should be defined as particles of which at least one dimension falls below an intrinsically arbitrary threshold of 100 nanometres. However, the reason why some nanoparticles are of interest to the food industry, as they are to other industries, is not simply that they are very small, intriguing as that may be, but that some, though not all, particles at nanoscale have functionally distinctive properties, so may offer nutritional or commercial advantages, though may also require additional risk assessment. Will the Government ensure that the regulatory definition of nanomaterials that must be built into the formulation of any requirements for additional risk assessment is functional and not merely metric? Will they work towards trying to ensure that EU regulation also settles on a functional and not a merely metric definition?
Secondly, there is the matter of ensuring that communication by companies to consumers is adequate. There has been a great deal of emphasis on communication by labelling. But I think that we all know that communication is genuine only where it is actually understood by the relevant audiences—in this case consumers. Transparency by itself is never enough. It is not enough because the fact that information is made available does not ensure that it will be noted, understood or taken into account by relevant audiences. Excessive reliance on consumer choice—when that choice is supposedly informed only by incomprehensible data delivered in the smallest print, on colourful packaging designed to emphasise other, more glorious matters—is not genuine communication. Only government can ensure that food marketing achieves genuine rather than pretended communication with consumers.
There are a number of important audiences for genuine communication in this area. There is the matter of ensuring that communication between companies about research at a precompetitive stage supports, rather than suppresses, the understanding of important information. There is the matter of ensuring that communication by food companies with the wider public is adequate. Possibly the most worrying finding of the sub-committee, alluded to by both previous speakers, is that food companies appear to be secretive about the research that they are conducting. They do not, as far as we could discover, have in place modes of exchanging information on precompetitive matters, and they do not foster public engagement.
The sub-committee was well aware that this secrecy may reflect awareness of the problems created just over a decade ago by a non-UK company when it trumpeted the advantages of its products incorporating the then new technology of genetic modification into plant varieties without adequate communication with, and in particular without listening to, the public. We all know the disaster that resulted for UK and EU plant-breeding companies. We all know that we now live in a bubble in which we pretend that the foods we eat contain nothing that is genetically modified—except of course by traditional methods such as evolution and selective breeding of animals and plants—although non-EU countries have adopted many of the genetically modified crop varieties without harm and to their advantage. But the way to avert another disaster for another British industry is not to be economical with communication about research on products that incorporate engineered particles at the nano scale. What will government do to seek better communication among companies and between companies and the wider public, with a view to fostering an effective and mature discussion of the real issues that need to be addressed if engineered particles at the nano scale are to be incorporated into our food?
Lord Crickhowell
My Lords, I, too, served on the sub-committee, which was admirably chaired by the noble Lord, Lord Krebs. His presentation of the sub-committee’s work was equally admirable, comprehensive and clear, and there is no need for me to do more than emphasise the importance of a small number of our recommendations. At the outset, I should express my appreciation of the contribution made by our Clerk, Anthony Willott, and our advisers, Professor Stephen Holgate and Rachel Newton. We could not have begun to do the job without their wonderful support.
This is the second debate within a couple of weeks on a report of a Select Committee where the Government’s response is that of the previous Government, not the coalition. I will press the points made by the noble Baroness who has just spoken about the need for the Minister, my noble friend who is to wind up this debate, to clarify by how far the present Government agree with their predecessors or indicate if there are significant differences.
I knew absolutely nothing about nanotechnologies until at a Royal Society soirée I visited a presentation on the subject by Cardiff University. When I introduced myself as the university’s former president, I was given some basic tuition and a rather magnificent rule that I am now holding, which helped clarify for me the scale of nanospace. On the left, I see metres, stretching through millimetres, micrometres, nanometres to picometres. As the noble Lord, Lord Krebs, indicated, there is also the atom, and I could add DNA somewhere in what is described as nanospace. I was also shown a picture of a well known Roman goblet which changes colour—an effect apparently caused by natural particles of nano size. In that way, I learnt that nanoparticles may not be the creation of brilliant or, as is sometimes implied, mad scientists, but can be a natural phenomenon. Quite early on in the committee’s study of the subject, we discovered that nanomaterials in food were not entirely a new event. Ricotta cheese has already been mentioned, as has the fact that chocolate and ice cream, as the result of the manufacturing process, usually contain nanomaterial.
