Paris Reclaims Public Water

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WaterCommon Resources

Paris Reclaims Water

In June 2009, the Paris City Council announced that the city’s water system would revert to public control at the end of 2009, after a century of private control. Paris is one of more than 40 French municipalities and urban communities that reclaimed public control of their water systems over the last decade to reduce prices and improve services.

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Climate Change: It’s What’s for Dinner

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FoodCommon Resources

What you put on your plate matters

We all know that driving a gas-guzzling SUV contributes to climate change,but did you know that what you put on your plate could too? Here’s how your food choices affect climate change and what you, as a consumer, can do about it.

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Biotech Diplomacy

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Food

Injecting the Corn to Create GMOsWhen you think of an embassy, you might think of diplomats dining with world leaders and consulate staffers assisting travelers who have lost their passports. Lately, however, ambassadors representing the United States have been carrying out a less traditional sort of mission in the European Union: promoting the interests of biotechnology companies and the genetically modified products they are attempting to sell around the world.

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rBGH: Anything but Green

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Food

The dairy industry has followed the same path as much of agriculture: Produce as much as possible and do it cheaply, all in the name of increasing profitability. Like those who are, for example, growing grain or raising chickens, dairy farmers are responding to the increasing power of agribusiness and farmer-unfriendly federal policies by getting bigger or getting out.

One of the many factors contributing to factory-scale dairy operations is recombinant Bovine Growth Hormone (rBGH or also sometimes called rBST), an artificial growth hormone developed by Monsanto to increase dairy cows’ milk output.

Industrial agriculture proponents proclaim that farming on a large scale, and using technology such as rBGH, brings many benefits to farmers. Lately, a healthier environment has been their prime example of these supposed benefits. One outspoken advocate of industrial dairy production recently wrote that the genetically engineered hormone is good for the environment because dairy cows injected with it “eat less feed for each gallon of milk they produce” and this means that less land is used for cows given the artificial hormone. “Less land plowed, less fertilizer, less of all of the inputs that go into producing the dairy products consumers enjoy.” Going even further, he says, those cows on rBGH help cut down on greenhouse gases.

Are rBGH Cows More Efficient?

Is it true? Do cows injected with rBGH really eat less feed while producing more milk? The Food & Drug Administration says no.

Years ago, when rBGH was being approved for use, Monsanto wanted to make a label claim that it increased both feed efficiency and milk production. This is exactly what proponents of rBGH are saying now, that cows treated with the artificial hormone eat the same amount of feed while producing more milk. But when agency approval came in 1993, the label claim for increased feed efficiency was not allowed because Monsanto could not produce enough data to convince FDA of their claims.
So FDA approved the use of rBGH for increasing the amount of milk per cow, but didnt buy the claim that those cows are necessarily more efficient users of feed. But there’s still another question to ask: Is the amount of milk per cow all that matters? To answer that one, we need to look at which cows are getting treated with rBGH.

An Environmental Reality Check

So who‚ using these artificial hormones? While rBGH is used in only about 17 percent of all U.S. dairy cows, factory farm operators inject it into 42 percent of large herds (500 animals or more). Indeed, big dairy farms are the primary users of the artificial hormone. Nationally, fewer than 10 percent of small dairy farms (those with fewer than 100 cows) used rBGH in 2007.

To understand what this distribution of rBGH use means, perhaps we should step back and look at the overall bleak picture of modern dairy production. Instead of wandering around eating grass in pastures, as cows are built to do, the majority of them are now concentrated in factory farms where they eat grain that takes lots of land and energy to grow and transport. The process of planting and harvesting and transporting all that corn pollutes our soil and water with agro-chemical waste – about 10 billion pounds a year of nitrogen fertilizer alone is dumped onto fields – and releases carbon dioxide emissions into our atmosphere, where it assists with climate change.

So does it really decrease land use and help address climate change to cram together all those cows – many of them on rBGH – and feed them shipped in grains?

How – and where – cows are raised matters. While the United States lost 94,000 dairy cows over the last decade, their number increased dramatically – by half a million – in the biggest dairy states. Meanwhile, smaller, sustainable family dairy farms are going away, their numbers having fallen by 39 percent over the last decade. Larger, unsustainable factory dairies have replaced them. Between 1987 and 2002, the average size dairy herd more than tripled, going from 80 to 275 cows.

In California from 1997 to 2007, the number of dairy cows increased by 30 percent, from 1.39 million to 1.81 million. Those 422,000 additional cows consumed 44 million more bushels of corn in 2007 than the state’s dairy herd ate a decade earlier. An additional 293,000 acres of corn were required to feed those new dairy cows in 2007.

