Woven was represented at the workshop by Nick Rousseau, Managing Director. In addition Neil Whippey of EatGrub participated, so was able to speak directly about the experience of a company making products for human consumption.
The process for submitting to secure Novel Food approval and role of Committee and FSA
The process is:
- Food product company compiles a dossier of evidence and completes application form – submitting to FSA
- FSA gets the committee to review the dossier and assess the risk
- Committee may well go back to food company for additional details or to highlight areas of concern
- Committee ultimately advise FSA on level and nature of risks associated with the food product
- FSA determines how manageable the risks are and what measures should be taken (eg. Labelling)
- FSA submits this to European Commission who will generally agree with assessments coming from the UK
The process can take up to 18m and the cost of an application is £4,000
What is submitted for approval could be either:
- A specific product that contains insect material
- Insect material ingredients
In the latter scenario, a number of companies that use the same ingredients could benefit from a blanket authority. They must use essentially identical ingredients, however all complying with common standards.
The dossier of evidence can be very substantial and must include specific laboratory testing (at a recognized laboratory) that shows clearly the key nature of the product/ingredient that would enable a risk assessment to be carried out. This will include both composition of the insect material plus any contaminants or other materials that might be introduced as a result of the farming method, environment, etc. There will be significant costs in securing this analysis.
In the former case, if a company has a number of products with different insect materials they will each need individual authorization.
The authorization will specify a given set of restrictions on exactly what is accepted – variety of insect, conditions under which it is farmed, processes of manufacture undertaken, etc.. This will depend on the perception of the variables that could be expected to change the risk profile of the ingredient/product.
Situation regarding the current and new Novel Food Regulations
Companies making products with insect materials could apply right now for Novel Food acceptance. Not required, however.
Currently any company can manufacture, market and trade food products in the UK that contain whole insects – eg cricket flour.
From January 2018 it will be required that companies trading with food products containing insect materials submit applications for Novel food recognition, but will still be able to trade during the period during which the application is assessed – can take up to 18m
Particular issues that will affect protein alternatives – particularly food containing insect materials
We had an extensive debate about the fact that a large number of people in the UK (20-25%) are allergic to dust mites and the fact that insect protein will result in an allergic reaction, in some cases potentially very severed in individuals. There is a need for research to understand the nature of this and how comparable it is to other allergens such as crustaceans, agreed standards for labelling to alert consumers, and post market studies to establish the actual impact on consumers from eating insect products.
The research involved needs to be seen to be independent of the businesses involved.
We were able to secure a commitment from the key member of the committee to find a way to balance the risks and opportunities so that businesses will be able to trade with products including insect material.
This raises many serious issues for the sector and for Woven, in terms of how we can support businesses with this. One scenario is for Woven to act on behalf of its members and seek a blanket approval for insect ingredients used in a range of individual companies’ products, so that the cost and effort involved can be shared.
We are keen to hear your views!
Today I attended the FSA workshop on Novel Foods Regulations, with Neil Whippey of Eat Grub. It was a really useful and informative although we came away with some challenges for the fledgling UK insects for food sector (insects for feed was not in scope).
Full report will follow as an in-depth article for Woven members (see membership offer coming out soon).
A few highlights:
- There is a £4,000 fee for applying for Novel Food approval and you have to submit one for each individual product that has a distinct risk profile
- There is scope to secure a blanket approval relating to an ingredient but this would potentially need to be very tightly defined – this could mean multiple companies securing this together, or Woven acting on their behalf, to share the costs
- You can trade now and manufacture, market and sell products with whole insect material. From January 2018 when the new regulations come in you will only be able to continue if you are in the process of working through a Novel Foods application – but this process can take up to 18m and you can trade throughout.
- The potential for insect materials in foods to cause allergic reactions needs research and careful thought. Woven will seek to work with its members and the FSA to ensure that the right balance is struck between risks and benefits and we have secured some champions within the FSA and the committee that advises them, with whom we will maintain a positive relationship.
So, definitely a worthwhile event and further signs that Woven Network is going to be critical if this sector is to succeed in the UK.
Who are the EFSA?
The European Food Safety Authority (EFSA) is an independent EU agency, established after a series of food crises in the 1990s, to be a source of scientific advice and communication on food chain risks. Their workload is set by requests from either the European Commission, the European Parliament, or EU Member States.