However, scientists are now able to manipulate matter at the nano scale—a 1,000 millionth of a metre—so that it can exhibit new and unusual properties. This work may produce real benefits for consumers and manufacturers. We have heard some of them, such as better packaging, so food is fresher and lasts longer, and food with unaltered taste but lower fat, salt and sugar levels. Those are real possibilities. As the noble Lord, Lord Krebs, pointed out, there may be fertilisers that can be applied in smaller quantities—of real advantage to agriculture and the environment. The noble Lord explained that we decided to concentrate on food. Some of us were not entirely happy about this because health products, beauty products, sun creams and so on may all have similar consequences if misused. A number of the recommendations we make will need to be applied in due course to those kinds of materials.
Having accepted the potential benefits, I comment briefly on the possible risks and how we deal with them. We have heard that nanotechnologies may present new risks. They require risk assessment and regulation, and that is not an entirely straightforward process. Like many members of the committee, I was disturbed to hear of the limited amount of research looking at the toxicological impact of nanomaterials, particularly in the gut and, via the gut, into the bloodstream, nervous system and brain. Bluntly, we were not impressed by the evidence we received on the subject from the research councils. There are encouraging words in the previous Government’s response to our recommendations 5 and 6. The research councils’ sign-post notices have been issued, which apparently direct people in the right direction. A grant has been provided by NERC for work at the University of Birmingham. The research councils have carried out an independent evaluation of their nanoscience portfolio—I do not think it is a big portfolio so the evaluation cannot have taken them long. The Health Protection Agency has launched its National Nanotoxicology Research Centre at Chiltern and the Food Standards Agency has commissioned two projects. However, my understanding is that little additional research has been generated by these initiatives at this stage.
We need a clear statement from the Government about what is being done about proactive forms of funding for research and within the EU to ensure that member states effectively co-ordinate their research. My honourable friend David Willetts, giving evidence to the Science and Technology Committee earlier this afternoon, said that in British universities and research institutions there were a large number of small nanoprojects without any effective assessment of whether they added anything to the totality of research. We do not want something like that also happening in the European context, where it may well be that other countries are undertaking serious and valuable work on the subject.
Mention of the EU takes me to our recommendations 17 and 18, which have not been referred to in the debate, on the REACH regulations covering chemicals. I served on an earlier Lords committee on the introduction of REACH. The Government’s response recognises that some aspects of REACH were not designed with nanomaterials in mind. The committee was particularly concerned that the one-tonne threshold for considering the potential toxic effect of substances under the REACH regulations was not appropriate for nanomaterials. I do not get the impression that the necessary revisions are being pursued with adequate urgency. I welcome the fact that, alongside REACH registration, the previous Government announced that they intended to develop a scheme for the collection of information on both nanomaterials and products containing nanomaterials that are available in the UK. As this was described as a bottom-up approach, which I understand is exactly what the coalition Government favour in so many fields, I hope that the Minister will be able to confirm that that activity will be pursued by the new Government.
Finally, I say how strongly we felt—this has been said by other noble Lords—about the importance of the industry being open about what it is doing and positive in its communication with the public. The evidence that we received was depressing. Large firms that should have learnt lessons from the GM disaster, for a variety of reasons, seemed to be continuing down the route that led to the disaster. If they do not trust the public, the public will not trust them. The New Scientist, in May, contained a report that stated that a Unilever spokesperson,
“won't say what nanofoods Unilever is looking into. Two other food multinationals, Kraft and Nestle, declined to talk about their research in the area at all”.
Nothing seems to have changed.
My honourable friend David Willetts, the science Minister who gave evidence earlier today to the Science and Technology Committee, made an interesting observation in his recent speech delivered to the Royal Institution. He was not talking about nanotechnology but synthetic biology. He said:
“The UK Research Councils had the foresight to hold a public dialogue about ramifications of synthetic biology ahead of Craig Venter developing the first cell controlled by synthetic DNA. This dialogue showed that there is conditional public support for synthetic biology. There is great enthusiasm for the possibilities associated with this field, but also fears about controlling it and the potential for misuse”.
