Tiny Farms on Regulations, Barriers to Entry, and the Technical Side of Insect Farming

After being virtually introduced by a distant mutual friend, Jena and I hit it off quickly. Owner and brains behind Tiny Farms, Jena was witty, driven, and a joy to speak with. Tiny Farms is a San Francisco based startup working on pioneering smart, scalable insect farming. We hopped on a call to discuss data, crickets, and regulations… to name a few topics. I’ll jump ahead in the story to say I ended the call with a smile on my face, knowing that we have people like Jena working hard on “smart farming” for our future.

Aly: So today we’re going to talk regulation, barriers to entry, and some technicalities of getting into the “cricket business.” Just for our readers, could you explain to me again what inspired your interest in entomophagy?

Jena: Sure! My partners and I were interested in starting a new project around food sustainability. We, at the time, came across Marcel Dicke’s, a scientist from the Netherlands, TED talk about edible insects and we decided to get into the space. Less than a year later the report by the UN FAO about edible insects came out and we knew this would really propel us forward. I think a lot of people were inspired at that time and felt like this was a moment for this industry to move forward, since it had backing from such a large group.

Aly: I know you mentioned that it is a little difficult to get into the [ento] field because of fees, regulations, and other barriers to entry. I’m hoping you can share a little about what you’ve learned regarding the FDA and getting GRAS certified. How has that process been? Let’s discuss the “unknown unknowns…!”

Jena: A lot of that is still unknown [chuckles]. I’m going to read you something that sums up the regulations as it stands right now. So under the Food Drug and Cosmetic Act, we have: 

Aly: What else exists on regulation for insects?

Jena: That’s the gist of it! There’s information on the USDA and FDA websites about Good Manufacturing Practices etc. but there’s so much information that it can be hard to navigate, and none of it is specific to insects. For example, there’s a law that meat, poultry and egg establishments need to be inspected by the USDA, but insects fall outside of these categories. I have heard of cricket farms proactively asking for inspections from the USDA, which I think is a great idea.  Basically, insects are food if we grow them with the intention of using them as food, and there’s no specific regulation as to how we raise them so we have to use common sense, creating our own measures of quality as we go.

Oh, and there’s HACCP – anyone dealing with food production needs to have a HACCP plan to ensure food safety. This involves systematically documenting the processes of the operation with all the inputs etc. and creating protocols for identifying and dealing with any potential hazards, like metal from a machine getting into food, or traceability of inputs in case you get a bad batch of feed or something. I think everybody in the space really wants to go above and beyond when it comes to food safety, which is sensible – we are dealing with a largely stigmatized food and the press has its eyes on us. People have been flailing around looking for “What rules do I follow…” as in any nascent industry. Something that folks have commonly come across is the FDA’s GRAS determination… or Generally Recognized As Safe, which is for food additives and requires that a scientific dossier be compiled, which can cost a lot of money.

Although this was a hot topic among cricket startups for a while, there is growing doubt as to whether it is actually necessary for cricket flour. I think recently, many people have been feeling like cricket flour doesn’t need a GRAS determination because of this part of the Food, Drug, and Cosmetic Act which says [insects] are food. The people making stuff out of insect flour are using whole insects rather than creating a protein isolate from insects. Because of this, the insects should still be recognized as FOOD and not a food additive, which would require a GRAS determination. We’ve gotten very general feedback from regulators in that regard. There’s also a feeling that prodding regulators  for a black and white answer as to whether we need GRAS status, which based on reasonable interpretation of the law we arguably don’t, may not be such a good approach.

What I find interesting about this is that while the Europeans are asking insect proprietors to wait while governing bodies draft some shiny legislation on food insects (due to be finalized within months), we’re leaving it to the likes of Whole Foods to make the call as to whether insects are ready to be consumed by the masses, based on what we can provide for them in terms proof of food safety and adherence to good practices. If they do, and no reason why they shouldn’t, it’ll be a real breakthrough for the industry and I believe will open the door to being able to sell insects pretty much anywhere, in the states at least. Our community is paving the way here, and it’s wonderful to watch … and be a part of!

Aly: So just to clarify – if insects are used as a protein isolate, they do need a GRAS determination. If they are used whole, then they don’t. GRAS certification is only for processed or extracted bits of food.

Jena: That’s how I interpret it…though I admit I’m not a lawyer. But I sure I could easily find a lawyer to interpret it that way haha. But definitely if some process is happening to them and they become something other than whole insects (something extracted) they become a new thing that needs to be GRASsed.

Aly: That’s why I want to write about it though… to start these dialogues and get people talking. I mean… the people forming & interpreting these regulations – how familiar are they with the ento-community? The field is still a bit niche.

