IFT Comments to NOSB on Nanotechnology

November 3, 2009

Valerie Frances
Executive Director
NOSB, National Organic Program
US Department of Agriculture
1400 Independence Avenue, SW., Room 4004
So., Ag Stop 0268
Washington, DC 20250
Tel: 202 720 3252
E-mail: valerie.frances@ams.usda.gov

Re: Docket No. AMS-TM-09-0060; TM-09-07 (National Organic Standards Board; Public Meeting)

Dear Ms. Frances:

The Institute of Food Technologists is thankful for the opportunity to comment on the proposed National Organic Standards Board (NOSB) recommendations for nanotechnology in organic production, processing and packaging.

The Institute of Food Technologists (IFT) exists to advance the science of food. Our long-range vision is to ensure a safe and abundant food supply contributing to healthier people everywhere. Founded in 1939, IFT is a nonprofit scientific society with 20,000 individual members working in food science, food technology, and related professions in academia, industry, and government. IFT champions the use of science-based solutions across the food chain through knowledge sharing, education, advocacy, and furthering the advancement of the profession. IFT has played a leadership role in food nanotechnology by convening the Food Nanoscience Advisory Panel consisting of Institute members representing the academia, government and industry.

IFT recognizes the potential for nanoscale science, engineering, and technology to positively impact the food and agriculture sector, therefore it supports objective and well designed research and development efforts in that sector. The potential benefits of using nanoscience and nanotechnology in food systems include safer and more nutritious food products with better quality and stability. Other positive outcomes include: improved processing and packaging systems that increase the safety, quality and shelf-life of food products; reduction of food losses; minimized energy use and environmental impact; and better ingredients and nutrient delivery systems that promote consumer health and wellness.

Ultimately, nanotechnology may assist the food science to advance the human condition on earth – feed a growing world population, eliminate foodborne illnesses, hunger and malnutrition, prevent chronic diseases – in a sustainable and environmentally respectful way.

To develop the potential benefits of nanotechnology in food applications, it will be necessary to define and manage any concerns that could negatively impact the safety of the food supply or environmental sustainability. These potential concerns need to be characterized properly, researched, and resolved in order to implement commercial applications of the technology. Knowledge on the potential impact of several nanotechnology applications is becoming available as research is conducted in areas of safety, health and the environment. IFT in collaboration with other stakeholders is currently working to provide a comprehensive report on state of the science on the safety of nanomaterials in food applications. Further, IFT continually advocates for increased funding for research and encourages responsible development of the technologies.

IFT strongly encourages the NOSB to reject the conclusions of their Materials Committee to “exclude and prohibit the use of nanotechnology and the products of nanotechnology in certified organic production processing, handling and packaging”. Instead, IFT supports the adoption of a petition process that allows for consideration of each potential application of nanotechnology on a case-by-case basis. This IFT recommendation is in keeping with the Minority Opinion submitted by one or more members of the Materials Committee. Prohibiting or not considering yet-to-be applications of nanotechnology in production, processing and packaging of organic foods would hinder the development of this evolving technology at this time.

IFT actively advocates and supports science-based public policy and legislative initiatives, especially as they relate to the production, processing and packaging of foods. Similarly, IFT encourages the NOSB to consider science-based policy decisions when it regards the use of nanotechnology in organic foods. IFT urges the NOSB to enhance collaborative efforts with other stakeholders domestically and internationally for scientific input in their policy decisions. IFT is more than happy to work with the NOSB in any way possible to provide background information. For additional information please contact William Fisher at wfisher@ift.org or 202 330 4977.

Sincerely,

William Fisher Vice President, Science and Policy Initiatives

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