This report was requested by the European Commission, and you can read the full text here.
Belgium, France, Iceland and the Netherlands had previously conducted their own risk assessments related to insects as food or feed.
The request came in advance of the EU decision whether or not to categorise edible insects as Novel Foods, and on 25 November edible insects were categorised as Novel Foods. This has imposed new regulations on companies involved in the sector.
The request was presumably also motivated by a lack of data and knowledge regarding edible insects. This was also the conclusion of the EFSA – more data regarding edible insects is needed.
In a nutshell
No significant microbiological risk.
Further research and data generation is strongly recommended.
A number of important recommendations for insect farmers and processors are made.
Most of the potential risks (and potential benefits) are likely to come from the type of substrate used, and corresponding farming and processing practices.
In the format of a risk profile, the report focuses on four main areas:
- Biological hazards (bacteria, viruses, parasites, fungi, prions)
- Chemical hazards (heavy metals, toxins, veterinary drugs, hormones)
- Environmental hazards
More research is highly recommended
See “Recommendations” below.
No significant microbiological risk
When fed on currently allowed materials (not on waste streams), rearing insects is not expected to be any more dangerous than rearing other livestock, in terms of microbiological hazards.
Insects are also much more genetically different from us than other livestock (birds, mammals), presenting a much lower risk of zoonotic diseases. In theory the same should apply for prion diseases such as vCJD.
– Matt Anderson
The hazards associated with rearing insects on waste streams (e.g. kitchen waste, garden and forestry waste, human and animal manure, slaughterhouse waste) need to be specifically assessed.
Hazards are affected by a range of factors
The EFSA acknowledged that biological and chemical hazards are influenced by:
- Specific production methods
- Specific substrate used
- Stage of harvest
- Insect species
- Methods used for further processing
Environmental risks are comparable to other animals
“Hazards related to the environment are expected to be comparable to other animal production systems.”
It is important to note that the EFSA are referring specifically to potential environmental hazards, not potential environmental benefits. Potential environmental benefits include: substituting soy beans, substituting fishmeal, livestock emissions, water footprint, land footprint, and food-conversion efficiency.
– Harold Stone
Collation of existing data
The report pulls together existing data on production, consumption, supply chain, food and feed.
This report confirmed the lack of data regarding the consumption of edible insects. European trends in insect eating can only be estimated from sales of insect products. Other than the inclusion of insects as a category in the EFSA’s own standardised food classification system (FoodEx2), there have so far been limited attempts to acknowledge insects as a food category in Europe.
– Matt Anderson
Findings in detail
The concern is whether bacteria could be pathonogenic to humans (e.g. Salmonella, E. coli, Campylobacter). Unlike poultry and larger animal livestock, these pathonegnic bacteria are unable to replicate inside the insect gut, which reduces the risk.
Substrate choice and processing methods still need to be carefully regulated, and further research is needed.
The report considers the potential transfer of viruses from insects to humans. There is no evidence of a jump having ever occurred.
Humans can act as vectors for some human viruses (e.g. dengue fever) which are able to replicate within the insect. Again however, there is no evidence of this in farmed insects to date.
There is also no scientific evidence for insect virus infections inducing major metabolic changes in insects, that would in turn produce substances toxic to humans.
Further research is nevertheless recommended.
Parasites should not be a problem in properly managed closed farming environments, because they will not have access to all of the hosts needed to complete their life cycles.
The risk of insect-derived prions infecting humans is zero, but there may be a risk of insects acting as vectors for our own prions.
This could be a problem if insects are raised on human or animal derived substrates (e.g. slaughterhouse or sewerage). Further research is recommended into this.
For toxins, the focus is on the substrate used.
For heavy metals, pesticides and biocides, further research is recommended.
For hormones and veterinary drugs, insects should undergo the same testing as other animals.
Allergic reactions to insects can be caused by inhalation or contact, and primarily occur with people who regularly come into contact with insects – e.g. entomologists and fish bait breeders. There have been cases of allergic reactions and anaphylactic shock in humans from consumption.
The potential for allergic reactions cannot be controlled by choice of substrate, as is the case for most of the risks discussed in the report.
The obvious solution, provided the risks assessed through research are not higher than acceptable levels, is to inform consumers of the insect content and potential allerginictiy and/or cross-reactivity of insect-derived products through adequate food labelling.
