The cricket parathas were removed. After health authorities tested two106 of the uncooked crickets for bacteria (as with any meat, the bacteria were there), there followed some polite back-and-forthing and then instructions from health inspectors to cooks for the handling and preparation of raw insect meats, at which point the parathas were put back on the menu. They remained there until the fall of 2011, at which time they were again removed. Dhalwala’s plan, as she stated in a 2015 interview, was to reintroduce insects, but soft-peddle them until the customers got used to them.
If Canadians and Australians were soft-peddling their wares so as not to startle customers and health authorities, the latter being particularly susceptible to negative reactions, then the European entomophagists faced more complicated challenges. Some of the biggest ones stemmed from what might appear to be an entirely unrelated set of historical events.
In 1994, in the turbulent wake of the mad cow (BSE) storm across Europe, the European Commission banned the feeding of processed animal proteins (PAPs) from mammals to cattle, sheep, and goats. These proteins — essentially offal and other “waste materials” from slaughterhouses — had been added to the feeds of young pre-ruminants before their rumens developed, and thus before they could digest hay. The extra protein enabled them to grow faster and, in the long run, use less food. Before BSE, this recycling of slaughterhouse waste seemed to represent industrial ecology at its most efficient.
After scientists reported that BSE (bovine spongiform encephalopathy) and related transmissible spongiform encephalopathies (TSEs) were spread by ingestion of meat, especially nervous tissue, from infected animals, a ban on these PAPs made sense as a way to stop the spread of the disease.
In January 2001, afraid that there might be cross-contamination between foods intended for farm animals and those intended for dogs, cats, and other non-ruminants, the ban was extended, now excluding PAPs from all farmed animals. Fishmeal was the only exception. Nobody was thinking about insects. They had bigger issues on their minds: mass slaughter of cattle, trade barriers, and farmer suicides, for instance. They had to act — and be seen to act — decisively, if not always carefully.
In October 2015, most EU member states still officially prohibited the selling of insects as food, but there were reportedly no “precise” regulations in place. In the midst of this regulatory ambiguity, tales were circulating in the press of insect sightings in supermarkets in the Netherlands (insect burgers and nuggets), Belgium (burgers with buffalo worms), and the UK (bags of whole mealworms, crickets, and grasshoppers). In March 2015, Irma, a grocery store chain in Denmark and the second-oldest such chain in the world, announced that it would be selling edible insects. Two days after the insects hit the shelves, they were removed. “The goods are no longer for sale due to an unearthing of the authorities’ views on selling these types of products,” Irma spokesman Martin Hansen told a local radio station.
In Paris, in August of 2015, I heard rumors that authorities in some parts of Italy had pulled insects from a supermarket shelf, but I couldn’t determine whether this was old news (a batch of silkworms from South Korea was rejected by border officials in 2012) or something new. The news from Italy was accompanied by an explanation that honey, royal jelly, propolis, and red dye from cochineal insects were the only officially allowable insect products on the EU market.
Casu marzu, the traditional Sardinian “delicacy” made by allowing fly maggots (Piophila casei) to crawl around in pecorino (sheep’s milk) cheese, and Milbenkäse, a German sheep or goat cheese modified by mites, fell into a regulatory gray area and seemed to be allowed but only in certain jurisdictions.
In 2014, the Belgian Federal Food Safety Agency went out on a bureaucratic limb and approved a list of ten insects considered safe for human consumption. In 2015, the Belgians asserted that insects for human consumption “appear to offer great potential” as an alternative protein source and acknowledged that breeding and marketing insects was already being tolerated in some parts of the European Union.
The post-BSE food bans were a source of great frustration to Antoine Hubert and the European Association of Insect Producers. The bans meant that although Ynsect could argue that what it was doing made ecological and economic sense, and was in fact encouraged by FAO, they were legally prevented from making the logical step from research and prototype to commercial production. Hubert was also both impressed and annoyed at the way Enterra had used this situation to its own advantage, although Ynsect’s own forays into pet foods and collaborative activities in Singapore and elsewhere demonstrated similarly deft business sense.