Jena: That’s absolutely right. There are obviously a broad range of regulatory bodies we have to deal with, and when it comes to local city regulators and state regulators, you never know how they’ll react when they hear you want you to do, there definitely needs to be more dialogue with these folks while eating insects is new. Blogs such as Bugible are crucial advocacy for our industry, the more we can tell our story, the more likely any given regulator will act warmly toward ento companies, as opposed to shocked and appalled.

But honestly, I’m not too worried about the regulatory issues. There is so much precedent for this [eating insects] all over the world and we are not afraid that crickets are going to harm anyone, unless of course someone is allergic…

Aly: Right. You mentioned earlier that much more work needs to be done in the field of allergen testing. This really made me curious… people who are allergic to shellfish may have issues with crickets… but we’re not certain. What sort of work has been done in this area and what sort of work still needs to be done?

Jena:  I think that [allergen testing] and responsible labeling is one of the most important parts of this. People can be allergic to anything… my husband is allergic to apples and they don’t have an allergy warning. But if it is something serious, like peanuts or shellfish, the issue becomes so much more important. There are several studies that identify a common allergen between shellfish and certain insects, so although the studies might not be specific to crickets, companies are incorporating shellfish allergy warnings on their labels. Labels have been approved by the FDA that say that there may be a cross-allergen with shellfish, but that is more of a safety thing to cover people’s butts since we are not exactly sure. Better to be safe than sorry when it comes to anaphylactic shock! I think our field is so concerned with the opaqueness of regulations that we are ahead of the game – over-labeling… we’re doing pretty well over here.

Aly: I would agree that the community is ahead of the game. So what would the next steps be to obtaining more information about allergens and other unknowns?

Jena: Well the allergen stuff is quite complicated – in general, people don’t know what they’re allergic to until they have an allergic reaction. Allergen testing can be done at the doctor’s, but they’re not testing for any potential allergen but instead only specific, known allergens. Similarly, it’s easy to send off for a lab test of a cricket to find out if it contains the same allergen as tree nuts or shellfish for example, but a complete breakdown of any and all potential allergens is a different story. I don’t think this kind of scientific scrutiny is something that we generally subject our food to. I think what we’ve really got to do, since we’re talking about whole culture of people with little or no history of insect consumption suddenly being offered chapulines casually, is to do our best to collect information from consumers when it comes to allergic reactions, and stay on top of the growing body of scientific literature on the subject.

Aly: Is there more work that needs to be done in the nutrition profiling of different insects? Do we have accurate protein and calorie counts for a majority of the edible insects out there? It seems to me that the research is diverse but spread out here. I know that Next Millennium Farms does some pretty intense nutritional profiling on their products and have incredible depths of information that are still growing on the topic. Do you think this area is relatively well covered or needs work?

Jena:  Well, to get this information it is not that complex. You just need to send samples off to the lab and get your nutritional analysis. There is also published literature by the FAO and others that contain nutrition facts for various insect species. Not too concerned here.

Aly: That’s awesome. So in your opinion, what is the biggest concern of the industry as a whole right now? What areas are we lacking in?

Jena: Honestly, my biggest worry is that someone poisons the well for the rest of us by putting out a bad product or getting bad press for the industry. Other than that, it seems pretty straightforward: Be good, do the right thing, and we should be fine.

Aly: Right on. So if you had a magic wand, what further research would you commission to be done?

Jena: That’s a great question. You know, I might have said something about the health benefits of insects, but that’s so difficult. You hear things in the news that just go back and forth: cholesterol is horrible, then it’s not so bad… antioxidants are trending, then they’re not…. I would like to see more studies on insect health and behavior. Most academic work on insects is about how to kill them, not how to make them healthy and happy like we want our crickets to be. I think it would also be great to see some guidelines for newcomers to the industry, especially around food safety.

Aly: Agreement, all around! I’d like to end with a broader question: what’s next for Tiny Farms? What does the future hold? What can the ento-community do to be helpful?

Jena: Tiny Farms is going to be focusing on making our farms “smarter.” We’re really excited about when we can move on to other insects as well. I really just think it starts with more advocacy. Talk to people outside of your circle and spread the word. It’s already amazing how much we’ve seen interest in insects skyrocket in the last couple of years. A few years ago, people would look at you like you were crazy if the idea of eating bugs came up. But a few short years later, people who we mention it to are like, “Oh yeah, I think I’ve read an article about that!” We actually went to this conference in Canada and the border guard was asking us what the purpose of our visit was and we said, “Oh… it’s kinda funny, we’re doing an edible insect thing…” and the guard responded, “What do you mean? I’ve heard all about that – it’s great.”

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We’ll check in with Tiny Farms in a few months to hear about the progress made! For more information, please visit http://www.tiny-farms.com/