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Review of U.S. State-Level Entomophagy Regulation 2015

From the International Food Protection Training Institute (Link)

PDF of Review

Review of U.S. State-Level Entomophagy Regulation 2015

Adam Lewis
Agricultural Consultant
Minnesota Department of Agriculture
International Food Protection Training Institute (IFPTI)
2015 Fellow in Applied Science, Law, and Policy: Fellowship in Food Protection

Abstract

This study examined state-level food safety regulatory response to the use of insects for human consumption, or “entomophagy.” Interviews were conducted with state regulatory officials from the 50 states; multiple interviews were conducted in states where regulation of retail and manufacturing of food are carried out by different agencies or delegated to a local agency. The study identified states where insects are sold at retail and the number of insect manufacturers; current regulations; types of insect food products; regulatory challenges regarding manufacturing facilities; and perceived food safety risks. Twenty states either reported receiving inquiries related to beginning an entomophagy-based business within their state; had previously regulated entomophagy facilities; or currently regulate entomophagy at the manufacturing or retail level. However, while the Food and Drug Administration (FDA) has jurisdiction over food being made using insects that is wholesaled and crosses state lines, there is no clearly-defined guidance at present for state regulators from the FDA. The study concludes that present state-level food safety regulation is fragmented, inconsistent, and does not address the current widespread use of insects as food. Recommendations include increased FDA-industry collaboration in order to create an entomophagy guidance document for the successful implementation of a preventive control system in order to provide consistent regulation of entomophagy processing and manufacturing facilities.

Keywords: 50 states, approved source, crickets, food safety, Food Safety Modernization Act (FSMA), guidance document, hazards, insects as food, insects for human consumption, Preventive Controls for Human Food (PCHF)

Background

People throughout the world have been eating insects as a regular part of their diets for millennia (van Huis et al., 2013, p.1). More than 1900 species are regarded as edible, including beetles, caterpillars, bees, wasps, ants, grasshoppers, locusts, crickets, cicadas, leaf- and planthoppers, scale insects, termites, dragonflies, and flies (van Huis et al., 2013, p.1). The benefits of entomophagy include utilizing a nutrition source that is high in calcium, zinc, and iron; environmental friendliness (e.g., requiring 12 times less feed than cattle to convert feed into the same amount of protein); and economic benefit, as the cost of start-up is significantly less than traditional farm-raised animals (van Huis et al., 2013, p.2).

Insect food producers are currently regulated by the FDA using Good Manufacturing Practices (GMPs) (Halloran & Munke, 2014); however, these GMPs are subject to a variety of interpretations. The FDA has published guidance documents and provided regulations for seafood and juice processors incorporating hazard analysis and critical control point (HACCP) principles which provide industry and regulators with consistent, sound scientific evidence to ensure the product and process is safe. However, the FDA has not provided guidance for insect food processors.

The Food Safety Modernization Act (FSMA) Preventive Controls for Human Food (PCHF) rule is now final (U. S. Food and Drug Administration [FDA], 2016) and uses HACCP-based principles that food facilities must follow unless the facilities are covered by an exemption. If not, the firm has the responsibility for: conducting a hazard analysis, preventive controls, monitoring, verification, corrective actions, and making corrections. Farms are exempt from the preventive controls rule unless raw agricultural commodities (RACs) are changed into a processed food. The FDA identifies multiple activities that change an RAC to a processed food, including slaughtering of animals and freezing. Insect farms would be exempt from the new FSMA PCHF rule unless facilities are slaughtering insects, freezing them, or conducting activities that would change the product into a processed food. FDA is developing guidance documents addressing the following: hazard analysis and preventive controls, environmental monitoring, food allergen controls, and validation of process controls. However, no guidance document currently exists for insect processors despite the fact that insects are rich in nutrients and moisture, and provide a favorable environment for microbial survival and growth (van Huis et al., 2013, p.117).

Problem Statement

At present, there is no comprehensive description of the state regulation of the processing and sale of insects for human consumption.

Research Questions

  1. What types of insects are most commonly being processed and consumed for human consumption?
  2. What types of foods are produced using insects?
  3. What are the challenges associated with the regulation of insect-processing facilities?
  4. What are the food safety risks related to insect processing and consumption based on the current understanding of state food safety regulators?