Those words could be applied exactly to nanotechnology and the evidence we received from Which? confirmed it. My honourable friend went on to say that he was struck by a comment from a participant in the discussion on synthetic biology who said:
“Why do they want to do it? … Is it because they will be the first person to do it? Is it because they just can't wait? What are they going to gain from it? … The fact that you can take something that’s natural and produce fuel, great—but what is the bad side of it? What else is it going to do?”.
My honourable friend continued:
“Synthetic biology must not go the way of GM. It must retain public trust”.
I would add that nanotechnology must not go the way of GM; it, too, must obtain public trust. I hope that that message will be listened to by those in industry in this country and indeed abroad. If nothing else is achieved by this report but they listen and become more open and transparent, then our work will certainly have been well worth while.
Lord Methuen
My Lords, I thank the noble Lord, Lord Krebs, for initiating this debate and for his excellent chairmanship of the sub-committee. I also thank our secretariat and special adviser for all they did to support us in producing the report.
It was a very interesting inquiry exploring a highly innovative area in which comparatively little research seems to have been carried out. There is a lot going on underground, one might say. We deliberately concentrated on the food industry, excluding areas such as cosmetics and skin protection products.
It was quite obvious that the commercial sensitivity of such research as is being carried out in this field by various firms in the food industry has stifled the exchange of data between the organisations involved. It is to be hoped that the Nanotechnology Knowledge Transfer Network and the Nanotechnology Industries Association will be able to encourage the interchange of such information, particularly in view of the many unknowns in the areas of toxicity and intestinal effects.
As has been said by other noble Lords, the use of nanotechnology in the food and drink industry offers all sorts of exciting possibilities in improving diet, reducing the intake of salt, sugar and other things of that nature, combating obesity, and finding better and longer-term storage options for food due to improved and perhaps intelligent food contact materials and packaging.
The previous Government’s response to our report was generally one of acceptance, and it is to be hoped that this new Administration will similarly accept our recommendations. I note that the Food Standards Agency has been reported as being disbanded but I hope that, as the earlier debate at Question Time indicated, that will not be so. If it is disbanded, I wonder what will happen to the excellent Food and Environment Research Agency near York that gave us so much useful information in its evidence.
One of the key problems in this field of nanotechnology is definition, as has been said by other speakers, and providing an adequate regulatory framework at both domestic and EU levels. The figure of 100 nanometres is often used but there is nothing magic about this number. The definition should be based on a combination of an order of magnitude of less than 1,000 nanometres and the reactivity of the material concerned. It was emphasised to us that the material may be “nano” in only one or more dimensions, depending on whether it is a film, a sheet—for example, food contact material—a particle or even a nanotube.
As I said earlier, the committee was particularly concerned about toxicity issues. I was pleased to note in the government response that both the EPSRC and the MRC are seeking research bids in this area and that the research councils have carried out an independent review of their nanoscience portfolio. One can only hope that the current funding cuts will not result in a diminution of the research effort that is required.
I am still concerned that not enough is known about the impact of nanoparticles in the gut, including the long-term consequences of their ingestion into the body, and on foetal growth. I am glad to see that the Health Protection Agency has launched a National Nanotoxicology Research Centre to undertake studies of what is absorbed through the gut. There needs to be co-ordination with EU initiatives across the whole breadth of this and the research council portfolio to ensure we do not duplicate work being carried out in other member states.
I am also concerned about the impacts on the human food chain due to the possible use of nanoparticles in agriculture, animal feedstuffs, and pesticides and herbicides. Obviously this is an area where Defra is probably more involved than the FSA.
One of the most important issues in front of the committee was the necessity of keeping the public aware of the advent of these developments in food production so as to avoid another publicity fiasco such as occurred with GM crops. There is at present a very low public perception and understanding of nanotechnology as applied to the food people eat. It is essential that manufacturers are open and transparent in the purpose of their research and development aims, and they must bring to the fore the benefits for the public that may be obtained by the use of this technology in food production, packaging and shelf life.
It has been an interesting debate and I hope the Government will be able to support the mostly positive response we had from the previous Administration.