And in Idaho, which is considered new to the production of milk on a large scale, the number of dairy cows in the state skyrocketed from 272,000 in 1997 to 513,000 in 2007, an increase of 88.6 percent. Those 241,000 additional cows ate about 25 million more bushels of corn. Growing that corn required 167,000 acres of land.

California and Idaho dont produce enough corn to supply the rising demand from factory farms, so much of that extra corn has to be shipped from thousands of miles away, using energy and contributing to climate change.

More cows eat more feed that is grown on more land. That strikes us as neither efficient, nor environmentally friendly. And what about all the manure?

Storing millions of gallons of factory farm generated manure and other waste in one place emits dust particles and hundreds of different volatile gases, including ammonia, carbon dioxide and methane. In fact, one 2,500-cow dairy produces as much waste as a city with 400,000 residents. So perhaps it was no surprise to hear California‚ San Joaquin Valley Air Pollution District‚ 2005 announcement that the region‚ more than two million dairy cows bore more responsibility for air emission of volatile organic compounds than cars, trucks or pesticides.

And for one more opinion on whether rBGH is better for the environment, we can turn once again to the FDA. In a 1993 environmental impact statement, the agency noted that analysis of the impact of rBGH use on greenhouse gas emissions found that emissions would either increase slightly or decrease slightly, but that “the magnitude of the changes will be extremely small and insignificant compared to total worldwide emissions of carbon dioxide and methane.”

Bad for Business

Ironically, given the aims of industrial agriculture, the profitability of using the drug is questionable. It has produced a very mixed bag – some farmers seem to make money with rBGH, but others don’t. Plus, the variability is high, depending on the price of milk, feed and other factors. While farmers who put their cows on rBGH may see a 10 percent increase in milk production, they also have increased expenses, including corn feed that has become more expensive, the $6.50 per injection cost of the hormone (not including the labor charge to administer it) and the possibility of more bills from the veterinarian to deal with bovine health ills stemming from rBGH. Additionally, some dairy farmers report that cows treated with rBGH burn out faster and have to be sent to slaughter and replaced.

In all this talk about increasing milk production, perhaps we should pay heed to a very basic financial reality: Increasing the supply of milk reduces the price that dairy farmers receive for it. That financial reality drives many out of business and forces the remaining producers to adopt the bigger-is-better model, fraught with the questionable technology that comes along for the ride.

All that said, recombinant Bovine Growth Hormone affects more than the environment and dairy economics.

Lingering Health Questions

This artificial hormone’s history is just a bit shady. While the U.S. Food and Drug Administration approved rBGH in 1993, based solely on an unpublished study submitted by Monsanto, the governments of Canada, Australia, New Zealand, Japan and the European Union have never allowed it to be used.

The possible health implications of rBGH for humans and cows are significant. The milk from cows injected with rBGH has higher levels of another hormone called insulin growth factor-1 (IGF-1). Elevated levels of IGF-1 in humans have been linked to colon and breast cancer. Some researchers believe there may be an association between the increase in twin births over the past 30 years and elevated levels of IGF-1 in humans.

And rBGH use has increased bacterial udder infections in cows by 25 percent, adding to the need for antibiotics to treat the infections, a worrisome trend in light of the growing problem of antibiotic resistance.

The Bottom Line

Pumping rBGH into cows to increase milk production has not led to fewer cows producing more milk. Instead, it has become a tool for keeping more cows in fewer places where they gobble up more grain grown unsustainably on more acreage. In short, rBGH has contributed to the growth of mega-dairy operations that cram together thousands of cows generating mountains of waste that are toxic to us and to our environment. In addition, rBGH causes numerous human and bovine health issues, including bacterial resistance to antibiotics and more frequent bovine udder infections.

What You Can Do About It:

Consumers should purchase dairy products that are labeled “rBGH-free,” “rBST-free,” or “organic.” Problem is, some states are trying to prevent dairies from labeling their products with this information.

  • Download the fact sheet: How to Go rBGH-Free

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rBGH: What the Research Shows

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Food

rBGH_Health thumbnail

[pdflink file=”rBGH_Health.pdf”]

Although Canada and the European Union have banned the use of bovine recombinant growth hormone in dairy cows due to its health risks for both humans and cows, the Food and Drug Administration has dismissed evidence for these risks in order to approve the use of rBGH. The following is a sampling of research, funded by government agencies and major universities – that raises serious concerns about the safety of rBGH/rBST and challenges FDA approval of the use of this hormone. Please note that in some studies rBGH also is referred to as bovine somatotropin, or rBST.

