Legal barriers in the EU and other countries for using black soldier fly larvae as feed for farmed animals
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TOPIC: Legal barriers in the EU and other countries for using black soldier fly larvae as feed for farmed animals

Legal barriers in the EU and other countries for using black soldier fly larvae as feed for farmed animals 14 Mar 2014 15:15 #7802

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This thread has now been broken off this thread to provide a clearer structure:
forum.susana.org/forum/categories/91-pro...-company-agriprotein


+++++++++++

We also had a discussion about legal barriers to commercialisation of the black soldier fly larvae production as animal food.

You can listen to the discussion about this issue here:

youtu.be/dKE7OSz5VKM?t=15m40s

If you can't use Youtube then I have attempted to write it out below for you:

I asked: Where are we at in terms of commercialization of this technology? (it always sounds promising but it nevers seems to go anywhere - what are the barriers? Is the company in South Africa making a profit yet? Or are they still piloting?)

Answer by Ian: "The people in South Africa who are working on it are BioCycle. They have up and running a pilot plat - a proof of concept pilot plant, which is using faecal matter from bucket latrines and pit latrines, and processing it on site there. There is still more work to be done to get a safe end product - before it can be rolled out into rural areas to ensure that there is no transmission of disease or any other problems. So there is still works that needs to be done. But it’s not far off. I think in the next couple of years it will take shape a lot more."

Answer by Björn Vinneras (youtu.be/dKE7OSz5VKM?t=17m22s): "BSF larvae are classified as a “production animal”. There is the constraint in EU legislation with insects considered to be production animals, and therefore not to be consumed by other animals. It’s forbidden currently to feed a production animal (this includes insects) to other farmed animals. But there are lobby groups working on changing this, as it does not really make sense to apply this rule to black soldier fly larvae."

Further information by Björn in an e-mail:
We (Swedish University of Agricultural Sciences) have an EU project together with EAWAG and Pacovis (a Swiss company). The production animal part is a several step thing in the Animal Bi Product Regulation, summing up at they are production animals, and therefore ruled out. I think it was just a coincidence that it turned into this and nothing planned when the main part of the text were written in the early nineties, to tackle the mad cow disease.

Link to Björn’s previous posts on this topic:
forum.susana.org/forum/categories/91-pro...al-sludge-management

Answer by Hakan Jönsson (youtu.be/dKE7OSz5VKM?t=18m28s):
Agreed with Björn. This is one important reason why no commercial production of BSFL has taken place yet in Sweden.

Answer by Stefan Diener (youtu.be/dKE7OSz5VKM?t=19m02s):
In addition to this, one is not allowed to feed “waste” to farmed animals under the present legislation in the EU (larvae would be regarded as farmed animals because they are "production animals"). This is another barrier to the take-off of this technology.

Nelson asked Ian whether in South Africa the same restrictions apply?

Answer by Ian (youtu.be/dKE7OSz5VKM?t=19m53s): "There are still some restrictions in South Africa regarding what the larvae and farmed animals can be fed (due to the issue of prion transmissions). The company Agro-Protein has a licence for producing "Mag meal" (animal feed made out of black soldier fly larvae made out of maggots). The restrictions are slightly less than those in the EU but I don't know all the exact details."
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Last Edit: 26 Mar 2014 12:33 by muench.

Re: write-up from webinar 6 - black soldier fly research by Ian Banks 14 Mar 2014 17:51 #7804

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Hmm, would aquaculture fish that have been fed with BSF larvae (in a country that allows it) be banned from import into the EU because of the above mentioned legal restrictions?
Krischan Makowka
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Re: write-up from webinar 6 - black soldier fly research by Ian Banks 17 Mar 2014 09:14 #7839

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JKMakowka wrote:
Hmm, would aquaculture fish that have been fed with BSF larvae (in a country that allows it) be banned from import into the EU because of the above mentioned legal restrictions?


Sorry for bringing this up again, but it seems to have been missed for the most part...

Import restrictions on developing countries' agricultural produce is already a bad enough problem, thus this is an important issue to figure out before promoting this.
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Last Edit: 17 Mar 2014 09:15 by JKMakowka.

Re: write-up from webinar 6 - black soldier fly research by Ian Banks 17 Mar 2014 09:51 #7840

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JKMakowka wrote:


Import restrictions on developing countries' agricultural produce is already a bad enough problem, thus this is an important issue to figure out before promoting this.


I don't think it is possible to be definitive about the risks of importing a new animal feed to the EU before actually trying to do it.

The European Food Safety Authority assesses sources of animal feed to consider the risks associated with their use in the EU. It would be interesting to know whether they are considering the sources of the feed which is being fed to the fish which is being used in animal feed fishmeal.
I don't work for anyone, I am a philosopher interested to think about how we think about WASH and sanitation. All thoughts are mine alone, I am responsible for any errors.

Previously trained and worked as a Soil Scientist and worked on projects composting sewage sludge.

Re: write-up from webinar 6 - black soldier fly research by Ian Banks 17 Mar 2014 10:00 #7841

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I was actually referring to direct fish imports (Nile Perch & Tilapia for example is a large export from Uganda, and aquaculture is becoming more and more popular here). But you are right, it would just as well apply to fish meal used as fish feed (although as far I I know this is seldom derived from aquaculture so far).

