By Dr. Aaron T. Dossey: President, Founder, and Owner of All Things Bugs LLC (a for profit biotech firm) and Founder of Invertebrate Studies Institute (a 501c3 nonprofit).<\/p>\n
Submitted on February 16, 2022, in response to Reference Number: RFI no. 7200AA22R00008 \u2013 CONFIDENTIAL and PROPRIETARY Dr. Aaron T. Dossey To whom it may concern at USAID,<\/p>\n I am\u00a0Dr. Aaron T. Dossey, President, Founder and Owner of All Things Bugs LLC<\/a>\u00a0and chief editor of the foundational textbook \u201cInsects as Sustainable Food Ingredients<\/a>\u201d.<\/p>\n All Things Bugs LLC is the world\u2019s first wholesaler of insect-based food ingredients and one of the top innovators in the insect industry. The company, founded in 2011, develops technologies or every aspect of the industry including: food product development, ingredients and insect processing, insect farming automation and mechanization, insect feed formulation development and is one of very few firms in the world developing insect genomic and genetic engineering solutions for this industry (or food, feed, pharma, vaccines and beyond). We are open to all forms of collaborations and partnerships. You can learn more about our research here:\u00a0www.cricketpowder.com<\/a><\/p>\n Insects are potentially the most efficient and sustainable source of protein on earth, even compared to many plant sources (Dossey, et al., 2016a<\/a>\u00a0;\u00a0Dossey et al., 2016a<\/a>).\u00a0 Insects utilize substantially lower amounts of land, water and feed and other livestocks.\u00a0 They can be grown vertically indoors in buildings in cities (unlike even plant-based protein sources), modularly (to help with disease quarantine etc.), and directly adjacent to or amid population centers and\/or food production factories to substantially limit the need to ship the insect material long distances to where food is produced and\/or consumed.\u00a0 Additionally, many edible insects can be fed with pre-consumer food waste, agricultural byproducts (banana leaves and peels in places like Honduras (Padam et al, 2014), corn stocks, soy hulls, unusable vegetables, etc.) and even grasses, algaes and other materials which cannot be fed productively to other livestock or used as human food. By far the most efficient utilization of farm raised insects is as direct human food ingredients (primarily as a powder, but possibly eaten whole as well). This makes most efficient use of the nutrient cycle \/ food chain, skipping less efficient warm-blooded livestock (cows, pigs chickens) and even fish which all represent a substantial efficiency reduction when incorporated into the human food system.\u00a0 However, in many cases, particularly utilization of insects to feed fish and chickens, they can provide significant improvement over other high protein feedstocks as far as land and water utilization, waste management and overall environmental impact.<\/p>\n The major limitations holding insects back as a major sustainable commodity (from locally to globally) are 1) largely, lack of investment in farming technology and infrastructure to scale up, reduce feed costs (innovation in agricultural byproduct utilization as insect feed) and reduce labor costs, 2) opportunities to market insect powders at large scale to food manufacturers and 3) not enough insect-based food products on the market to help the industry scale and get wider public acceptance.\u00a0 The latter 2 can largely be solved by: 1) government and other investment in insect-based food companies to build infrastructure and develop\/implement automated\/mechanized insect farming (from local to global scale) and 2) major food companies to be incentivized to partner with small insect-based food companies to invest in technology and scale as well as launch insect-based food products under major brands.\u00a0 The latter would substantially improve public acceptance of these products as they would be coming from major well-known and well-respected brands, and that scale would substantially lower the costs of these products.\u00a0 The first barrier, lack of investment in farming technology and infrastructure, would best be solved by investment and partnering of governments and NGOs with small insect-based food startups.\u00a0 Many of us have substantial technologies ready to go but lack the opportunities to build our own insect farms, produce our own products or otherwise implement those technologies at scale. Additionally, government agencies interested in food security and sustainability should engage innovative insect-based food \/ production startups in robust dialogue and offer opportunities to inform governments at all levels as to how insect are a substantially, yet still largely ignored, solution to both issues and offer solutions for many others (including vaccine and pharmaceutical bioproduction).<\/p>\n The following answers to USAID\u2019s proposed questions are hereby submitted to provide advice on the best ways in which organizations and governments can support the insect-based food industry to have the maximum potential positive impact on food security, sustainable agriculture and reducing the impact of human food production on the natural environment and biodiversity. We are submitting this information toward the benefit of food sustainability and food security and to assist in reducing human impact on the natural environment and to reduce biodiversity loss. We do not transfer ownership of this content to any other entity and Dr. Aaron T. Dossey retains all rights to this document and its content. Certain questions may be deleted if we felt we did not have a valuable response, given page limitations.<\/p>\n Insect Production Expertise<\/strong> 2. Do you anticipate expanding your insect-production operation? If yes, to where? 3. Which developing countries have strong opportunities for growth in insect production for animal feed, and why? 4. Where do you see expanding profitable market opportunities for insect-based feed production? 