Lord Hunt of Chesterton
My Lords, we should give thanks to the Science and Technology Sub-Committee on Nanotechnologies and Food and to its excellent chairman, the noble Lord, Lord Krebs, who was the most effective and communicative chairman of the Food Standards Agency in its founding. The committee clearly did a good job, as one can see from the previous Government’s response. However, in their response, and that of the current Government, one does not hear many promises about resources. We shall look to hear about that from the Minister.
As other noble Lords have mentioned, the natural world is full of small particles essential for the physical state of the atmosphere, the oceans and the processes in the Earth. But as with smoke, asbestos and traffic, human activities also produce particles ranging down to the scale of molecules and the wavelength of light. As the noble Lord, Lord Crickhowell, said, it is the tiny gold particles in red glass that make it look red—the thesis of my grandfather, by the way.
These nanoparticles are constrained within engineering processes and are more or less under control, but of course they are less constrained as they move through the environment and living tissue. Noble Lords might like to know that probably the first parliamentary study of nanotechnology took place on Clapham Common in 1760, when Benjamin Franklin took a party of six parliamentarians to study how an extremely thin monomolecular layer of oil can damp water waves. This interest was for calming waves in His Majesty’s dockyards at that time—everything was to do with His Majesty’s dockyards—but this continues to be a problem, as we have been seeing more recently.
The potential of nanoparticles is very considerable, from electronics to catalysts and, perhaps most importantly for the whole world, the extraordinary possibility of their use at a molecular or nano level for water purification and desalination. There are some groups working on this in the UK at Aberdeen, and MIT is involved. This is potentially an enormous boon to the poorest communities in the world. Broadly speaking, clean water might come under the category of food—it probably does for these people.
The other important point is for agriculture. Again, as the noble Lord, Lord Crickhowell, said, it is not just that we can use pesticides more efficiently—currently only 20 per cent get into the crop and 80 per cent go down the rivers—but this technology may be a big boon for agriculture.
However, the benefits of this technology have to be balanced with the health and environmental effects, both for the public and for workers. Some workers may have high exposure, and it is very important that this dimension is not forgotten. I notice that there was no actual evidence from the trade unions to this working group, but this is very important. Of course, exposure in industry is a lot better than it used to be. I have never been so drunk in my life as when I worked with ICI and we had trichloroethylene coming out of the plant as we filled up the bolts—one could get very drunk on that. But that is the older kind of industry; now we have much more sophisticated methods.
Public fears can easily be aroused, as we saw with GMOs and asbestos, but public attitudes are based on a delicate balance of perception of advantage and concern about risks. This balance can be influenced by public bodies and collaboration between the political world and scientists working together. Internationally, the UK has often been in the lead in these delicate areas of risk and advantage. The committee addressed all these issues and made sensible institutional and policy recommendations to deal with research, government regulations, industry and international co-operation. However, some of the recommendations have been made before, as we have seen in previous House of Lords reports on science-related issues.
The research on nanoscience and nanotechnology is done largely by industry, research councils, government departments and agencies—some of them using contractors or research institutes—and of course by the EU. This report, as we have seen previously, points to how research councils sponsor research but often, rightly, have limited capability and direction to respond to governmental, societal or industrial needs, as the noble Earl, Lord Selborne, emphasised. That is often not their central objective, which is generally fundamental and open science leading to publication.
In the 1990s, a larger proportion of the science budget was spent by government departments on projects that had direct relevance to policy, and this changed particularly under the emphasis of the noble Lord, Lord Sainsbury. As I know from experience of working on GMO dispersion for a government department, the results were then published. If the government department sponsors work, that does not then lead to non-publication. Although government agencies make use of research councils’ research and data, they cannot direct them, which is the point made in the committee’s report and by other noble Lords.
Another aspect concerns toxicological research and the fact that it needs to be directed—that is at paragraph 4.58. Another advantage of directed and politically sensitive research being funded and directed by government departments is that the public communication and consultation could be done professionally and with political understanding, which is important in this area. The recommendations in the report for public bodies need to be supported, and a positive role is needed to overcome the concerns of scientists who are very cautious. I talked to nanotech scientists, funded by research councils, before the debate, and learnt that they are extremely sensitive about commenting publicly in any way about the applications of their work. So if scientists are to avoid being involved in debacles such as we have seen with GMO and Climategate, they need to find some form and methods of working with government to ensure that they can stick to their fundamentals and publish openly, and that the more tricky, applied aspects are handled more by government and agencies which are familiar with that aspect.