Human Health

rBGH and Human Health Problems Resulting from Mastitis (I)

Based on the proposed label supplied by Monsanto, the increased risk of mastitis [inflammation of the udder] that may be associated with rBST has human health implications (antibiotic resistance in farm-borne human pathogens)

“BST-induced mastitis is harder to treat than naturally occurring mastitis and duration of treatment is longer due to higher incidence of infection with S. aureus… There is a one third higher incidence of antibiotic resistant bacteria. BST use increases the amounts of drugs in general to treat the various adverse effects it causes in cattle.”

rBST (NUTRILAC) Gaps Analysis Report.” Report of the rBST Internal Review Team, Health Protection Branch, Health Canada.. April 21, 1998.

rBGH and Human Health Problems Resulting from Mastitis (II)

“The public health and food safety aspects of mastitis in dairy cows are exclusively associated with the potential problems of side effects from using antimicrobials in the treatment or prevention of such cases. Treatment of clinical mastitis cases with antimicrobials is not limited to those cases, which may be classified as severe…, also, milk clinical cases are often treated with local application of antimicrobials… Even cases of sub-clinical mastitis are sometimes treated with antimicro-bials…”

“The public health reasons for limiting as far as possible the use of antimicrobials in dairy cows are the risk of: an in-creased incidence of allergic reactions from drugs and their metabolites in consumers of milk and dairy products; an in-creased selection of bacteria resistant to antimicrobials.”

“European Commission. ‚Report on Public Health Aspects of the Use of Bovine Somatotrophin.” 15-16 March 1999. Food Safety – From the Farm to the Fork.

rBGH and IGF-1 (I)

milk truck“Six lactating, non-pregnant Jersey cows were given subcutaneous [below the skin] injections of recombinantly derived bovine growth hormone (rBGH) for seven days Concentrations of [a growth hormone called] insulin-like growth factor (IGF-1) in the milk increased from 0.44 +/- 0.04 (mean +/- s.e.m.) during the seven days preceding treatment to 1.6 +/- 0.2 nmol/l on day seven of treatment. Taking the increase in milk yield into account, the total increase in the secretion of IGF-1 into milk of one udder half was 6-fold.”

Prosser, C. G., Fleet I. R., A. N. Corps. “Increased secretion of insulin-like growth factor 1 into milk of cows treated with recombinantly derived bovine growth hormone.” Journal of Dairy Research 56(1):17-26, 1989.

rBGH and IGF-1 (II)

The increased secretion of IGF-I into milk during rBGH treatment is of further relevance in view of the proposed com-mercial use of this compound in the dairy industry. Bovine IGF-I has an identical amino acid sequence to human IGF-I and would therefore be active in humans.

“Application of rBST increased the amount of excreted IGF-I in milk by 25-70% in individual animals. The Committee noted that bovine milk may contain truncated IGF-I (des(1-3)IGF-1), which was found to be even more potent than IGF-1 in the anabolic response when given subcutaneously to rats.”

European Commission. “Report on Public Health Aspects of the Use of Bovine Somatotrophin.” Food Safety – From the Farm to the Fork. March 15-16, 1999.

IGF-1 and Cancer

“The role of IGFs in cancer is supported by epidemiological studies, which have found that high levels of circulating IGF-I and low levels of IGFBP-3 are associated with increased risk of several common cancers, including those of the prostate, breast, colorectum, and the lung.”

Yu, Herbert and Thomas Rohan. Review. “Role of the Insulin-like Growth Factor Family in Cancer Development and Progression.” Journal of the National Cancer Institute 92:1472-89, 2000.

rBGH, IGF-I, and Gastrointestinal Cancer

“The combination of IGF-1 in BST-milk and IGF-1 normally secreted into the human gastrointestinal lumen would aug-ment intraluminal concentrations of this hormone, increasing the possibility of local mitogenic effects [factors that cause cell division to commence] on gut tissues.”

Challacombe, D. N., and Wheeler, E. E. “Safety of milk from cows treated with bovine somatotropin.” Lancet 344:815-816, 1994.

IGF-I and Breast Cancer in Premenopausal Women

“We evaluated the association of plasma IGF-I and IGF binding protein-3 with risk of breast cancer in a study of 94 cases of premenopausal ductal carcinoma in situ and 76 controls. Compared with women in the lowest tertile [quarter] of IGF-I, women in the upper two tertiles of IGF-I had an elevated risk for ductal carcinoma in situ.”