Methodology

A telephone survey of state agriculture and local health officials was carried out using the Directory of State and Local Officials (Association of Food and Drug Officials [AFDO], 2015). An introductory e-mail provided the subjects with thirteen questions to be asked in the telephone survey. Eight questions focused on the subject’s regulatory framework and five questions related to the regulatory process. Responses to the survey questions were analyzed to address the four research questions above.

Results

All 50 states responded to the survey. Twenty states indicated that they had either received inquiries related to beginning an entomophagy-based business within their state; had previously regulated entomophagy facilities; or currently regulate entomophagy at the manufacturing or retail level. Six of the 20 states were currently regulating crickets or cricket products using Good Manufacturing Practices (GMPs) (see Table 1). Two of the 20 states had previously regulated cricket entomophagy products using the GMPs (Louisiana and Utah); nine of the 20 states had received inquiries related to cricket entomophagy (Alaska, Idaho, Maine, Michigan, Minnesota, South Carolina, Texas, Vermont, and Washington); and two states (Arizona and New York) reported currently regulating entomophagy at the retail level.

Several responses to the survey questions illustrate the diversity of regulatory experiences related to entomophagy. A Montana regulatory official stated, “There has been talk and phone calls about insects for human food, and we have seen insects used for human food that fall under our temporary food exemption.” An Arizona regulatory official said, “The State Fair is primarily where insects for human consumption are offered for sale, and the insects used at the State Fair are primarily from California. There are also numerous retail stores selling packaged entomophagy products including novelty items such as lollipops with an edible insect such as scorpions inside of the lollipop.” From Kansas, a regulatory official commented that “There was a startup for mealworm flour, and at this point the start-up operation falls under the cottage food retail exemption.”

The widespread nature of entomophagy is illustrated by two manufacturers: Chapul and Exo. Chapul produces cricket bars using cricket protein powder that is dairy- and soy-free. Exo produces protein bars using cricket flour and claims that the bars are all natural, dairy-free, gluten-free, paleo-friendly, soy-free, and contain 10g of protein. These two companies distribute products to 42 of the 50 states, primarily to retail establishments (Exo, n.d.; Chapul Bars, n.d.).

All of the states using the GMPs (or a modified form of the GMPs) to regulate entomophagy facilities identified crickets as an ingredient, or sold as a whole insect as shown in Table 1.

alewis-figure-1The potential size and evolution of large producers is illustrated by two other manufacturers: Big Cricket Farms in Ohio and Aspire, located in Texas. According to its website, Aspire has the capacity to process up to 7 million crickets on a weekly basis (Aspire Food Group, 2016). Big Cricket Farms, whose mission statement starts with “To drive the edible insect industry forward” also raises crickets specifically for human consumption; the company bills itself on its website as “the first American insect farm to obtain food-grade certification from their state Department of Agriculture and the FDA.” The firm raises Gryllodes sigillatus, a.k.a. the Tropical Banded Cricket (Big Cricket Farms, 2014). An Ohio regulatory official who has been to the facility identified jurisdiction as one of the biggest challenges in regulating insect facilities, as the Ohio Department of Agriculture does not have jurisdiction until the crickets are dead—in effect, after an important part of the manufacturing process has already taken place.

California was the lone state in the survey to regulate products other than crickets or cricket products using the GMPs. A California regulatory official identified insects in hard candies such as ants and scorpions (which are regulated under the GMPs) and chocolate-covered grasshoppers during the interview. Products found on the website of California’s Hotlix Candy Store include ant wafers and whole crickets flavored with bacon and cheddar, sour cream and onion, and salt and vinegar. Worm snacks were also offered in BBQ, Mexican spice, and cheddar cheese flavors (Hotlix Candy Store, 2015).