That brings me back to the point that if government departments needed funding or the capacity to do that kind of work, they could apply the openly published science for their own purposes. However, there is a difference in the approach of the United States. There, government agencies fund applications to turn the openly published science into useful products. Remarkably, they will look all around the world for their science, including papers by JCR Hunt. As I know from experience, a government department there will say, “Goodness me, this is an interesting paper. Let’s fund somebody in America to set up a company and do something with it”. That does not happen in the UK. It must therefore be remembered that 90 per cent of the research is done outside the UK. It is not the job of research councils to review the research being done around the world—that should surely be the job of technically able groups in the government departments. The UK Technology Strategy Board has the same aim of developing UK technology, but it requires quite a large financial hurdle, often too large for smaller companies to work.
Another crucial institutional aspect referred to in the report is the co-ordination with research in the European Union. It is strong where there is very strong research, and the EU is leading globally on regulations. Also, EU research is working towards commercial projects and setting up new European-wide standards. Our concern, as has been expressed today, is that even our civil servants and a recent European Commissioner on these Benches have commented privately that the UK does less well than others in taking a strategic view of that EU research and driving research in the direction of the UK's interests in technology. That is essential. As new European programmes have been established for FP8, it is important that we should take a more strategic view. Of course, the research councils could help there.
The other point made is that there is concern that the work being done by our research councils is not co-ordinated with research being done in other national research councils in the rest of Europe. I used to be a chairman of a committee in NERC under the noble Lord, Lord Krebs, and I used to keep badgering colleagues in NERC to find out what was going on in exactly the same area in the other research councils. They did not know their names or their telephone numbers. A lot more can still be done in that respect. It is as if in the United States you had a research policy in California, in Arizona and in Illinois all doing different things and not co-ordinating. We must do better. The European Science Foundation has helped in that regard, but there is a long way to go and the committee has pointed that out.
We look forward to the Government's response. I particularly look forward to their response about public information. I note the comments made by other noble Lords about the fact that some major companies involved in the area are not particularly open. Without naming names, I spoke to the advertising agency for one of the major companies in this area. The advertising agency person told me that their advice to that major company was not under any circumstances to mention the environment or any of their products in that context. That is the situation, and we must move away from it.
Once again I thank the committee for its report, and I look forward to the Government's response.
The Parliamentary Under-Secretary of State, Department of Health (Earl Howe)
My Lords, this has been an extremely useful debate. I congratulate the noble Lord, Lord Krebs, and his fellow committee members on their excellent report.
Nanotechnology is a fascinating new field of science. However, it can also be difficult for the lay person—I include myself in that category—to grasp its implications, given its potentially wide range of applications and the difficulty of visualising what it is and how it works. That makes the committee's achievement all the more impressive. It has sifted through a great deal of written and oral evidence to produce a readable and extremely interesting report—one that, I understand, has already been widely cited as a source of authority.
I followed with great interest all the contributions made during the debate, and I will return to some of the specific points raised in a few moments. Nanotechnologies and nanomaterials are clearly important issues for the Government. As I hope noble Lords will understand, we are still in the process of formulating our detailed policies in this area. As the House may know, the previous Government published a UK nanotechnologies strategy this March. Current Ministers, including me, will carefully consider the degree to which we will continue with that strategy. The report of the Science and Technology Committee makes a number of sound and sensible recommendations. For the reasons that I have just given, it would be premature for me to give a formal response on behalf of the Government on all of them. However, the majority of the recommendations fall within the remit of the Food Standards Agency, whose advice remains unchanged. Indeed, work is already under way within the agency to implement relevant recommendations. I shall say more about that in a moment.
My noble friend Lord Selborne speculated about the glittering prizes that may be attained in the future from this technology. The Government keep an open mind about the likely benefits of the use of nanotechnologies and nanomaterials in food. Proponents, as we have heard, point to a range of potential benefits such as improved packaging, better delivery of vitamins, lower-fat foods that have improved taste and texture, and reductions in food spoilage and food-borne disease. While all this sounds promising, the products themselves are very much at the research and development stage, and it remains to be seen how many will actually bear fruit commercially. However, many noble Lords have pointed out that what is clear, and what history tells us, is that unless consumers have full confidence in the safety of the end products, the benefits from innovation will be lost. This requires a combination of informed consumers and an appropriate, proportionate and fully transparent system of regulation.