Bohlke, Kari, Daniel W. Cramer, Dimitrios Trichopoulos, and Christos S. Mantzoros. “Insulin-Like Growth Factor-I in Relation to Premenopausal Ductal Carcinoma in Situ of the Breast.” Epidemiology 9(5):570-573. 1998.

IGF-I and Prostate Cancer

“IGF-I is a mitogen [factor encouraging cell division] for prostate epithelial cells. To investigate associations between plasma IGF levels and prostate cancer risk, a nested case-control study within the Physicians Health Study was conducted on prospectively collected plasma from 152 cases and 152 controls. A strong positive association was observed between IGF-I levels and prostate cancer risk.”

Chan, June M, Meir J Stampfer, Edward Giovannucci, Peter H. Gann, Jing Ma, Peter Wilkinson, Charles H. Henne-kens, and Michael Pollak. “Plasma Insulin-Like Growth Factor-I and Prostate Cancer Risk: A Prospective Study.” Sci-ence 279(5350):563-566. 1998.

IGF-I and Bovine Spongiform Encephalopathy (Mad Cow Disease)

“It is speculated that IGF-I plays a role in the expression of genes that encode for prion [the infectious agent believed to cause BSE] synthesis and that increased IGF-I shortens the incubation period formilk bottle Bovine Spongiform Encephalopathy (BSE) [commonly referred to as Mad Cow Disease]. Thus, the use of BST might increase the risk of exposure to BSE infection.”

“rBST (NUTRILAC) Gaps Analysis Report.” Report of the rBST Internal Review Team, Health Protection Branch, Health Canada. April 21, 1998.

IGF-I‚ Resistance to Pasteurization

“IGF-I in milk is resistant to pasteurization and even elevated levels of IGF-I have been reported after pasteurization. The latter might be related to the standard analytical procedures, which fail to detect protein-bound (IGFBP-bound) IGF-I. Consequently, consumption of milk from rBST treated dairy cows will increase the daily intake of IGF-I.”

European Commission. “Report on Public Health Aspects of the Use of Bovine Somatotrophin.” Food Safety , From Farm to the Fork. 15-16 March 1999.

IGF‚ Carcinogenic Effects on Rodents (II)

“When exposed to insulin-like growth factor 1 or supraphysiologic [higher than normal] levels of insulin, NIH 3T3 cells that expressed high levels of receptors formed aggregates in tissue culture dishes, colonies in soft agar, and tumors in nude mice… The results demonstrate that when amplified, this ubiquitous growth factor receptor behaves like an oncogenic [cancer causing] protein and is capable of promoting neoplastic [uncontrollable cell] growth in vivo.”

Kaleko, Michael, William J. Rutner, and A. Dusty Miller. “Overexpression of the Human Insulinlike Growth Factor I Receptor Promotes Ligand-Dependent Neoplastic Transformation.” Molecular and Cellular Biology. 10(2):464-473. 1990

rBGH and Unstudied Human Health Problems

The following questions deserve attention:

  • Does the IGF-1 molecule remain in the gastrointestinal tract of humans (when products from rBST-treated animals have been consumed)?
  • Based on the biological activity of IGF-1 activity as cellular growth factor and assuming that IGF-1 is not immediately destroyed in the gastrointestinal tract, what is the consequence of the direct exposure of the gut mucosa?
  • What evidence can be provided that orally ingested IGF-1 enters systemic circulation and what are the possible conse-quences of this systemic bioavailability?

“Several reports express concerns about undesirable allergic reactions which might occur after the consumption of milk obtained from rBST-treated cows… the question of whether or not a change in milk protein composition as a consequence of rBST application to the dairy cows might pose an additional risk factor in the development of food allergies has so far not been addressed adequately.”

European Commission. “Report on Public Health Aspects of the Use of Bovine Somatotrophin.” Food Safety , From Farm to the Fork. 15-16 March 1999.

“Evidence from the subchronic rat study submitted by Monsanto had shown that rBST was absorbed intact from the GI tract following oral administration, albeit at high doses, and elicited a primary antigenic response. The full immunological and potentially toxicological consequences of this observation were not investigated.”

“rBST (NUTRILAC) Gaps Analysis Report.” Report of the rBST Internal Review Team, Health Protection Branch, Health Canada.  April 21, 1998.

Animal Welfare

rBGH and Animal Welfare

“Any exogenous treatment that modifies the physiology of an organism with the objective of increasing its productivity is likely to impair welfare if the individual is not able to adapt to the physiological and metabolic changes this treatment in-duces.”

