IFT Provides Comment to National Organic Standards Board

October 12, 2010

Lisa Ahramjian
Executive Director
National Organic Standards Board
USDA-AMS-NOP
1400 Independence Ave., S.W.
Room 2646-So.
Ag Stop 0268
Washington, D.C. 20250-0268

Via email: nosb@ams.usda.gov

Re: Document Number AMS-NOP-10-0068; NOP-10-08

Dear Ms. Ahramjian;

The Institute of Food Technologists (IFT) appreciates this opportunity to offer comments for consideration by the National Organic Standards Board. IFT’s comments pertain specifically to the nanotechnology recommendation arising from the NOSB’s Materials Committee. 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 individual members working in food science, food technology, and related professions in industry, academia, and government. IFT champions the use of science across the food value chain through knowledge sharing, education, and advocacy, encouraging the exchange of information, providing educational opportunities, and furthering the advancement of the profession.

Given the critical need for additional scientific and technological advancements to sustainably meet the food needs of our growing global population and the potential for nanotechnology to play a valuable role, I encourage you to carefully consider the potential for nanotechnology in organic food production, processing, and packaging. IFT would welcome an opportunity to be a scientific and technical resource to you should you undertake further dialog on this topic.

Further scientific and technological advancements in agriculture and food manufacturing are critical to be able to sustainably meet the food needs of our rapidly growing global population; and nanotechnology holds tremendous potential for positive advances in the farm-to-table food system (IFT, 2010). A recent IFT Scientific Review indicates that in agriculture, nanotechnology could respond to the need for more precise management of resources (e.g., water); improve crop and livestock production; contribute to control of pathogens in food animals and their feed; enhance pest, disease, and weed control; support sustainable and precise production; and improve postharvest technology (including waste management, for example). In food manufacturing, nanotechnology presents novel ways to detect pathogens in real-time via portable and/or in-line systems that could be used throughout the food system; and allow more packaging advancements (e.g., antimicrobial properties, biodegradability, traceability) (IFT, 2010). IFT encourages the NOSB to consider specific nanoparticles and applications, rather than the technology as a whole, in its decision making.

IFT also recognizes the importance of responsible research and development and adequate characterization of nanoscale materials to establish the safety of novel nanostructured food-related materials. Thus, IFT has been collaborating with several organizations to assess the state of the science on nanomaterials.

IFT actively advocates and supports science-based public policy and legislative initiatives, especially as they relate to the production, processing and packaging of foods. IFT encourages the NOSB to base its policy decisions on science as regards the use of nanotechnology in production and manufacture of organic foods. In our Nov. 3, 2009 comments to the Board, we urged the NOSB to enhance collaborative efforts with other stakeholders domestically and internationally for scientific input into policy decisions. Scheduling a symposium on the topic is an opportunity for such collaboration. If the NOSB were to convene a symposium, IFT would be pleased to assist in identifying experts to address the Board’s areas of interest (e.g., adequacy of the definition, any potential areas of concern not included in the definition, and effect of different regulatory approaches).

Since 2006, IFT has conducted annually an International Food Nanoscience Conference. Our 2010 conference addressed the following topics:

  • state of the science on safety and toxicological assessment
  • science-based risk assessment
  • detection of nanoparticles in food
  • new and emerging applications in the food supply
  • investments of the National Nanotechnology Initiative
  • European Union investments
  • U.S. and EU regulatory updates, and
  • legal implications.

Conference presentation visuals are readily accessible at: http://www.ift.org/knowledge-center/focus-areas/emerging-technologies-and-ingredient-innovations/nanoscience.aspx.

An article summarizing the conference presentations is published in the October, 2010 issue of IFT’s monthly publication Food Technology, accessible at: http://www.ift.org/~/media/food%20technology/pdf/2010/10/1010feat_2_nanomaterials.pdf. A backgrounder and answers to frequently asked questions about nanotechnology are accessible on this web page as well. An IFT Scientific Status Summary, “Functional Materials in
Food Nanotechnology,” is accessible at http://www.ift.org/Knowledge-Center/Read-IFT-Publications/Science-Reports/Scientific-Status-Summaries/~/media/Knowledge%20Center/Science%20Reports/Scientific%20Status%20Summaries/FuncationlMaterialsinFood_1106.pdf.

Thank you for considering these comments. Please let me know if we may be a resource to you.

Sincerely,

William Fisher
Vice President, Science and Policy Initiatives

IFT. 2010. Feeding the world today and tomorrow: The importance of food science and technology. A Scientific Review of the Institute of Food Technologists, Chicago, Ill. By J. Floros, R. Newsome, W. Fisher, G. Barbosa-Canovas, H. Chen, C.P. Dunne, J.B. German, R.L. Hall, D.R. Heldman, M.V. Karwe, S.J. Knabel, T.P. Labuza, D.B. Lund, M. Newell-McGloughlin, J. Robinson, J.G. Sebranek, R.L. Shewfelt, W.F. Tracy, C.M. Weaver, G.R. Ziegler. Comp. Rev. Food Sci. Food Safety 9:572-599. Accessible at: http://onlinelibrary.wiley.com/journal/10.1111/%28ISSN%291541-4337.

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