Regulation: The Basics
Question: Hello, I am an environmental health specialist with the Detroit Health Department and also sit on the board of the Southeastern Michigan Environmental Health Association. We are interested in learning more about how cricket farms that are intended for human consumption are regulated. We currently do not have any of these farms in our area, but want to be ready for when we do have one! Can you please tell us who is the licensing authority? Is it the FDA or state or local health department? And does these manufacturers follow CFR regulations or FDA and state food code regulations? Thank you in advance for your help!
Answer:
Thank you for reaching out! Here’re the basics:
- FDA regulates the bugs. They’ve been very specific that they’re looking for food-grade standards to be followed from point of harvest onwards.
- State Department of Health regulates the harvest-onwards, and typically handles licensing unless you state does it at a more local jurisdiction. A lot of my clients will build a food-grade freezing and storage room inside their farms, which they get licensed as either generic food processing facility, frozen food processing facility, or food-grade cold storage, depending on your particular state’s licensing and permits.
- Some larger farms are only concerned about being primary production farms. A lot of them will rent a freezer trailer (that has all its food permits in order) for the harvest. This is also fine.
- Smaller farms tend to do some additional value-added processing (making powder, etc). The value-add work either needs to happen in the food-grade room on-farm or (more ideally) at an off-site food processing facility or commercial kitchen.
- CFR and FDA/state provisions need to be followed. There are a few additional rules for insects specifically:
- Common and Latin name should be in ingredients panel, and there should be a notice about potential sensitivity.
- For years, the common warning was “If you are allergic to shellfish, you may be allergic to insects.” Over time, we’ve seen it emerge much more as a sensitivity than an allergy, so some producers substitute “sensitivity” for “allergy.” Unless FDA updates otherwise, both are fine.
- Common and Latin name should be in ingredients panel, and there should be a notice about potential sensitivity.
- Feed can be an issue.
- Food vs Feed: A lot of insect farmers raise insects for both. If conditions are the same for both, it’s fine. If they use a cheaper, unregulated feed (for example, Lone Star’s fishbait feed), those insects cannot become food-grade. Fishbait feed is unregulated and untested in terms of heavy metals, pathogens, and pesticides, so not appropriate for human consumption. The other feeds (most commonly, Mazuri’s cricket chow) are fine for human consumption.
- If they’re using supplemental wet feed (often carrots, squash, watermelons, etc), they should be pre-consumer food waste, not post-consumer.
- Pathogen Testing: I’ve been in this industry for 5 years, and see a lot of pathogen test results. I’ve never seen any positive results, which is pretty cool. I’ve wanted to try intentionally infecting crickets with various pathogens for years to see if the bacteria can even survive in their environment, but I’m not qualified to do that work myself 😛 That being said, here’s the standards we hew to for protein powder:
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Aerobic Plate Count: <10,000 cfu/g (AOAC)Yeast & Mold: <1,000 cfu/g (AOAC)Total Coliforms: < 100 cfu/g (AOAC)E. Coli: < 10 cfu/g (AOAC)Salmonella: Absent/25g (FDA-BAM Ch.5)Listeria spp.: Absent/25g (FDA-BAM Ch.10)Staph aureus: < 10 cfu/g (AOAC)
- If they’re just farming and freezing, they’re typically selling to a processor, who is typically responsible for the inbound and outbound pathogen testing.
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- Documents submitted for approvals: When my clients go to their state department of health for licensing, I like them to have:
- State-specific forms
- Description of product
- Process flow diagram
- Completed CCP worksheet
- Recall procedure
- FDA-reviewed label (if selling to the public)
Other Resources for Regulatory Support:
National Good Agricultural Practices Program: from Cornell’s College of Ag & Life Science, has great log sheets and SOPs.