During each interview, state representatives were asked to identify challenges related to regulating entomophagy facilities. Table 2 shows what challenges were identified for all states participating in the survey. Approved source, understanding the process, and understanding the hazards accounted for 66% of challenges identified. Of the six states indicating that entomophagy regulation was occurring and applying the GMPs in Table 1, ten responses to challenges were noted. The challenges identified (from the states listed in Table 1) included understanding the process (40%), determining approved source (20%), understanding the hazards (20%), the unknown (10%), and establishing jurisdiction (10%).

alewis-figure-2Of the eight states that regulated entomophagy firms or had previously regulated entomophagy firms using the GMPs, none indicated that any hazards were identified during inspection work. A New York State regulatory official pointed to a 2001 incident where approximately 15 people became ill following the annual Explorers Club dinner in New York City. The primary symptom was burning mouth/throat due to the mechanical irritation caused by the urticating hairs of tarantula. A food prep review found that some of the tarantulas may not have been adequately singed to remove the hairs. The tarantula example illustrates the hazards within entomophagy which could easily be overlooked without scientific guidance provided to industry and regulators.

A Georgia regulatory official shared information received from the FDA that there is a growing body of scientific literature that people who are allergic to shellfish (shrimp, lobster, etc.) may also be allergic to insects either as food or as adulterants in foods.

The FDA has provided e-mail guidance to a Pennsylvania regulatory official that states there is no specific FDA regulation that either prohibits or condones the use of insects as food. The Food, Drug, and Cosmetic Act requires food products to be “fit for food” (FDA, 1938). In general, “fit for food” means the product is safe and wholesome and does not present a health hazard. Firms, not the FDA, must determine if this is the case and FDA’s role should be to oversee that firms meet this charge.

Conclusions

Entomophagy regulation lacks national standardization and existing regulation is fragmentary and often ad hoc. However, entomophagy is found in most states; nationally, the volume of product is increasing. States are currently regulating entomophagy manufacturers using GMPs, which is not a food process- or product-specific regulation. Insect processors may fall under the Preventive Controls for Human Food (PCHF) rules, in which case regulators would rely on industry to provide information related to hazards in the product and process. The PCHF rules will also require manufacturers to identify hazards in their operation and validate and verify control of these hazards based on scientific data. Additionally, the FDA has not provided guidance to state regulators or to industry regarding hazards, processes, and sources. As a result, there is a current and significant need for increased guidance for consistent entomophagy regulation.

Recommendations

The FDA should work with the manufacturers of entomophagy products to provide a guidance document for entomophagy. The guide would be used as a resource for industry and regulators to provide consistent, sound, scientific evidence ensuring the product and process is safe.

An expanded study should be conducted to identify potential hazards associated with the production of insect-based foods in order to assist in the continued effort to achieve a comprehensive description of the regulation and sale of insects for human consumption.

Acknowledgments

I would like to thank Dr. Benjamin Miller, Division Director; Valerie Gamble, Outreach and Delegation Coordinator/Previous Supervisor, and Lorna Girard, Supervisor for giving me the appropriate time to complete this project and for encouraging me to apply to the program. Thank you to the International Food Protection Training Institute (IFPTI) for giving me the opportunity to complete the Fellowship Program and be a part of Cohort V. More specifically, I want to thank the following individuals from IFPTI: Dr. Craig Kaml, Senior Vice President, and Gerald Wojtala, Executive Director, for providing valuable feedback during our presentations and on my journal article and expressing his ideas and suggestions to make our projects successful; Dr. Paul Dezendorf, IFPTI Research Subject Matter Expert, for all of the guidance provided throughout the process and taking time out of his busy schedule to help assist me in the development of my project; Mr. Cameron Smoak, Mentor, for his professional guidance throughout the program; Ms. Suzanne Kidder, Curriculum Delivery Coordinator, for all of the work she has done in providing and setting up the food and lodging accommodations and working with me during the application process; and Ms. Denise Miller, Staff Writer, for making a batch of cricket flour cookies for the Fellows to sample. I would also like to thank all of the state and local officials who participated in the survey. Lastly, I would like to thank my family for all of their support during this process, including my wife Becky, my mother Suzanne, my father Darold, and my sister Gina.

