Heading slide No 1 Definitions and nomenclature for - - PDF document

Heading slide No 1 Definitions and nomenclature for nanotechnologies are part of the working tools for engineers, manufacturers, chemists, scientists and others in academia or industry. Most of these are rarely heard, let alone seen by the consuming public. However, from a consumer perspective it is those terms or names, that have comprehensible definitions and end up in products in the market place that are of primary

• interest. Fundamentally, at the consumer level these terms and names appear on or as,

labels. So why do we have terms or ‘labelling?’ The organised consumer movement has long held as one of its tenants, the value of

• labelling. Labels provide the ideal medium by which manufacturers/producers/retailers etc.

communicate information about their wares to the consumer. It allows the manufacturer to provide information they feel is a selling point to the consumer, what they want you to know about the product. There are obviously other avenues used as well, but in the main, the label is the first thing

• n a product that the consumer’s eye is drawn to.

It is the single most important means that consumers use to gather information on which to make an informed decision about whether or not to purchase a particular product. As such, labelling provides an advantage to both those selling a product and those purchasing one. Labels are the legitimate and preferred method by which important and often life preserving information is made available to those needing it, right through the supply chain

• f a product and affects hundreds of other products in their use, including nano ones.

There is no disagreement that health and safety labels are both important and essential. Labels also have another important and fundamental role - that of informing the next person/company/manufacturer/retailer down the line, ending eventually with the consumer. It was President Kennedy who first promulgated the basic rights of the consumer, and amongst those rights was the right to know, to have the information necessary to make an informed choice. Labels are used to garner that information. Labels also have a role in making comparisons between products, in advising how the product may be safely used, stored, recycled and sometimes in its eventual disposal. Nanotechnology, while not new in itself, has been, and is instrumental in the market place where we are seeing a virtual explosion of new nano enabled products coming into commercial use. Most consumers are unaware that this technology has been used. It has been shown that where commercialisation of a product gets ahead of the science and/or regulation, problems result. We are in fact dealing with this very issue since Woodrow Wilson suggests that there are at least 1300 nano-products already in the market, very few carry labelling. Australia doesn’t know how many nano products are in

• ur market and seems reluctant to take steps to find out and record this information.

COMMUNITY PERSPECTIVE ON LABELLING AND DEFINITIONAL ISSUES July 4th 012.

Not only from the consumer viewpoint, but from everyone’s perspective, good labelling and enforceable definitions are necessary for effective management of environmental, health and safety risks.

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• next slide - slide no 3 - Good labelling etc..

What happens if we don’t have labelling? The Australian government while wholly supportive of labelling for health and safety reasons has opted in many situations NOT to support labelling for Consumer Choice. This is in spite of numerous surveys carried out over the years that have found well over 90% of consumers support ‘right to know’ or purely for consumer information . This holds true even where consumers may wholeheartedly support new and emerging technologies such as genetic engineering and the use of nanotechnology. They want it labelled. The arguments put forward as to why we shouldn’t label nano-products are:-

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• 1.

Nanotechnology covers a wide range of applications including medicines, food, industrial chemicals, ICT etc, leading to possible confusions in what labelling was trying to achieve.

• The response: This is true and there are likely to be more areas with which nano
• will be associated with in the future- it is a convergence technology. But if we look at
• another recent technology, for example solar energy, once the public becomes
• acquainted with the term, the mechanics of how that energy is obtained doesn’t
• matter, they simply know it means coming from the sun. The same could be true
• for nanotechnology products - people may come to think of it in terms as simple as
• ‘coming from something very small.’

next slide - slide no. 5 2. It might be difficult to provide information of the type and level required to inform choice in a meaningful way.

• The response:

What is so difficult about a label stating ‘produced through

• nanotechnology’, or in a list of food or chemical ingredients, xxxx(nano) or
• nano xxxx? It becomes an education tool
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COMMUNITY PERSPECTIVE ON LABELLING AND DEFINITIONAL ISSUES July 4th 012.

3. Products may contain larger non-nano particles of a certain chemical as well as

• some nano particles depending upon the method of manufacture so there is an
• issue surrounding the absolute or percentage mass (or other metric) that should
• trigger labelling and how that measure should be quantified.
• The response: This is also true. However, again the consumer isn’t interested
• in the absolute mass or percentage, just the information that the product
• contains or is made through the use of the technology. However this
• information is important and necessary for risk assessment and Regulation. If
• a whole of chain paper trail, that is, tracking and tracing,was instigated from
• where the nano was produced or used, this would assist both the Regulators
• and the consuming public.
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3. There is a risk that such labelling information might imply nano-particles are dangerous without any proof and details of danger.