There is a long tradition of corporate leaders in the agri-food system railing against, and trying to thwart, government regulation. For those of us who have spent a few decades studying the global pandemics of foodborne diseases, however, it has often seemed as if the regulations were too little, too late, too fragmented, and too much reliant on the smiles and wiles of corporations whose reason for existence, after all, was not to “feed the world” but to make profits for owners and shareholders under the guise of feeding the world.
I would not color the new entrepreneurs at Ynsect, Enterra, and Entomo with the same brush we use on Tyson, Carghill, and McDonald’s, but caution is not a bad thing when regulating a commodity as intimate as food.
The members of the European Association of Insect Producers were simply asking for clear regulations and a fair playing field, rules that would facilitate the entry of transformative, ecologically based technologies into the marketplace. Most of those getting into the insects-as-food business would concur with Afton Halloran and colleagues, who have bravely ventured into the chaotic jungles of insects-as-food regulations where — I am pretty sure, though I cannot prove it — there are mind parasites that kill brain cells on contact. Having emerged from those jungles, the authors — who must have had access to a vaccine against the mind parasites, as they emerged unscathed to tell the tale — assert that the “greatest barriers to the growth of an edible insect sector is the lack of all-inclusive legislation that governs the production, use and trade of insects as both food and animal feed.”
That seems a fair characterization to me. The EU regulations, urgently put into place in the midst of a situation that was driven more by panic than by sober reflection had, at least in retrospect, probably overreached. In fairness, mechanisms to implement the kind of integrative, cross-departmental, interdisciplinary, extended-peer-review approaches that philosophers Silvio Funtowicz and Jerry Ravetz have called post-normal science (PNS), were still embryonic. PNS, Ravetz and Funtowicz argued, is required where “facts are uncertain, values in dispute, stakes high and decisions urgent.” That certainly applied to the BSE situation.
Whatever one thinks of the original decisions, farmers — including those who raise insects — have had to live with them. The question now is how to proceed. Before looking a little more closely at the issues, I think we should consider why regulations are necessary at all. This consideration goes to the heart of what we think of as an ideal society, articulated by Jean-Jacques Rousseau as a social contract, in which citizens collectively constrain their desires in order to master their needs. In this context, the answer to why regulations are necessary goes something like this: if farmers are sending their goods into a system that distributes them around a region, a country, and, increasingly, the world, then those who are sitting down to share a meal with friends need some level of assurance that the food will not kill them, and that the lands and people on which those foods depend are being properly nurtured from generation to generation. Nurturing the lands and people includes fair wages for the farmers, reasonable assurance that the animals are well-treated, and protection against the spread of diseases in the animals and plants that the farmers are producing on our behalf.
If the farmer lives down the lane from me, or sells her produce through a local store, then I can check out her farm and get some assurance th
at way. That local system is built on trust (and keeping our wits about us). The more global systems are also built on trust, but, given the repeated betrayals by corporate leaders who are business-smart but biology-stupid, that trust needs to be expressed through regulations.
When parts of the food system are expanding rapidly, all kinds of people get into the business. Some opportunists see quick profits. Explosive growth in hamburgers, ready-to-eat salads, almonds-as-health-food, and chickens-as-lean-protein were all accompanied by epidemics of bacterial and viral diseases — think E. coli, Salmonella, bird flu. We have no reason to believe that insects are immune to spreading diseases; in fact, the entire focus of international and national regulations regarding insects to date has been on discovering how they can spread disease and how to prevent them from doing so. This creates serious challenges for introducing insects as human food.
A friend of mine who runs an open-air café and bakery received repeated visits from public health inspectors who were concerned about some flies in his kitchen. What if they landed on the pizza? They would be cooked, of course, and, although aesthetically disturbing, they would not be a public health hazard. But what if the pizza itself had an insect topping? What would this do to all the standard public health and food safety rules we have so diligently constructed over the past few decades?