References

Aspire Food Group. (2016). Frequently asked questions about cricket nutrition and farming. Retrieved from Aketta.com Website: http://www.aketta.com/aketta-crickets/faq.aspx

Association of Food and Drug Officials. (2015). Directory of State and Local Officials. Retrieved from http://dslo.afdo.org/

Big Cricket Farms. (2014). F.A.Q.: Frequently asked questions. Retrieved from http://bigcricketfarms.com/faq.html

Chapul Bars. (n.d.). Find a Store. Retrieved from http://www.chapul.com/find-a-store

Exo. (n.d.). Find a Store. Retrieved from https://www.exoprotein.com/pages/store-locator

Halloran, A. & Munke, C. (2014). Discussion paper: Regulatory frameworks influencing insects as food and feed. Retrieved from http://www.fao.org/forestry/39620-04ee142dbb758d9a521c619f31e28b004.pdf

Hotlix Candy Store. (2015). Hotlix candy. Retrieved from http://www.hotlix.com/candy/ http://www.fao.org/docrep/018/i3253e/i3253e00.htm

U. S. Food and Drug Administration. (1938). Federal Food, Drug, and Cosmetic Act FD&C Act: 21 U.S.C. 342 – adulterated food. Retrieved from https://www.gpo.gov/fdsys/granule/USCODE-2011-title21/USCODE-2011-title21-chap9-subchapIV-sec342/content-detail.html

U. S. Food and Drug Administration. (2016). FSMA final rule for preventive controls for human food. Retrieved from http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334115.htm

van Huis, A., Van Itterbeeck, J., Klunder, H., Mertens, E., Halloran, A., Muir, G., & Vantomme, P. (2013). Edible insects: Future prospects for food and feed security. (FAO Forestry Paper 171). Retrieved from Food and Agriculture Organization of the United Nations website:

Black Soldier Fly Larvae – Tasting Notes

Black Soldier Fly Larvae are a leading insect for feed applications. If you have ever seen a chicken eat BSFL, you will know why, the love it! No one seems to be targeting the use of BSFL for food. Let’s answer the question on what they taste like.

EnviroFlight kindly provided samples for evaluation. Please note that their production system is designed for feed applications and not food.

Black Soldier Fly Larvae – Dried, Wholeimg_0009

Aroma – pungent, strong earthy, fishy. In my opinion, the aroma is not very appetizing. In some respects, similar to dry roasted cricket powder. BSLF is fishy vs shrimp-like and is stronger.

Flavor – earthy, chocolate-like, malty, the fish flavor perception is very low, mildly sweet. The taste is a lot better than the aroma.

Texture – the dried whole BSFL have a very soft texture. They mostly dissolve upon chewing. The texture was not chalky.

Black Soldier Fly Larvae – Oil, Crude

The flavor had more pronounced chocolate/malty flavors. The fat was solid at room temperature. When warmed slightly to melt, the color is slightly yellow.

Defatted, milled Black Soldier Fly Meal (much of the fat is removed by mechanic press prior to milling)img_0011

Aroma and flavor was similar to the dried whole BSFL. The dried whole tasted slightly better as the fat portion was not removed. The texture was not chalky.

The powder did not dissolve well in water.

Can BSFL be used as a food ingredient?

The strong aroma and flavor pose challenges for using BSFL as a food ingredient. The preferred culinary use would be to cook fresh (not dried) BSFL. The flavor of fresh is likely a lot milder and more palatable. Businesses harvesting BSFL are also focused on feed applications but that could change.

There are techniques to reduce flavor that can be applied to dried product. Solvent extraction using ethanol or hexane should work. Another is super-critical carbon dioxide extraction. It would be interesting to try these on cricket powder too.

Grasshopper Wild Harvesting Using a Net

Grasshoppers are commonly consumed in Mexico and regions of Africa. However, they are hard to come by in the States. (Unless, you live next to some tall grass and its the right season. Being in Texas, there are plenty of grasshoppers to go around.)

Lets get right to the interesting stuff… what did I catch and what did it taste like!

5 different grasshopper species.

From Phone 308 From Phone 306 From Phone 309 From Phone 304 From Phone 305

Preparation: The insects were frozen then rinsed. They were cooked in butter/oil until they changed color and held for an additional 2 minutes.

After cooking:

From Phone 318 From Phone 314From Phone 315 From Phone 317 From Phone 316

Flavor

The flavors were very mild. They have a brothy flavor that is sort of like vegetable broth but non-descript. They didn’t taste like any particular protein or vegetable. The closest flavor I can think of is seaweed with a little bit of asparagus. I tried just 3 of the varieties and they were all similar in flavor.

The textures were pleasant. The exoskeletons broke down upon mastication. They were pretty dry; not a meaty texture.