The report addresses the need for better communication with the public about nanotechnologies in food. Members of the public rightly expect to have access to accurate and balanced information about issues that affect them and their families. This is particularly the case in relation to food, and the Food Standards Agency will work to ensure that information about nanotechnologies is made available in easily accessible ways.
The committee emphasised the importance of transparency. Of course the Government must play their part, but industry must also be open about the nanotechnology-enabled products that are being developed and used. The noble Lord, Lord Krebs, was absolutely right to point out that we know from previous experience with genetically modified foods that innovation cannot be forced on an unwilling or sceptical public. It is therefore in everyone’s interest to promote consumer confidence. This is particularly the case if, as some claim, nanotechnologies can help to tackle major challenges such as healthy eating and waste reduction.
The noble Lord, Lord Krebs, asked what the Government would do to ensure that the food industry is more transparent about its research on nanotechnologies, a question that was echoed by my noble friend Lord Selborne. The Food Standards Agency will work with industry and other stakeholders to ensure that as much information as possible is shared. That will be done, for example, by setting up a nanofoods stakeholder group and through a public list of products containing nanomaterials. Where I hesitate is over the committee’s recommendation of a mandatory reporting system for food products that are under development. As I have indicated, the Government have not agreed their detailed strategy on nanotechnology in general, or on the fine detail of the committee’s recommendations, but I could not but be struck by the arguments advanced by the Food Standards Agency in the previous Government’s response to the report: namely, that mandatory reporting could be counterproductive as it could well have the effect of driving research out of the UK, making it even more difficult to keep abreast of developments. There could be other and less dirigiste ways of achieving the committee’s aims in this area.
In answer to the direct question posed by the noble Lord, Lord Krebs, the noble Baroness, Lady O’Neill, and my noble friend Lord Methuen, I can only repeat what I said earlier in the day about the Food Standards Agency. A robust regulatory function will continue to be delivered through the agency. The Government fully recognise the important role that the agency plays, but we are examining whether some—I emphasise the word “some”—of the functions of the FSA could more sensibly and cost-effectively sit elsewhere. But again, as I indicated earlier, no decisions about that have been taken.
There is a need to co-ordinate and collect information, and I can tell my noble friend Lord Crickhowell that the Food Standards Agency is in the process of setting up a nanofoods stakeholder group, as recommended by the Select Committee, and will consult this group before establishing a register of foods that are currently being manufactured with the use of nanotechnologies later this year.
My noble friend asked about REACH. As far as I am aware, there is no further news to report. However, I will gladly ensure that he is kept informed of any developments.
Food products in the UK must meet the highest safety standards. As the committee concludes, different nanotechnologies raise different questions and so evaluation needs to be conducted on a case-by-case basis. For example, low fat mayonnaise made with a nanoemulsion of oil and water requires a different approach from insoluble nanoparticles of silver in a food supplement or embedded in food packaging.
The existing regulatory system for food ingredients provides a good level of control over new nanomaterials. The legislation will evolve, as it should, and I can say to the noble Lord, Lord Krebs, that the committee’s recommendations about clarifying the legal position of nanomaterials and drawing up appropriate definitions will be taken forward in the relevant fora in Brussels. The aim must be to provide clarity and safeguards against the introduction of new or altered food ingredients that have not undergone an independent safety assessment. This is important. In fact it has already happened in the area of food additives, and other revisions are under way in novel foods and food contact materials.
The noble Baroness, Lady O’ Neill, urged the Government to ensure that regulation should be based on functionality and not only on size. The point is well made and the Government will take it fully into account in our discussions in Brussels. In fact, recent changes to legislation on food additives are not tied to a particular size threshold but to changes in properties due to any change in particle size.