Given the information above, e.g. the current ban of "producer animals" as animal feed I assume the same should apply for imports, which is unfortunate. But as I am not an expert on this topic I would like to hear from the above researcher who seem to have looked into the issue.
Krischan Makowka
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Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein) 17 Mar 2014 12:46 #7845

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I have done a bit more research on this. Although the proceessed animal proteins had been banned, this was lifted for the feeding of fish in June 2013, and this included the feeding of fish with feed made from insects.

I also found this interesting project: proteinsect* - which is an EU funded project looking at the safety of insects as animal feed - both inside and outside the EU.


* Mentioned here on the forum: forum.susana.org/forum/categories/91-pro...ersity-in-accra#4559 (added by moderator EvM)
I don't work for anyone, I am a philosopher interested to think about how we think about WASH and sanitation. All thoughts are mine alone, I am responsible for any errors.

Previously trained and worked as a Soil Scientist and worked on projects composting sewage sludge.
Last Edit: 17 Mar 2014 13:27 by muench.
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Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein) 17 Mar 2014 13:52 #7848

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Great that sounds promising, got a link to that June2013 change?
Processed fish feed is probably one of the most promising applications of BSF on a larger scale both for human and animal waste (chicken, pigs & cows) as it seems the most safe and value and distribution chains already exist. In addition fish meal as a protein source is relatively accepted (and similar to insect protein) and companies are looking for an alternative these days with declining marine fish stocks and considerable public opposition.
Krischan Makowka
Technical Adviser at the Uganda Water and Sanitation NGO Network (UWASNET)
www.uwasnet.org

Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein) 17 Mar 2014 13:56 #7849

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Well it was reported in this Reuters article but I am trying to track down the actual EU rule change to confirm.
I don't work for anyone, I am a philosopher interested to think about how we think about WASH and sanitation. All thoughts are mine alone, I am responsible for any errors.

Previously trained and worked as a Soil Scientist and worked on projects composting sewage sludge.
Last Edit: 17 Mar 2014 13:56 by joeturner.
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Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein) 17 Mar 2014 14:07 #7850

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It is EU Regulation 56/2013 from January 2013: see here

With the exception of fishmeal and compound feed containing fishmeal, which are already permitted for feeding non-ruminant animals, PAP from non-ruminant animals and feedingstuffs containing such PAP should therefore be reauthorised for feeding aquaculture animals. Strict requirements during the collection, transport and processing of those products should apply in order to avoid any risk of cross-contamination with ruminant protein. In addition, regular sampling and analysis of the PAP and the compound feed containing this PAP should be performed in order to verify the absence of cross-contamination with ruminant proteins.
I don't work for anyone, I am a philosopher interested to think about how we think about WASH and sanitation. All thoughts are mine alone, I am responsible for any errors.

Previously trained and worked as a Soil Scientist and worked on projects composting sewage sludge.
Last Edit: 17 Mar 2014 14:08 by joeturner.

Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein) 18 Mar 2014 11:11 #7867

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I have quickly rescanned the discussion above and I don't think this has been mentioned:

Ian Banks has a paper in a recent edition of the academic journal Tropical Medicine & International Health called "Growth rates of black soldier fly larvae fed on fresh human faeces and their implication for improving sanitation" see here.

Apologies if this has been mentioned above, but maybe it will be of interest to others.
I don't work for anyone, I am a philosopher interested to think about how we think about WASH and sanitation. All thoughts are mine alone, I am responsible for any errors.

Previously trained and worked as a Soil Scientist and worked on projects composting sewage sludge.

Re: write-up from webinar 6 - black soldier fly research by Ian Banks 20 Mar 2014 10:51 #7908

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Hi all,
Very interesting discussion.
On legal aspects, you can check on PROteINSECT pages, they made a report on legal issues : www.proteinsect.eu/index.php?id=37
JF Kleinfinger
Last Edit: 20 Mar 2014 10:51 by JFK.

Re: Black soldier fly (BSF) larvae for faecal sludge reduction - research in South Africa (with the company Agriprotein) 20 Mar 2014 11:03 #7909

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Thanks JFK, I saw that report, but for some reason didn't actually read it!

These sections are interesting:

There are several safety risks associated with the use of insects in food and feed that must be considered. Perhaps most significantly, insects pose microbial hazards by harbouring pathogens that can cause foodborne illness. In one study, microorganisms isolated from the body surface and gut wall of the common domestic housefly (Musca domestica) included four pathogenic species of bacteria and fungus (Banjo et al, 2005). Insects may also be unsafe for consumption due to the presence of toxins.


In order to ensure that insects comply with food and feed safety requirement, it is vital that measures are taken to minimise the hazards described here. Microbial hazards can be mitigated through a combination of processing techniques, such as drying, boiling and roasting, and correct storage at refrigeration temperature. Insect toxicity can be eliminated by strictly controlling farming conditions so that sources of chemical contaminants are not present. Allergic reactions to insects are likely to be a rare event but nevertheless labelling of products containing insect protein should warn of the potential risk (Belluco et al, 2013).


The impression given by this report is that although the use of insects in feed is now not totally out of the question in the EU, significant proof would be needed of the safety of processes and, quite possibly, additional EU legislation.

I don't see that the point about the substrate on which the insects are feeding has been addressed directly in this report.
I don't work for anyone, I am a philosopher interested to think about how we think about WASH and sanitation. All thoughts are mine alone, I am responsible for any errors.

Previously trained and worked as a Soil Scientist and worked on projects composting sewage sludge.
Last Edit: 20 Mar 2014 11:10 by joeturner.
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