Assessment of the Regulatory Framework Related to Using Insects as Food and Feed
This presentation was given at the Entomological Society of America 2017 Southwestern Branch Annual Meeting.
Here are the slides…
It is important that insect processors and consumer goods companies have information about where there insects come from. I put together a questionnaire to help facilitate a dialog between the insect supplier and customer. It will also serve as a record.
Here is a link to the Word doc: Edible Insect Farming and Processing Questionnaire
Edible Insect Farming and Processing Questionnaire
- Describe the current Good Manufacturing Process (cGMP) used at the facility
- Describe the sanitation procedures
- Insect contact surfaces and equipment cleaning
- Environmental monitoring
- Are the insects clean and wholesome? Explain.
- Do they contain any external waste
- Are the insects raised specifically for human consumption
- What are the technical specifications of the product? Please attach a specification for each requested product.
- Protein content
- Please attach a pictures of the finished good including packaging and labels
- Describe the facility security
- Describe the rearing process
- Do you rear insects yourself
- Describe the feed.
- Feed ingredients
- Describe the housing
- Size(volume) per housing unit
- Surface area per housing unit
- Number of crickets per housing unit
- Are the insect treated humanely. Explain.
- Access to food
- Access to water/moisture
- Freedom to exercise instinctual behaviors
- Monitoring frequency
- Describe how the insects are harvested
- How are live insects separated from the remains
- Slaughter process
- Describe the storage conditions
- Describe the further processing
Let me know if I missed any questions.
UPDATE: added a third and fourth reference.
Fourth: Food Navigator article that includes the standard response and additional follow up questions.
Third: A power point from by the director of the National Institute of Food and Agriculture (NIFA) Dr. Sonny Ramaswamy.
Here is the LINK. (the file is from Ben Guarino’s Inverse article.)
The first is courtesy of Andrew Brentano of Tiny Farms. Tiny Farms has an excellent forum, Open Bug Farm, that covers a wide range is topics on edible insects.
I attempted to secure my own copy by messaging the FDA’s Food and Cosmetic Information Center (FCIC). The first response did not have much content so I sent a follow up note.
My interest in getting a copy came from the IFT (2015) panel discussion on edible insects. One of the speakers, who is from the FDA, mentioned that there was a standard response for edible insects. The key points he mentioned were on point with the letter Andrew received.
The response I received was slightly different and didn’t have some of the same key points.
Some follow up questions I have from the letters:
- Why don’t they match more consistently in content and language?
- Why must insects be raised specifically for human consumption? Corn is diverted all over the place.
- What is the basis for disallowing wild crafted insects? I feel its no different than trolling for shrimp.
- There is no mention of needing a GRAS determination.
- Whats the definition of ‘Exotic Food’ and why does it matter? This is the first mention of ‘Exotic Food’ I have seen. Its not in any regulations.
Please share any letter or response you have received.
Be in touch on Twitter at Bob the Cricket
I have been blogging about government regulations in the US on edible insects. Current thinking is the the FDA/regulators will not press edible insects companies to stop making products. US Regulation
Today’s post will discuss the risk of consumer litigation for edible insect businesses.
Edible insect producers could experience class action law suits or individual lawsuits. The plaintiffs would need to prove damages and prove causation of injury. The legal structure of your business will affect your liability.
Is the FDA involved in consumer litigation? What can occur is that the FDA can send a warning letter… FDA Warning Letter to KIND via Food Navigator
Top 4 concerns for consumer litigation related to edible insects.
- Physical hazards – For example, dry roasted whole cicadas can be a choking hazard. Legs/exoskeleton can get caught in ones throat. It would probably not cause full obstruction of the airway. Objects that are round and the same size of the airway are more likely to cause blockage. A stuck leg could cause other foods to get stuck also. See The American Academy of Pediatric Policy Statement on choking prevention. I feel a choking hazard warning is not needed. If a piece of insect gets trapped in ones throat and doesn’t go away then, I recommend that the consumer seeks medical attention to have it removed. Very annoying but not likely to cause long term harm.
- Asphyxia– Insect are a potential food allergen. More info on insect allergens.
- Antinutrients – Not well studied and would be difficult to prove harm.
- Claims –
- Nutrient claims – The nutrition facts panel of a processed food need to be accurate. One of the benefits of edible insects is the protein and mineral content. Nutrient contents of insects can vary greatly by species and how they are grown, harvested and processed. Accountability falls to the consumer goods company and not the suppliers or manufacturers. Front of package claims must be in line with regulations. FDA’s Food Labeling Guide
- Animal welfare – We know that cricket can be cannibals if they don’t have enough space or food. How can we qualify that the crickets are being raised and harvested humanely?
- Sustainability – Companies often promote environmental benefits on their website as a key feature of their product. Do insects meet third party standards for sustainability? Report Debunks Walmart’s Claims of Sustainability and Fairness in Its Food Supply Chain
The best way companies can manage risk from consumer litigation is to use an allergen warning. Secondly, any claims must be supported with data and documentation.
Did I miss anything? Should industry be using a choking hazard for whole orthoptera products?
Let us know in the comments.