5. Would you be able to implement your technology and\/or your business model in a developing-country context? If not, what challenges prevent you from doing so? 6. Would you be interested in starting or expanding business in a development scenario? If no, why not? And if yes, how? 7. What feed do you currently use for your insect production? How would you source feed for insects in a developing country? Potential Challenges and Solutions<\/strong> 9. What factors do you take into account in your insect species selection process? (Survey of customer need\/preference as related to current and projected marketability; species biomass; production cycle; etc.) 10. If you have encountered the challenges outlined below, what solutions have you tried or do you suggest? 11. What challenges exist for US insect-production companies operating in developing countries? (If you are not a US-based company, what challenges do you face operating in developing countries?) 12. What is your preferred method of meeting new potential partners, and how can USAID\/USDA facilitate these connections? (In person conference? Database? Webinar\/virtual conference?) 13. What regulatory barriers (including the absence of regulatory procedures for insect production, marketing and\/or use) have you encountered, particularly for working in developing countries? 14. What are critical knowledge gaps where research is necessary to improve and\/or scale up insect production for animal feed? 15. What consistent services or resources are required to optimize insect production? (e.g., Waste collection? Electrical access for processing? Water for processing? Access to external markets? Access to local financing? Infrastructure for indoor production?) 16. How could collaboration with a larger global network yield potential technical solutions to issues you currently face? 17. What protocols do you employ to maintain optimum shelf-life in your production line including avoiding and minimizing food\/feed waste? 18. What food safety issues are associated with insect production systems, and how are they mitigated? 19. Are there any other challenges or benefits to insect production farming versus other kinds of farming? Environmental Impact<\/strong> 21. How is your work in insect production contributing to decreased greenhouse gas emissions and\/or improved climate change mitigation? 22. For development of a circular economy production model, how would you identify, aggregate, and\/or treat waste products for use in insect production? 23. What challenges do you face, if any, in your containment procedures for producing both endemic and non-endemic species to avoid habitat invasions from escaped insects? 24. How could insect production practices contribute to ecosystem loss, or other forms of environmental degradation? Primarily by directly displacing other sources of protein and oil in the human food supply.<\/p>\n Potential Benefits<\/strong> 26. How could insect-production projects help meet the GFSS goals: inclusive and sustainable agriculture-led economic growth, strengthened resilience among people and systems, and a well-nourished population? 27. What additional benefits of insect production do you see not typically mentioned in the scientific or gray literature or forums? 1) Low pandemic\/pathogen risk, 2) meat-like flavor, 3) probably more sustainable than even plant proteins, 4) synergistic with developing vertical agriculture, 5) ideal for urban agriculture & farming at food processing plants, 6) promise of genetically engineered insects, 7) quickly replenished.<\/p>\n 28. How can insect production increase opportunities for job creation and business development for American stakeholders? A whole new system of agriculture not already monopolized by wealthy interests.<\/p>\n 29. What type of partnership or funding could help to start an insect production project, or scale up production, particularly in a development context? Would these involve USAID or USDA? If so, please explain. Non-dilutive funding is ideal. Grants are ideal \u2013 or research and\/or facility construction costs and a certain time period of operating costs. This could involve USAID and USDA, as well as other governments, NGOs and philanthropists \u2013 potentially angel investors. Could be a subsidy from USDA to build a facility.<\/p>\n 30. What are the potential benefits of engaging women, youth, and marginalized communities in insect production? What are some of the potential social or economic risks? The focus should first be on creating the opportunity efficiently and establishing market revenue. A failed farm cannot employ anybody. The benefits of including marginalized communities could improve their health and economic status while demonstrating to them (eg: voters and stakeholders) the value of sustainable agriculture versus extractive agriculture (the latter already employs many of them). Culture downsides would be from failure of the endeavor.<\/p>\n 31. How can insect production sustainably transform existing food systems and other value chains? What steps are needed to ensure that this systemic change is inclusive, sustainable, and equitable? See above.<\/p>\n 32. Aside from what is featured in this RFI, what additional questions about insect production should USAID and USDA be asking? Given limited space to respond here, future dialogue is needed.<\/p>\n If you need anything further, please do not hesitate to call: 352-281-3643 or email:\u00a0Aaron.T.Dossey@allthingsbugs.com<\/a><\/p>\n
\nUSAID\/USDA Understanding Global Insect Production RFI
\n(For the PDF version click here<\/a>)
\nCopyright Aaron Todd Dossey, February 15, 2022
\nPublished Aaron Todd Dossey, February 14, 2022<\/p>\n
\nATD of ATB and ISI<\/p>\n
\ninfo@cricketpowder.com<\/a>
\nAll Things Bugs LLC
\n2211 Snapper Ln
\nMidwest City, OK 73130<\/p>\n
\n1. Where, what scale, and with what type of insect production do you work?