• The response: People working with nanotechnology are acutely aware that we do
• not yet have all answers regarding health and safety and the environmental impact
• f all the nano-particles being studied. In the absence of applicable Regulations, we
• cannot be sure that nano-particles already on the market don’t or won’t cause
• problems. However, if we accept that they are safe, what is the problem in
• acknowledging via labelling that they are nano products? Shouldn’t we be telling
• people that the advantages, features, benefits of the product they have bought is
• there because of nanotechnology? Conversely, if a product already in the market
• later proves to be unsafe, labelling would alert the consumer to the fact to take
• appropriate action.
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4. It may detract from health and safety warnings

• The response: It is hard to find any justification for this statement. If for
• example it was necessary to let the consuming public know that a nano-product
• should be handled or disposed of in a certain way, then that should appear as a
• health and safety warning. Other than that, the nano would either be in the
• ingredients list, in the name of the product (determined by the manufacturer)
• r as an information statement on the label of the product.
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6. Under the World Trade Organisation (WTO) Agreement on Technical Barriers to Trade (TBT), WTO members need to ensure that technical regulations (including labelling) are not more restrictive than necessary to fulfill a legitimate objective.

• COMMUNITY PERSPECTIVE ON LABELLING AND DEFINITIONAL ISSUES July 4th 012.

• The response: This is constantly used as an excuse not to label for consumer
• information, It has unfortunately been used frequently by the USA as it denies its
• wn citizens certain labelling information, most notably the labelling of genetically
• engineered foods. Codex has now agreed that countries should have the right to
• label for g.e if they wish to do so, and it is no longer considered a Technical
• Barrier to Trade. Australia should not be intimidated into following the USA in this
• regard with either g.e. or nanotechnology. It has been recommended by the
• Blewitt Inquiry into labelling that any new technology should be labelled for a period
• f thirty years and then reviewed.
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7. We don’t label for ‘processes’

• The response: Well, you know, we do. Food Standards put this up as an excuse not
• to label when consumers were agitating for the labelling of g.e. foods. Yet we
• frequently label for processes, in the case of foods, homogenised milk, Gluten free,
• rganic produce, halal meats and free range eggs, to name a few. We also
• recognise ‘over cooked’, ‘underdone’, ‘tenderised’ and ‘caramelised’. With
• commodities we know of anodised products, ceramic coatings, air brushed
• photograph, micellised vitamins and additives, carbon dating etc. ..so there really
• isn’t any truth in this statement.
• We frequently label for processes and this should apply to the use of products
• produced or enabled through nanotechnology.

Looking now at Supporting arguments for the addition of informed choice labelling. These include:-

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1. To educate the public that there is a new process being added to manufacturing and to prompt them to make themselves informed about it.

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2. Surveys and Public engagement exercises show very strong support for labelling for informed choice. (NETS have done many surveys as have Consumers SA and Choice over time)

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3 To ensure transparency in the use of a controversial new technology - to establish trust

• in the community and to avoid the same situation we had with the intgroduction of
• genetic engineering.
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• 4. To promote a standardized approach to labelling which is what we are about today.

COMMUNITY PERSPECTIVE ON LABELLING AND DEFINITIONAL ISSUES July 4th 012.

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• 5. To ensure that users of manufactured nano-particles (MNP) and products containing
• manufactured nano-particles (PCMNP) can correctly identify the MNP contents for
• the purposes of assessing risk in selection, purchase, distribution, handling, use
• and disposal, especially while information is being acquired on any effects upon the
• natural environment and human health from both short and long term exposure to
• nano-particles.
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6. Provide guidance on the use of specific terms on (nano) labels.

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7. We do label for processes as pointed out earlier

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8. To Acknowledge where we don’t have sufficient information to determine safety,

• where there are still unknowns about the use of a nano-particle.

Consumers are ultimately the end users of nano enabled products. It follows that they may also be responsible for the recycling and or disposal of such products. Labelling of nano will assist in this regard. Acceptance of any new technology by the consuming public depends upon the honesty with which the government and industry deal with consumer’s concerns. This is now being widely recognised in any number of public documents in numerous countries. Government and industry are continually touting then line that ‘the market place will decide’ and with this I agree. For this to work efficiently and fairly however, the market place must have factual information to allow the public to make that choice, or the market place is skewed towards what government and industry think the public should have. What the promoters are really concerned about is if they do label for choice, then consumers may shun the new technology. I acknowledge that this is a risk, but it will more likely be a sure thing if the public feels information is being hidden from them by refusal to label. The logic is that if there is no labelling then there must be something to worry about.This happened with genetic engineering, it is still not a technology that most consumers are comfortable with, since from its inception there has been a reluctance to label. The present labelling standard does not provide consumers with the information they asked for. To return to the work the ISO is doing in this regard. TC229 and European CEN are actively working towards labelling of manufactured and/or engineered nano products for consumer information. There is a recognition that labelling from business to business is also important, and that business may have different requirements for labelling than consumers, so both will be worked upon separately. However labelling for consumers must have a starting point and this is where a tracing and tracking or paper trail coming down

COMMUNITY PERSPECTIVE ON LABELLING AND DEFINITIONAL ISSUES July 4th 012.

through business, will be essential for consumer information. Standards Australia through its NT-001 committee is taking an active part in these projects. In addition it has been recognised that specific language suitable for the consuming public, that is, language the lay person can understand, is desirable, and work at the Stresa meeting in June progressed this view by the raising of a new work item which will devise a Plain Language Guide for Consumers on Nanotechnology. This New Work item is presently out for Ballot. Thank you for listening and I’d like now to ask my colleague Georgia Miller to continue this presentation looking at definitions.

COMMUNITY PERSPECTIVE ON LABELLING AND DEFINITIONAL ISSUES July 4th 012.