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Madrid, 30 June 2016
Nanomaterials in agri/food/feed: update from EFSA
2
OUTLINE
Short Introduction to EFSA
Risk assessment process
Current applications
Current guidance for risk assessment
What to expect
Future guidance development
Introduction to EFSA and who is assessing nanomaterials
01
EFSA IS…
Set up in 2002 as an independent source of scientific advice
Located in Parma since 2005
Having 450 Staff, 60% engaged in science
Delivering scientific outputs
Providing independent, timely risk communication
Promoting scientific cooperation
PROVIDING SCIENTIFIC ADVICE FROM FARM TO FORK
Plant Health
Animal health
and welfare Biological
hazards
Chemical
contaminants Nutrition
Plant
Protection Genetically modified
organisms
Animal feed
Food
additives
Food
packaging
6
Cross-cutting science
OTHER EFSA UNITS INVOLVED
Scientific Committee and Emerging Risks for guidance development
ApDesk for registration of applications
EFSA’s scientists evaluate, assess, advise
…BUT NOT TO
develop food safety policies and legislation
adopt regulations, authorise marketing of new products
enforce food safety legislation
take charge of food safety/ quality controls, labelling or other such issues, like inspections and traceability
9
Alignment and
cooperation
Applicants <> EC + MS <> EFSA
EFSA RISK ASSESSMENT PROCESS
Nano = Key enabling technology
producers
Legislation in place for safe governance
Risk Analysis (RA, RM, RC)
Definition in progress to enhance clarity
Food inspection
Labelling in progress to enhance transparency
Consumers, NGO, media
10
1
2 3
5
Current applications received at EFSA: http://registerofquestions.efsa.europa.eu/roqFrontend/login?2
03
12
No applications yet
NOVEL FOODS
Legal framework being implemented
13
Passed and ongoing applications
FOOD CONTACT MATERIALS
Dossiers submitted on explicitly engineered nanomaterial
Exposure scenario: no migration into the food
No food flavouring nano-applications
14
FOOD CONTACT MATERIALS
EFSA-Q-2014-00529 Additional data request Request for the evaluation of Zinc oxide nano particles
EFSA-Q-2014-00308 Finished Request for safety evaluation of zinc oxide, nano particles for use as an additive in plastics
EFSA-Q-2013-00641 Additional data request Request for safety evaluation of Nano-Hexadecyltrimethylammonium Bromide modified Montmorillonite Organoclay for use as additive in plastics
EFSA-Q-2013-00100 Finished Request for the evaluation of additive : coplymer in Nanoform of methacrylic acid, ethyl acrylate, n-butyl acrylate, methyl acrylate, butadiene
EFSA-Q-2012-00706 Finished
Request for the evalutation of Additive : Copolymer in nanoform of ethyl acrylate, methyl methacrylate, butadiene, styrene and either not crosslinked or crosslined with divinyl benzene or 1,3-butanediol dimethacryalte
EFSA-Q-2011-01079 Finished Titanium nitride, nanoparticles
EFSA-Q-2006-323 Finished Titanium nitride, nanoparticles
15
Re-evaluation programme (Reg (EU) n. 257/2010)
FOOD ADDITIVES
All FAs permitted before January 2009, All on bulk materials
Re-evaluations of food colours to be finalised by 2015.
No dossier, no applicant.
Data gathered following EFSA public calls for data (by interested parties), or public domain.
Silver (E174), gold (E175), iron oxides (E172) and titanium dioxide (E171).
16
FOOD ADDITIVES RE-EVALUATION PROGRAMME
No limit for nanofraction according to EC specifications of FA (Reg (EU) n. 231/2012)
According to the information provided by interested parties, bulk materials may comprise a small nanofraction, which can be considered as unintentionally present or formed
Facts
17
FOOD ADDITIVES RE-EVALUATION PROGRAMME
Nanofraction not sufficiently characterized in biological studies (e.g. % of substance in nanoform; methodology used)
Difficult to know how much nanofraction is present in the FA on the market:
- Silver: mass conc 20% of the mean total
silver conc in pearls (Verleysen, 2015)
- TiO2: limited % of particle size (by
weight) < 100 nm in different batches
18
Elementary gold may include NP
EFSA OPINION ON E175 (GOLD) JAN 2016
Lots of studies cited and discussed
In vivo, in vitro
Studies on pristine gold nanoparticles
Capped or coated particles not useful for RA (appendix)
http://www.efsa.europa.eu/sites/default/files/scientific_output/files/main_documents/4362.pdf
19
EFSA OPINION ON E175 (GOLD) JAN 2016
Conclusions:
Despite the absence of toxicity data, but taking into account the low solubility of elemental gold, systemic availability and thus systemic effects of elemental gold would not be expected.
