Early in the development of nanobiotechnology, the Canada-based Action Group on Erosion, Technology and Concentration (ETC Group) published a report in January 2003 on the convergence between nanotechnology and bio- technology in general13 and a second specifically on applications of nano- technology in agriculture and food in November 2004.14 One environmental NGO in particular, Greenpeace UK, also took an early interest in nano- technology and in 2005 carried out NanoJury UK, which brought together 15 people from different backgrounds in the north-east of England in a dialogue intended to have an impact on policy.15It stated that:
Greenpeace does not have a stance on nanotechnology as a whole, because the applications will be too diverse, including information technology, pharmaceuticals, defence and energy. The first applications of nano- technology look to be in making faster computers and helping doctors with better diagnostic tests.
There may be some very beneficial uses of nanotechnology if it is directed towards, for example, a genuinely clean energy system with the prospect of very efficient lighting, cleaner manufacturing processes and cheap, efficient solar cells. However, these are some years from deployment, so whether they
happen or not depends on a host of decisions about research and develop- ment funding now and over the next few years.
Greenpeace has concerns about the use of ‘nanoparticles’ – very tiny par- ticles which are so small that their chemical and biochemical properties will be different from the familiar bulk solids, and may be hazardous to human health and the environment. We want to see a moratorium on the release of nanoparticles to the environment until evidence that it is safe (for the environment and human health) is clear. In the longer term nanotechnology could produce self-replicating ‘machines’ whose proliferation could be environmentally problematic.16
Friends of the Earth’s nanotechnology project ‘aims to catalyse debate on what is set to be one of the defining issues of our time’.17 In May 2006 it published its report ‘Nanomaterials, Sunscreens and Cosmetics: Small Ingre- dients Big Risks’18commencing with:
In one of the most dramatic failures of regulation since the introduction of asbestos, corporations around the world are rapidly introducing thousands of tons of nanomaterials into the environment and into the faces and hands of millions of people, despite the growing body of evidence indicating that nanomaterials can be toxic to humans and the environment.
Friends of the Earth believes that there are at least several hundred cos- metics, sunscreens and personal care products which contain engineered nanomaterials that are commercially available right now.
Our research demonstrates that nanoparticles have entered just about every personal care product on the market, including deodorant, soap, toothpaste, shampoo, hair conditioner, sun screen, anti-wrinkle cream, moisturiser, foundation, face powder, lipstick, blush, eye shadow, nail polish, perfume and after-shave lotion.
In a report published on 11 March 2008,19 Friends of the Earth argued that it had identified at least 104 food and agricultural products either con- taining untested and potentially hazardous manufactured nanomaterials, or manufactured using nanotechnology, and that the real number of products is much higher ‘given that many food manufacturers may be unwilling to advertise the nanomaterial content of their products’. It called on European policymakers to adopt comprehensive and precautionary legisla- tion to manage the risks raised by the use of nanotechnology and also called for:
. . . a moratorium on the further commercial release of food products, food packaging, food contact materials and agrochemicals that contain manu- factured nanomaterials until nanotechnology-specific regulation is intro- duced to protect the public, workers and the environment from their risks, and until the public is involved in decision making.
43 Public Perceptions of Nanotechnologies: Lessons from GM Foods
As of January 2008 the Soil Association, an influential organic food move- ment organisation in the UK, with Prince Charles as its patron, banned the use of man-made nanomaterials from all its certified organic products, saying in its press release:
This applies particularly to health and beauty products, but also to food and textiles. Ahead of the Government, we are the first organisation in the world to take action against this hazardous, potentially toxic technology that poses a serious new threat to human health.
Whilst the Soil Association recognises there may be benefits from nano- technology – it has the potential to radically, and positively, transform many sectors of industry including medicine (e.g. delivering drugs that target specific cells) and for renewable energy such as fuel and solar power. Yet, of the $9 billion per year being invested globally in nanotechnology, much is going to the development of cosmetics and health products. Many well- known companies such as L’Oreal, Unilever, Boots and Lancome are already developing and introducing these super fine particles into their products and none of these products are required to have labelling to warn consumers.20
Indicatively, the Soil Association’s press release sets out its answers to the question:
Is nanotechnology like GM?
There are many parallels with GM in the way nanotechnology is developing. As with GM:
Commercial opportunities have run ahead of scientific understanding and regulatory control. The risks of nanotechnology are still largely unknown, untested and unpredictable.
The industry is trying to win over Government backing with compelling claims about the benefits of the technology and win over consumers by promoting individual products, whilst neglecting the fundamental issues of safety.
Initial studies show some negative effects and there is a list of potential health impacts that have yet to be investigated by scientists.
Regulators have not reacted to the scientific evidence of health effects for products that are already commercialised (titanium dioxide nano- particles), instead accepting industry reassurances and unpublished industry evidence.
The standard of proof is being set very high for any concerns, but low for reasons to dismiss concerns and without the context of a body of estab- lished scientific knowledge to judge conflicting arguments.
Concerns are being downplayed on the basis of absence of any consensus over health problems and with arguments that some nanoparticles occur in nature or have been produced by industry for some time (true, but not
on the scale and with the chemical range being developed now; anyway, health concerns exist for some of these such as air pollution).
What is worse than GM is that there is no official assessment process or labelling of the products, and nano substances are being rapidly introduced to the market. This is a very bad starting point for the responsible introduction of a powerful new technology.
In a recent horizon-scanning exercise in the UK, 35 representatives from organisations involved in environmental policy, academia, scientific journalism and horizon scanning were asked to use wide consultation to identify the future novel or step changes in threats to, and opportunities for, biodiversity that might arise in the UK up to 2050, but that had not been important in the recent past. At least 452 people were consulted.21 The Journal of Ecology article reporting the findings stated, inter alia, in relation to nanotechnology:
Benefits to biodiversity might arise from reductions in pollution and reduced bioavailability of chemicals following binding to nanoparticles. Challenges ahead include nanostructures, or their debris, that mimic functions found in cells (e.g. electron transport). Here, effects at surfaces or pores central to functioning in biological and environmental systems may be most important. If use becomes widespread or the structures are incorporated into ‘near- living’ systems, new approaches to risk will be needed.