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Media:  What do you make of these new guidelines?

Sureshlab:  The benefits of nanotechnologies in food packaging over conventional technologies are undeniably tremendous. These new guidelines are not a surprise for nano-researchers and we have been expecting these. I guess FDA's guidelines can be taken as a strong precautionary tone on safety risks of food packaging applications of nanotechnology.  However, big players such as Kraft, Nestle and even academic and scientific researchers will NOT consider this announcement as a step to jeopardize the benefits of nano food-packaging. Rather, one should remind and acknowledge that there are deficiencies in the current regulations, and a huge knowledge gap exists in terms of the public awareness and information on the impact of nanotechnology on food packaging. It is nice and advisable to take a proactive approach to avoid any unpredictable health hazard. I believe FDA is doing exactly the proactive approach.

Media:  What is the current common practice for nanotech use in food packaging? Why are they necessary? What is the advantage to nanotech applications in packaging?

Sureshlab:  Nanotechnology offers higher hopes in food packaging by promising longer shelf life, safer packaging, better traceability of food products, and healthier food. Polymer nanocomposite technology holds the key to future advances in flexible, intelligent, and active packaging. Intelligent, smart, and active packaging systems produced by nanotechnology would be able to repair the tears and leakages (self-healing property), and respond to environmental conditions (e.g., change in temperature and moisture). Intelligent food packaging can sense when its contents are spoiling, and alert the consumer, while active packaging will release a preservative such as antimicrobials, flavors, colors, or nutritional supplements into the food when it begins to spoil. Antimicrobial nanoparticle coatings in the matrix of the packaging material can reduce the development of bacteria on or near the food product, inhibiting the microbial growth on nonsterilized foods and maintain the sterility of pasteurized foods by preventing the post-contamination. Foods such as cheese, sliced meat, and bakery that are prone to spoiling on the surface can be protected by contact packaging imbued with antimicrobial nanoparticles. Nanotechnology can effectively produce oxygen scavengers in packaging for sliced processed meat, beer, beverages, cooked pastas, and ready-to-eat snacks; moisture absorber sheets for fresh meat, poultry, and fish; and ethylene-scavenging bags for packaging of fruit and vegetables.

It is even possible to produce intelligent smart packaging for providing authentication, and track and trace features of a food product for avoiding counter-feiting; preventing adulteration and diversion of products destined for a specific market. Complex invisible nanobarcodes with batch information can be encrypted directly onto the food products and packaging. This barcode technology could offer food safety by allowing the brand owners to monitor their supply chains without having to share company information to distributors and wholesalers.

Media: Is FDA ahead of the curve, or behind?

SureshLab:  The regulations put forward by the European Union (about two years ago) seems to be way ahead in the nanotechnology related food applications compared to us here in North America. The guidelines by FDA are only voluntary. I personally think, EU is more conservative than us in adopting the food nanotechnology. FDA is behind the curve on this issue.

Media: What effects will these guidelines have?

SureshLab:  These guidelines are indeed essential as they will aid in sustaining the growth of food industry in the longer term, and will help to avoid unpredictable health hazards. These will also change and influence the tangent of nanotechnology research towards safety and toxicology. Industries will be compelled to use clear labelling for ingredients present in the form of nanoparticles. Food manufacturing industries might be obligated to conduct the risk assessment. As such there are no standard protocols for testing the toxicology effects of nanomaterials. Further research into human exposure to nanomaterials and their toxicology and biokinetics will add more challenges.

Media: What revisions, if any, would you like to see?

SureshLab:  There is no consensus among the nanotechnology researchers regarding the definition of 'NANO', and more particularly the size as well. Although 1 to 200 nm range is commonly accepted as a nano-particle, 150 nm and above may not have as serious implications in terms of health risks. Some environmental groups’ claim that nanoparticles is in the range of 50 to 70 nm can enter cells. The definitions and the size range between 1 to 100 nm, put forward by the National Nanotechnology initiative of US is predominantly based on the non-food materials of nanoscience. Absence and lack of clear formal globally accepted definition about the term 'nano' and the legally accepted size range for nano would cause a political and technical challenge in terms of implementing these guidelines of FDA. Along with the voluntary disclosure mandate from the industries, FDA could possibly put forward a platform or web source to inform the public about the list of products that are commercially available in the market that are made using nanotechnology. The new legislation should be explicit with specific provisions for various nanomaterials. FDA could release a list of authorized substances that could be used as components of intelligent, smart and active packaging.

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