Regulations governing agriculture and food have emerged from agriculture, health, and food-safety advocates — groups that don’t often speak to each other. These regulations are furthermore a mixture of local, regional, and global. The regulatory situation is, to understate the case, a bit of a mess.
On August 10, 2015, the morning after having sampled larvae and locusts at le Festin Nu in Paris, I walked the few kilometers to the offices of the OIE (World Organisation for Animal Health), where I had an appointment with Brian Evans, Canada’s former Chief Veterinary Officer, now the Deputy Director General of the organization. The OIE has devoted pretty much its entire existence to controlling or eradicating diseases and pests that affect animals that are not insects. From its perspective, insects have generally been viewed as a problem, not a solution. Since some of the countries who are members already trade insects across their borders, I wanted to ask Evans if the idea of insects as food animals — rather than as pests and disease vectors — was anywhere on their radar. Short answer: no. Longer answer: sort of.
The “sort of” applies to bees, which may provide precedents for regulating other insects. Beekeeping has become big business; this is mostly related to pollination services for monoculture crops (almond orchards, canola, and the like). Honey is often a sideline commodity for pollinators, but some parts of the honey business are worth hundreds of millions of dollars. One of the fastest-growing markets unrelated to pollination services is for manuka honey, produced by bees that get their nectar from Leptospermum scoparium and sold for its medicinal value.
Given the global size of the pollination and selected honey markets, bees have had better public relations departments at their disposal than other insects. The OIE does have a list of diseases affecting the western honey bee (Apis mellifera) and the eastern honey bee (A. cerana) in its Terrestrial Animal Health Code. This code requires countries to report occurrences of named diseases. These include bacterial diseases such as American (Paenibacillus larvae) and European (Mellissococcus pluton) foulbrood and various mites. Even for bees, however, the general system of regulations is a hodgepodge of national and local rules, usually depending on the goodwill of apiarists and their willingness to let their competitors and neighbors know if they are encountering disease problems. I will let you, dear reader, imagine how likely that is.
Beyond bees, there appears to have been mostly whispering, arm-twisting, horse-trading, and reports summarizing what little research there is, inferring about bugs from research on other animals. In 2015, even as FAO was encouraging the production and use of insects in food and feed, the OIE had no codes that would cover diseases such as the deadly cricket paralysis virus described by Australian researchers in 2000, the Acheta domesticus densovirus that decimated the North American cricket farmers in 2009, or Linepithema humile virus 1 and deformed wing virus, associated with bee mortality and carried around the world by invasive Argentine ants.
FAO is concerned with food and agriculture. The OIE is concerned with diseases of animals, mostly farm livestock. So who deals with the food safety and public health issues? Theoretically, that would be the World Health Organization, through its Department of Food Safety; that department, however, has tended to focus on tracking epidemics of diseases as they occur in human populations and estimating the burden of foodborne diseases after the fact. One obvious place to direct global questions about insects as food would be to the Commission of the Codex Alimentarius, or “Food Code.” Codex was established by FAO and the World Health Organization in 1963 to “develop harmonised international food standards, which protect consumer health and promote fair practices in food trade.” Compliance with the standards, guidelines, and codes of practice recommended by the 187-member commission is voluntary, but they carry considerable force, being cited in the World Trade Organization agreements, for instance.
In 2012, at the seventeenth meeting of the Codex Coordinating Committee for Asia, Lao PDR, supported by Cambodia, Thailand, and Malaysia, proposed that food standards be developed for edible crickets. The proposal was not ratified. At the time I am writing this (late 2016), insects are mentioned in the Codex only insofar as there are allowable limits of insects or insect parts in other foods.