The committee’s report is one of several that highlight the gaps in our knowledge of nanomaterials. There is clearly a need to fill these gaps in order to assess and manage any potential risks effectively. We need to be able to ask the right questions and to draw the right conclusions from the data. The work that is currently under way, with funding from government departments and the research councils, will help to fill these gaps. In that context it is important to note that the various funding bodies do not operate in isolation but collaborate whenever possible. They also form part of a cross-government nanotechnologies research strategy group. This group has recently updated its list of research priorities, which will help to direct research funds in an effective way.
The noble Lord, Lord Krebs, asked specifically about the committee’s concerns relating to the proposed definition of engineered nanomaterial in the amended novel foods regulation proposal. I have touched on this already but I should add that the proposal for an updated EU regulation on novel foods is still under discussion. If a definition is adopted, then the Food Standards Agency will work with the Commission and other member states in monitoring and updating the definition to take account of technical advances and to reflect any international developments.
On the issue of risk assessment, the European Food Safety Authority is producing a guidance document for risk assessment of nanomaterials which will provide practical recommendations on how to assess applications made by industry for the use of engineered nanomaterials. This would apply to food additives, enzymes, flavourings, food contact materials, novel foods, food supplements, feed additives and pesticides. A first draft is due to be completed by July 2010 and will be subject to public consultation before it is finalised.
The noble Lord, Lord Krebs, mentioned that two products are known to be on the UK market. This was true in 2009 but I understand that one product became outlawed in January this year with changes to the law on food supplements.
My noble friends Lord Crickhowell and Lord Selborne questioned whether the research councils were sufficiently proactive in tackling the knowledge gaps in relation to the safety of nanomaterials. The relevant research councils have all taken measures to stimulate research into the safety of nanomaterials. A number of projects have been funded in recent years and these efforts are being intensified. For example, a programme on environmental exposures and human health has been launched jointly by the MRC and the Natural Environment Research Council working with the Department for Health and Defra. The programme specifically highlights nano-scale materials as an area of interest. It will fund four to six strategic collaborative consortiums to a value of £8 million to £10 million. The research proposals are currently under review and it is anticipated that the grants will be awarded in August 2010.
My noble friend Lord Selborne emphasised the importance of better research co-ordination to address gaps in knowledge and, as I have indicated, the cross-government research group has recently updated its priorities for nanotechnology research. A list of priorities was published after the committee report in March 2010 and provides a new focus for publicly funded research to fill the gaps that we fully acknowledge.
My noble friend Lord Crickhowell asked about progress on international collaboration of research. Government officials continue to work with the OECD programme on the safety of manufactured nanomaterials and I am informed that the underpinning research that has been commissioned with the help of the research councils is progressing well. At EU level the Technology Strategy Board is exploring further interactions with EU counterparts through involvement in a new research network focusing on the safe implementation of innovative nanotechnologies.
We have had a most valuable and constructive debate and I will take away the many points made. In conclusion, I emphasise the Government’s commitment to fostering a responsible attitude towards innovation and in creating the space for new developments, such as nanotechnologies, while ensuring the right level of regulatory oversight. Many have spoken of the importance of transparency. There is much that the Government can do to help the UK to benefit from innovation but none of this will matter if the public are not properly informed or are suspicious of the motives of those who seek to market new and innovative products. That underlines the critical role of transparency if the benefits of nanotechnology are to be realised. The Government, industry and the research community must all play their part.
Lord Krebs
My Lords, I thank the Minister for his response and other noble Lords who have taken part in this excellent debate. I do not propose to delay us for long but simply wish to note the positive response from the Minister, recognising that the coalition is still formulating its policy in certain areas. As it becomes clearer and the recommendations in our report are considered more extensively, I hope that I can remain in touch with the Minister and understand the full set of responses.
I note briefly a few points. I was very pleased to hear the Minister confirm a continuing role for the Food Standards Agency, that the regulatory issues that we addressed in Brussels are being taken forward, and that the activities of the research councils in commissioning research in this area seem to be moving ahead. The Minister also indicated the Government’s recognition of the importance of communication and he mentioned that the food industry sees its work at a very early R&D stage. In our opinion in the sub-committee, that was precisely the stage at which communication should start. If we wait until products are about to come on to the shelves it is too late. We are pleased to hear that the dialogue is being initiated under the aegis of the Food Standards Agency.
I thank noble Lords once again for contributions to the debate.