European Commission. “Report on Public Health Aspects of the Use of Bovine Somatotrophin.” Food Safety , From Farm to the Fork. March 15-16, 1999.

rBGH and Animal Welfare: Mastitis

mechanical cow milkingMilk production, feed efficiency, health, and reproduction were evaluated in 46 Jersey cows that received either 500 mg of sometribove (n-methionyl bST) in a prolonged-release formulation or an equivalent volume of excipient biweekly be-ginning at 60 +/- 3 DIM

“During the pretreatment period, only one quarter in a control cow required antibiotic treatment, whereas 11 quarters in cows later assigned to the treatment group received antibiotic therapy. When the number of new cases of mastitis during the treatment period were examined, the control cows had 4 cases, and the treated cows had 29 cases.”

Pell, A. N., D. S. Tsang, B. A. Howlett, M. T. Huyler, V. K. Meserole, W. A. Samuelss, G. F. Hartnell, and R. L. Hintz. “Effects of Prolonged-Release Formulation of Sometribove (n-Methionyl Bovine Somatotropin) on Jersey Cows.” Jour-nal of Dairy Science. 75:3416-3431, 1992.

rBGH and Animal Welfare: Reproductive Side-effects (I)

“There is evidence that BST treatment can adversely affect reproduction. Pregnancy rate dropped from 82 to 73% in mul-tiparous cows and from 90 to 63% in primiparous cows… The frequency of multiple births, which can cause welfare prob-lems, was substantially increased by BST. Failure to conceive is an indicator of poor welfare and multiple births lead to poor welfare.”

“Report on Animal Welfare Aspects of the Use of Bovine Somatotrophin.” Report of the Scientific Committee on Ani-mal Health and Animal Welfare of the European Commission. March 10, 1999.

rBGH and Animal Welfare: Reproductive Side-effects (II)

“There were a number of effects on reproductive performance that were associated with the use of rBST. These included a substantial increase in the risk of non-pregnancy and a slight increase in days open in cows that do conceive. There was also inconclusive evidence of increased risks of cystic ovaries and twinning.”

“Report of the Canadian Veterinary Medical Association Expert Panel on rBST.” Canadian Veterinary Medical Asso-ciation Expert Panel on rBST Executive Summary.

Sweating the Small Stuff

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Food

Nanotechnology Needs Research and Regulation

Nanotechnology is the process of manipulating matter at the molecular level – or nanoscale. Nanomaterials have at least one dimension that is 100 nanometers or less. A nanometer is one billionth of a meter – approximately 1/100,000 of a human hair.

This new technology has been touted as the next revolution in many industries, with more than 300 nanoproducts already on the market and sales of over $30 billion in 2005. This includes everything from sunscreen and stain resistant clothing to food, food packaging and dietary supplements. Investments in the global nanofood market alone are expected to reach $20 billion in 2010, with the world’s biggest companies, including Altria, Nestle, Kraft, Heinz and Unilever, involved in nanotechnology research and development.1

However, in the rush to incorporate nanoparticles into products already being marketed to the public, comparatively little money has been devoted to researching the health and environmental consequences of nanotechnology.

Smaller is Different

Nanoscale materials are very different than their larger counterparts, with distinct electronic, magnetic, chemical and mechanical properties. Nanoparticles have an increased surface area, which offers more space for interaction with other substances. This increased interaction with their surroundings means that substances at the nanoscale are more reactive and have higher toxicity than they do at their normal size. Picture a coffee maker. If you fill it with whole coffee beans, you get a very weak cup of coffee. But if you grind the beans first, you will increase the surface area of the coffee beans and get a dark, strong cup of coffee.2

Adding to the concern of increased toxicity, substances that are stable in larger forms (such as aluminum) can also become reactive or explosive in nanoparticle form, creating the potential for health effects that are not seen when the substance is in its larger form.