– Matt Anderson
“Boiling insects for five minutes is an efficient process for eliminating Enterobacteriaceae but not spore-forming bacteria. Thus, storage at refrigeration temperature (5 to 7 °C) is suggested.”
A few minutes of boiling is also recommended before roasting.
The report explores a variety risks associated with semi-cultivation practices (rearing insects in open habitats).
The potential for nutrient-rich fertilizers derived from insect-production waste is also explored.
Farming and processing
Boil and refrigerate, and boil before roasting, to eliminate spore-forming bacteria.
Introduce controlled antimicrobial use for insect farming, keep a close watch on bacterial populations in case resistance develops.
“The adoption of existing waste management strategies should be applicable for managing waste from insect production. Assessment of the individual production systems will determine the precise strategy to be adopted on a case by case basis.”
Ensure the proper management of closed farming environments, to reduce the risk of parasites.
For allergen risks, food labelling “insect content” and “potential shellfish allergy” should be considered.
There is lack of pre-marketing human results and reports of workers’ sensitisations.
On processing, the EFSA found “a lack of information relation to precise details regarding processes used.” Perhaps insect farmers and processors could help provide the EFSA and others with such details.
There is also potentially a lot more to be learned from countries and cultures with histories of eating (and processing) insects.
– Harold Stone
More research (specific assessment) of rearing insects on substrates such as kitchen waste, garden and forestry waste, slaughterhouse waste, and human or animal manure.
Dr Arnold van Huis has also specifically identified a “particular need for research into the water footprint of producing edible insect protein, as there is currently no publication on this”.
– Harold Stone
The EFSA highly recommends further data generation, and identifies the following uncertainties:
- There are no systematically collected data available on insect consumption in European countries;
- The pattern of consumption may only be estimated through sales data of insect product;
- How and to what extent the inclusion of insects in gastronomy and in the product range of food suppliers can impact the general consumption pattern in the population is unclear but holds the potential for a rapid change in future consumption patterns;
- There is lack of consolidated information relating to the magnitude and frequency of managed feeding of insects to farm animals.
- There is a lack of studies on the occurrence of human and animal bacterial pathogens in insects processed for food and feed are very scarce in the scientific literature;
- Insect virus infections do induce major metabolic changes in insects and may produce substances toxic to humans, but there is no scientific evidence for such a case;
- There is lack of information relating to the likelihood of human viruses such as norovirus, rotavirus, Hepatitis E and A being passively transferred from feedstock through residual insect gut contents;
- Information in the literature refers to non-European areas (mostly Asia) and to insects harvested in the wild, and so the risk of parasites can be very different from what is found in farmed insects, with strict control of environmental conditions and substrates applied;
- There is lack of information on the extent to which insects act as mechanical vectors of prions.
- Published data on hazardous chemicals in reared insects in scientific literature are scarce;
- Data on accumulation/excretion of chemical contaminants from the substrates are very limited;
- To date, there is lack of information on the use of veterinary medicines for the treatment of insects to be used for food and feed;
- No information is available on the potential formation of food-processing contaminants during processing insects.
- There is lack of pre-marketing human results and reports of workers’ sensitizations.
- There is a lack of information relating to precise details of the processes used.
- There is lack of information on the environmental impact of different mass-rearing insect productions systems.
Outside of this list the report also seems to suggest further research into:
- The interaction between production methods, substrates used, stage of harvest, species and developmental stage, and methods for further processing;
- Specific assessment of waste stream substrates.
“There are questions about how farming methods could introduce food safety risks, for example, microbiological contamination. It is likely that appropriate techniques will control risks, but as it is a new sector there may not be established good practice.”
Eoghan Daly, The Institute of Food Safety Integrity and Protection (interviewed by Environmental Health News)
“Addressing the European protein deficit through the use of novel feeds is key to ensuring our future food security, so this opinion is a positive development.”
Dr Adrian Charlton, PROteINSECT
“This opinion is an important stepping stone in furthering our understanding of the potential of insects as a protein source It provides valuable insight against which PROteINSECT can continue to communicate our research findings to key stakeholders across Europe and beyond, on production, processing, quality, safety and consumer acceptance around insect protein for animal feed.”
Dr Elaine Fitches, PROteINSECT
“EFSA concludes that the main risks come from the rearing and processing methods and not from the insects … Insects should be allowed in aquaculture.”
Antoine Hulbert, IPIFF