The Codex treatment of insects reflects the official practices of its national members and is in keeping with organizations such as the FDA, which establishes “maximum levels of natural or unavoidable defects in foods for human use that present no health hazard.” The FDA publishes a list that includes such line items as apple butter, with five or more whole or equivalent insects (not counting mites, aphids, thrips, or scale insects) allowed per 100 grams of apple butter; frozen broccoli, with an average of 60 or more aphids and/or thrips and/or mites per 100 grams; and green coffee beans, where an average of 10 percent or more by count are insect-infested or insect-damaged. According to its website, “the FDA set these action levels because it is economically impractical to grow, harvest, or process raw products that are totally free of nonhazardous, naturally occurring, unavoidable defects. Products harmful to consumers are subject to regulatory action whether or not they exceed the action levels.”107 The FDA has a category of foods designated as GRAS (Generally Recognized as Safe); by late 2015, no insect-based foods had been approved under this designation. Nevertheless, the Massachusetts Department of Public Health did approve cricket chips for sale in grocery stores, and the FDA allows the sale of insects to people as food as long as the insects are farmed, not caught in the wild. Bottom line: the regulations are unclear.
In 2015, the tectonic regulatory plates shifted slightly. The European Food Safety Authority (EFSA) is an advisory group to the European Union. On October 8, 2015, the EFSA Scientific Committee published a “Risk Profile Related to Production and Consumption of Insects as Food and Feed,” in which they concluded that “for both biological and chemical hazards, the specific production methods, the substrate used, the stage of harvest, the insect species and developmental stage, as well as the methods for further processing will all have an impact on the occurrence and levels of biological and chemical contaminants in food and feed products derived from insects. Hazards related to the environment are expected to be comparable to other animal production systems.”108
Shortly afterwards, expecting the European Union to act on the report, Spanish authorities announced that they expected to lift the ban on marketing insects for human consumption. On November 19, 2015, the European Union put into place regulations with regard to new and innovative sources of food, which included insects, algae, and cloned meat. Nevertheless, the new regulations required that producers of such “novel foods
” (and yes, there is a definition of those) submit a full dossier to the EU authorities demonstrating the benefits of their products.
Antoine Hubert, speaking on behalf of the International Platform for Insects as Food and Feed (IPIFF) said that those applying the new regulations on novel foods needed to look at ways to reduce the “administrative burden and the costs” for cash-strapped insect breeders.109 When I had visited him in August 2015, his best-case scenario had been that the European Union would simply put insects into the exemption clause enjoyed by fishmeal. “Novel foods” was a kind of Plan B. Still, it opened the doors.
As we pondered the issues surrounding insect diseases, Brian Evans and I at the OIE shifted to the more general issue of what are called emerging infectious diseases. We agreed that everybody pretty much knew, based on decades of research, the driving forces that caused the emergence of the diseases that plagued humanity and our animals, and that the answers lay in addressing issues like land use, economic disparities, city design, and energy use and rethinking how food was produced and distributed. We also agreed that most global organizations would rather not think about these “political” causes of disease, preferring to focus on vaccines, drugs, and other short-term money-makers. The same issues apply to preventing and regulating disease spread through insect foods and feeds.
The regulatory wrangling in the European Union is about setting up food safety and quality assurance guidelines within their member countries. Nevertheless, it also has implications for trade, and for rules within the World Trade Organization and the Codex. These implications are very important for the businesses that are trying to find economically viable ways to get insects into the food system. I don’t dispute any of that.
What has emerged quite clearly for me, however, is that no matter how clear and flexible the entomophagical regulatory framework we design is, it will never, by itself, achieve the promise of a globally sustainable, insect-based agriculture and food system. Necessary? Yes. Sufficient? No way. The regulations and policies are important in that they help us make explicit some of the issues we are collectively concerned about. They also push us to consider how we might deal with those really important, left-out things: gender, equity, animal welfare, compassion, and, perhaps, somewhere in there, that “love you forever” thing.
Eat the Beetles!: An Exploration into Our Conflicted Relationship with Insects Page 25