Recommendations:
specifications for E 175 should include particle size distribution (± SD), the percentage (in number) of nanoparticles, using electron microscopy
Biological relevance
Future directions
20
Iron Oxides and hydroxides (E172): insufficient data for RA
http://www.efsa.europa.eu/sites/default/files/scientific_output/files/main_documents/4317.pdf
Silver (E174): insufficient data for RA
http://www.efsa.europa.eu/sites/default/files/scientific_output/files/main_documents/4364.pdf
21
Nutrient sources One application in the past – lack of data
comparing toxicity and bioavailability of nano- and bulk- forms
22
Ongoing re-evaluation of bulk materials
FEED ADDITIVES
Dossier submitted on the bulk
Presence of NP
Cooperation with Food additive evaluation
23
EFSA assesses only active ingredient
PESTICIDES
Formulations are assessed by Member States
Member States ask EFSA for harmonised guidance on nano-formulated pesticides
Nanopesticides/formulatons will be included in guidance update 2016-2019
24
Current mandate
CONTAM
Microplastics in food
Current EFSA Guidance document for risk assessment of nanomaterials: (EFSA
Journal (2011) 9(5):2140 http://www.efsa.europa.eu/en/efsajournal/doc/2140.pdf)
04
26
In spite of many practical limitations, chemico-physical characterization of ENMs should be considered in five stages
NM TEND TO INTERACT
(i) as manufactured (pristine state);
(ii) as delivered in food/feed products , taking into account also storage effects;
(iii) as present in the food/feed matrix;
(iv) as present in toxicity testing medium; and
(v) as present in biological tissues in
the human or animal body
nano activities at EFSA
27
Assessing the extent of exposure is fundamental as it heavily determines the safety testing strategy
NM TEND TO INTERACT
Exposure meaning to the specific ENM and/or, if any, to a new ENM structure or degradation/dissolution products formed within the food /feed matrix and/or in the gastrointestinal tract
6 exposure scenarios provide indications on how to carry out toxicity tests such as in vitro and in vivo genotoxicity tests, ADME and subchronic toxicity to take into account structural peculiarities of ENMs.
nano activities at EFSA
28
FOLLOW ONE OF THE 6 EXPOSURE SCENARIOS
nano activities at EFSA
1: No persistence of ENM in preparations/formulations as marketed (only exposure to the non-nanoform): the relevant toxicity testing outline should apply in relation to the intended use unless data are already available
2: No migration from food contact materials: (no exposure: no toxicity testing);
3: Complete ENM transformation into a non-nanoform in the food/feed matrix before ingestion (only exposure to the non-nanoform): the relevant toxicity testing outline in relation to the intended use should apply unless data are already available
29
FOLLOW ONE OF THE 6 EXPOSURE SCENARIOS
nano activities at EFSA
4: Complete transformation into a non-nanoform in the gastro-intestinal tract ( as shown through studies in gastro-intestinal fluids and/or ADME) and possibility of excluding absorption of the nanoform before digestion: limited testing is required mainly consisting of in vitro genotoxicity and some in vivo local effects.
30
FOLLOW ONE OF THE 6 EXPOSURE SCENARIOS
nano activities at EFSA
5: Total or partial persistence of the ENMs in the food/feed matrix and in the gastro-intestinal fluid and toxicity data on the non-nanoform available: ADME, 90 day-toxicity in rodents and genotoxicity to be tested. Resulting data are to be compared with those of the non-nanoform (if available) and:
If the difference observed indicates an increased hazard, the more toxicity testing will be required on the ENM;
If the differences observed indicate less hazard, requests to waive further testing could be scientifically justified.
31
FOLLOW ONE OF THE 6 EXPOSURE SCENARIOS
nano activities at EFSA
6: Total or partial persistence of the ENM in the food/feed matrix and in the gastro-intestinal fluid and toxicity data on the non-nanoform not available:
full testing required as foreseen by the relevant testing outline in relation to the intended use, taking also into account the presence of nano-particles.
What is in the pipeline 05
33
Systematic Literature Survey 2014
NANOMATERIALS IN AGRI/FOOD/FEED
http://www.efsa.europa.eu/en/supporting/pub/621e
34
Systematic Literature Survey 2014
NANOMATERIALS IN AGRI/FOOD/FEED
Peters et al, 2016 (submitted)
Case-by-case safety studies +
RA
Future EFSA guidance for risk assessment 06
36
DATA
EFSA RISK ASSESSMENT REQUIREMENTS
In dossiers prepared by applicants
Need more guidance
Aligned with ECHA
From call for data
Interested parties
Scientific Publications
Robustness, reporting and consistency
To be generated
case by case
37
TEST METHODS
EFSA RISK ASSESSMENT REQUIREMENTS
From OECD
Work in progress
Standards and reference materials
For complex matrices like food/beverages
From FP7 projects
Coming through
From REACH
…
As standard as possible
38
Human and animal health
MORE GUIDANCE FOR MORE CLARITY
Input from NanoReg, NanoDefine, +…
Incl. ADME, in vitro digestion, allergenicity, soft/hard NM, read across, solubility, aggregation/agglomeration, p-chem, dispersion
39
Environment
MORE GUIDANCE FOR MORE CLARITY
Input from NanoFate, + …
Exposure throgh manure, sludge, pesticides/formulations
Incl. Environmental fate, biodegradation/accumulation/ biomagnification, non-target organisms selection, protection goals,
Possible life cycle (for FCM)
News from the EFSA NanoNetwork 07
41
ToR of the NanoNetwork
since 2010, to exchange information with Member States on best practice and needs for risk assessment. http://www.efsa.europa.eu/en/scer/scernetworks
Outputs: Yearly meetings + Annual reports: http://www.efsa.europa.eu/en/publications/advanced-search/?sub_subject=63551
Contributors: 19 EU Member States, JRC, EU research (NanoDefine, NanoFate), DG SANTE, ECHA, EMA
42
Possible future update of the SC guidance:
Pesticides formulation and implementation of the Novel food legislation (central applications for EFSA)
Address the issues of solubility and of soft nanomaterials (enhancing bioavailability)
43
THANKS FOR YOUR ATTENTION
Acknowledgement
Maria Vittoria Vettori (feed)
Paolo Colombo, Ana Rincon (food)
Frederica Lodi, Anne Theobald (FCM)
Wolfgang Gelbmann (NDA)
Andrea Terron (PPR)
Tom Meyvis (ApDesk)
Ruud Peters (RIKILT) & Karin Aschberger, Hubert Rauscher (JRC)