Regulatory Status

I have personally contacted the FDA regarding the regulatory status of using “insects” as human food ingredients.  The reply I have been provided was that the FDA had no objections to insects as human food ingredients providing that they were manufactured to be “wholesome” (fit for consumption) and safe from biological, chemical, and physical hazards.  The FDA also stated that labeling must be clear that insects are being used as an ingredient.

In a letter from the FDA to another prospective insect ingredient user, it was stated that the insects must be raised (farmed) for human food use and that insects used for other purposes (e.g. bait or animal feed) cannot be diverted to human food use.

Finally, in an official FDA FCIC letter (Case No. 00048987) the FDA cited that insects as human foods were considered “exotic” foods.  They must be made using Human Foods GMPs.  And, the firm producing these ingredients is responsible for documenting the safety of their product.

Hazards

Biological: As living organisms it is expected that the intestinal tract of crickets has significant microbial presence.  Therefore, whole crickets WILL likely contain microorganisms.

Chemical: The main source for chemical hazards comes from the cricket feed.  The source of the feed must be assessed to ensure its use is “wholesome” and does not introduce chemical hazards (herbicides, pesticides, allergens, etc).

Physical: generally, none.  Whole crickets may contain debris.  Powdered product is ground.  Hard objects in whole crickets will damage grinders.

An extensive risk analysis has been conducted by the European Food Safety Authority (EFSA). EFSA Scientific Committee, 2015. Scientific Opinion on a risk profile related to production and consumption of insects as food and feed. EFSA Journal 2015;13 (10):4257, 60.

Recommendations

Include US style Good Agriculture Practices / Good Manufacturing Practices regarding cricket farming to processing.

Cricket farming must not introduce biological or chemical hazards

  • Crickets used for bait or animal feed may not be diverted to human use.
  • Crickets must be “farmed” and not of “wild” harvest origins.
  • Cricket feed must be free of biological, chemical, and physical hazards.
  • Cricket feed must not contain microbiological pathogens or substrates known to carry such (e.g. no fecal materials, especially human or animal sources.
  • Allergen containing feeds must be verified to not be present in crickets.
  • Physical hazards are not generally of concern.
Cricket harvesting must not introduce biological or chemical hazards

  • Whole crickets are expected to contain natural microbiological organisms. Presence of human pathogens is rare providing safe and wholesome feed was used.
  • Form harvesting to processing, crickets must be maintained
Cricket processing must not introduce biological or chemical hazards and should be used to control the presence of microorganisms.

  • A heat lethality step is recommended to ensure vegetative microbiological pathogens, if present, are destroyed.
  • Refrigeration, freezing, or drying is required to ensure spore forming pathogens cannot germinate, grow, and produce foodborne illness toxins.
Allergenicity is not known, since this is considered an “exotic” food.  Insect as human food providers should specifically request that commercial products include an allergen notice and method to respond to the manufacturer should they feel they had an allergenic reaction.

Frozen crickets bear label of “raw”; keep frozen.  A Letter of Guarantee should be obtained from the further processor that the “raw” crickets will be fully heat processed.  The final processor should also guarantee that they are sampling their heat treated and dried product for the presence of microorganisms that might indicate hazards for foodborne illness.  (e.g. Certificate of Analysis).

Summary

While cricket and insects as human foods is considered “exotic” in the USA, people have been consuming insects for millennia globally.  Relatively few scientific studies have been undertaken to establish illness data from consuming insects, including allergenicity.

Using Good Manufacturing Practices adopted to the Cricket farming/processing operations is required.  HACCP is recommended and should include a Critical Control Point for heat lethality.  In the absence of specific testing, the EFSA (reference) time of “boiling” for 5 minutes should be used as the critical limit.  As applicable, drying or chilling and cold holding is required to prevent spore former pathogen outgrowth.  Dried product should obtain an Aw critical limit of 0.85 or less.

As a relatively undocumented food item, insects used as human food ingredients, should be watched closely by farmers and processors for emerging data and emerging hazards.  Further traditional food processing by end-users is recommended (e.g. used in a cooked food product).