Because they are tiny, nanoparticles have the potential to bypass the blood-brain barrier, (the membrane that controls the passage of substances from the blood into the central nervous system). They also have the potential to pass the placental barrier. One 2004 study found that nanoparticles can easily travel from nasal passageways to the brain, and another found that gold nanoparticles can move across the placenta from mother to fetus.3 Once in the bloodstream, nanomaterials can circulate throughout the body and be taken up by organs and tissues. Given the higher toxicity of these particles, it is disturbing that the length of time they remain in the organs and what dose may cause harmful effects are unknown.4

Size and structural differences allow nanomaterials to migrate to different tissues and organs than their larger counterparts. There is also evidence that nanoparticles can be more completely absorbed by the body, increasing the substance’s “bioavailability” 5 (the amount of a substance that enters the bloodstream and is available to have an active effect). Nanoengineered materials also have the potential to increase the bioavailability of other chemicals, such as known toxins. One study found that micronized titanium dioxide in sunscreens increases the skin’s absorption of several pesticides.6

The degree of these impacts can vary greatly between individuals depending on physiological differences, such as thickness and condition of hair and skin, physical activity and duration of exposure.7

Regulatory Oversight

Yet, despite these uncertainties and possible dangers, nanotechnology goes unregulated.

The Food and Drug Administration, which is the agency responsible for regulating food additives and new chemical substances in food, states that “the existing battery of pharmacotoxicity tests is probably adequate for most nanotechnology products that we will regulate. Particle size is not the issue.” (emphasis added)8 Experts agree, however, that particle size is indeed the issue.

The European Commission Scientific Committee on Emerging and Newly Identified Health Risks reported that “experts are of the unanimous opinion that the adverse effects of nanoparticles cannot be predicted (or derived) from the known toxicity of material of macroscopic size, which obeys the laws of classical physics.” 9

Even industries that stand to benefit most from the development of nanotech materials recognize that particle size is the issue. DuPont’s director of materials science and engineering has said “it would be unwise to claim that just because there are tiny amounts, it’s harmless.” 10

Due to the potential impact of nanotechnology on the environment, in 2006 the Environmental Protection Agency began to regulate a class of consumer items made with odor-destroying nanoparticles of silver. The agency got involved after concern grew that nanosilver being washed down drains may be killing beneficial bacteria and aquatic organisms and may also pose risks to human health.11 This was the first move by the federal government to regulate nanotechnology. But most materials will not fall under EPA oversight.12 Most materials won’t be regulated at all, despite the fact that store shelves will be increasingly flooded with products made with this emerging technology.

Conclusion

Chemicals like PCBs and pesticides like DDT and dieldrin, which were once thought to be safe, were not truly understood until long after human health and environmental damage already occurred. To avoid similar disasters in the future, nanotechnology’s effects should be adequately studied before they are allowed onto the market. An adequate level of study would at least match the amount of testing and safety data the federal government requires for new food additives.

Recommendations

  • The scientific community has clearly established that the safety of nanomaterials cannot be assumed by studying their larger counterparts. The FDA should regulate nanotech products as the new chemical substances that they are, and require at least the same level of testing required for new food additives.
  • If they are approved, nanoproducts should be clearly labeled so consumers are aware that the products they are using contain these controversial ingredients.
  • Federal agencies such as the Food and Drug Administration should also be required to track any incidents, including adverse or allergic reactions, once nanotech products are on the market.


Footnotes

1 Kuzma, Jennifer and Peter VerHage. Nanotechnology in Agriculture and Food Production: Anticipated Applications. Woodrow Wilson International Center for Scholars. Project on Emerging Nanotechnologies, September 2006, p.9-10.

2 “Fine particles—Part 5: Incineration worsens landfill hazards.” Rachel’s Hazardous Waste News. Environmental Research Foundation (Annapolis, MD), January 3, 1990.

3 Gibbs, Larry and Mary Tang. “Nanotechnology: Safety review and risk management overview.” NNIN Nanotechnology Safety Workshop, December 2, 2004.

4 The Center for Food Safety. “Nanotechnology: It’s a small (and unregulated) world after all.” Food Safety Now! Autumn 2006.

5 Consumers Union. Written Testimony to the FDA on Nanoengineered Ingredients in Food, October 6, 2006.

6 Brand, Rhonda and James Pike, et al. “Sunscreens containing physical UV blockers can increase transdermal absorption of pesticides.” Toxicology and Industrial Health, 19(1): 9-16, 2003.

7 Consumers Union, op. cit.

8 Ibid.

9 Appropriateness of Existing Methodologies to Assess the Potential Risks Associated with Engineered and Adventious Products of Nanotechnologies. European Commission Health and Consumer Protection Directorate-General, Scientific Committee on Emerging and Newly Identified Risks, March 10, 2006.

10 Consumers Union, op. cit.

11 Weiss, Rick. “EPA to regulate nanoproducts sold as germ-killing.” The Washington Post, November 23, 2006.

12 The Associated Press. “Berkeley to regulate nanotechnology.” AP Online, December 12, 2006.

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