How and where the insects were harvested:
Choice of Net

There are two main types of nets used by entomologists (Texas A&M video on nets). The aerial net and the sweep net… I choose the somewhat DIY way. I picked up a heavy duty leaf rake for pool cleaning and the local department store. The big advantage, it turns out, was the 8 foot pole!

insect grasshopper net pool entomophagy

It worked well as is. Once a grasshopper was in the net I just grabbed it and put it into the jar. I could only catch one at a time this way. Im thinking about cutting open the bottom of the net and adding netting from a mesh laundry bag. It would make it more difficult for them to jump back out (yes, this happened a few times).

Location

From Phone 296

I found a nice patch of uncultivated lane ‘behind a gas station’. The grass varied in density, type and height. The best spots were where the grass was dense and near a ravine. I knew I found a good spot because they were pretty loud.

Season

I set out in the early afternoon on a hot Texas day in August.  I probably should have waited until the evening as they are less active when the temperature drops. My understanding is that they are less active in cooler temperatures. The large ones can fly up to 20 feet making them really difficult to catch.

What I learned from the Eat Insects Detroit conference

Eat Insects Detroit was the first conference in North America solely dedicated to edible insects. It was held at Wayne State University from May 20-28, 2016.

Consumer Perception:

Improving consumer perception is a huge area of focus.

Only about 30% of the people polled in North America were willing to try edible insects. I took away 2 main hurdles.       stats

Consumer perception is that insects are not safe to eat. They largely associate insect with pests. The general public is not aware of how insect are farmed, processed and used as food. The lack of knowledge leads to the consumers feeling that the products are unsafe. They also don’t know that humans have been eating insects for thousands of years. How can this obstacle be address? Little Herds and educational groups are doing a great job educating people about the benefits of eating insects. A key message for consumers is that insects are just like any other food we eat.

The other hurdle I would like to mention is taste. One study (I don’t believe it is published yet) reported that people did not want to eat insect because they taste bad, even though they never have tried them. Insects do have their own unique flavor that people may be unaccustomed to. Who can people trust? Chefs are a great resource for the industry. People would be relatively more comfortable eating insects at a local restaurant that they have been at before and enjoyed their food. Chefs know how to make food taste great. Startups should get chefs involved with their product development to ensure the flavors are balanced and have just the right amount of seasoning.  The #1 deciding factor for why people choose what to eat is taste. If it doesn’t taste delicious, people won’t want to eat it.

Special thanks to ‘The Bug Chef’ David George Gordon for years of excellent work with edible insects.bug chef

‘Insect Cuisine’ as an alternative to ‘Edible Insects‘ was presented by Kiah Brasch. “‘Edible insect’ sounds like they are just barley acceptable as food”. I think ‘insect cuisine’ is great for consumer facing communications. #InsectCuisine!

Regulations

Featured speaker, Ricardo Carvajal, provided an overview of the regulatory frame work in the US. He had a post on his blog from 2013 that really jumped out at the industry. Move Over, Cricket! Lickets: Edible Insects are On the March

His advice was to work with in the current regulatory frame work. More regulations are not needed and should not be wanted.IMG_0919

Ricardo referenced the definition for food from the Food Drug and Cosmetic Act (Title 21 sec. 321(f))

The term “food” means (1) articles used for food or drink for man or other animals

The must be a “reasonable certainty of no harm” according to Ricardo. I searched the Food Drug and Cosmetic Act and did not find this phrase. What it does relate to is the definition for adulterated food in sec. 402.

‘A food shall be deemed to be adulterated… If it bears or contains any poisonous or deleterious substance which may render it injurious to health’

My assessment is that the phrase “reasonable certainty of no harm” is a succinct interpretation of the law.

I felt a collective sigh of relief from the attendee’s after the presentation. There was a general consensus that we don’t need edible insect specific regulations in the US.

Incredible Foods: Sal de CricketIMG_0940

I was signed up as a vendor with Incredible Foods! It was a lot of fun having a booth at the expo. I received a lot of positive feedback on Sal de Cricket. The concept was well liked and everyone loved the flavor. I had samples of seasoned beer cup and also on tortilla chips.

Thank you every one who organized, presented and attended. It was really great meeting everyone.

IMG_0922