\nWe currently work primarily with mealworms (Tenebrio molitor) and House Cricket (Acheta domesticus), although we have previous experience with are preparing to begin working with Black Soldier Fly (Hermetia illucens) and Superworm (Zophobas morio) among others. In the future we plan to work with other types such as grasshoppers and lepidoptera\/caterpillars \u2013 we also have previous experience with those. Our scale is currently based on market demand and funding opportunities to manufacture our patented Griopro\u00ae brand cricket powder. We are primarily an innovation\/research\/R&D company but plan to expand our commercia pursuits in 2022 including a mealworm farm, cricket based cereal products, expanded cricket powder manufacturing and marketing our insect farming innovations (equipment and feed formulations). Aside from lab insect cultures for research, we currently purchase the crickets or our cricket powder from farms in the US \u2013 approximately 10,000 pounds per shipment (1-2 per year). In 2022 we plan to build our first insect farm to produce mealworms (Tenebrio molitor) for both human consumption and animal feed. We plan to produce approximately 20,000-50,000 pounds of mealworms per year in our first 1-2 years. This farm will incorporate the most cutting edge automated and mechanized mealworm farming technologies, mostly invented by our company.<\/p>\n
\nYes. We plan to build our first automated mealworm farm in the US in 2022. We are also in negotiations with partners in Mexico and Costa Rica to explore building cricket and mealworm farms there. Additionally, we have contacts in Honduras and are exploring collaborations to develop insect farming in that country as well. We also have a substantial interest in developing insect farming and research with collaborators in Cuba. Thus, our primary interests are in Latin America and the US. We have patents issued for cricket powder in Canada and Mexico.<\/p>\n
\nWe believe strongly that 2 categories of countries have the strongest potential: 1) Islands and 2) Latin America in general. We believe Honduras and Cuba would both be excellent choices for investing in insect farming and insect protein production due to their proximity to nearby export markets such as Mexico, the US and Central\/South America as well as the need for more sustainable nutritional sources and natural resource limitations within those countries. As described above, we feel strongly that insects can have a more substantial impact as a human food ingredient than as an animal feed commodity, though both applications will offer significant improvements in our agricultural system and its impact on the natural environment.<\/p>\n
\nWe believe insects or human food will make the most substantial and urgently needed impact in sustainability and lowering human impact on the natural environment.<\/p>\n
\nYes, easily.<\/p>\n
\nYes, we would be extremely interested in opportunities to do this. We can engage, partner, collaborate and\/or establish insect business and research in just about any capacity and in any topic area (farming, food product development, ingredient manufacturing, genetic engineering, other research or commercial endeavor).<\/p>\n
\nWe currently source crickets from US arms who use a gluten-free largely corn and soy based formulated diet. Mealworms are largely fed wheat bran but we are developing gluten-free diets or those as well such as rice bran and defatted rice bran. In developing tropical countries, we may continue to use corn, soy, rice and other common low cost commodities as insect feed but also utilize locally sourced byproducts such as rice and sugar byproducts, banana leaves and banana byproducts, coffee byproducts and others common in tropical regions.<\/p>\n
\n8. What scale of production is most practical to start insect production in a development context? Assuming the market exists, how can insect production models for animal feed (or even human consumption) most easily be scaled up in a development context?
\nFor human food, an insect production operation should plan to start out at least at 5,000 pounds of raw non-dried insect per month. Or animal feed, a viable scale is much larger due to low margins and low prices or animal feed (likely 50,000+ pounds per month to start). This allows or the beginnings of economies of scale, ability to supply food manufacturers and retailers and also provides enough volume so that industrial equipment at processing plants can be utilized or production of the insect-based ingredient (powder, which is by far the most useful format or insect to make it into the food supply). For scaling up, an insect producer should first establish their market \u2013 identify customers who are willing to buy based on certain cost, volume and quality parameters. To begin production before you know you can sell it is problematic. Also, getting investment (ideally non-dilutive) to build a proper facility with modern technologies (or insect feeding, watering, harvesting and particularly freezing) is important. This is where government grants and NGO funding is ideal if the goals o those organizations are to promote positive environmentally friendly food security. Strategic partners (large food or agricultural companies) can also be very helpful in either investing directly in the new enterprise or assuring significant initial market or the insect based ingredients as customers. Additionally, small innovation focused startups can make ideal partners to assist insect producers to optimize their operations, or simply investing directly into the innovation startups to build new insect production capacity themselves can be most efficient.<\/p>\n
\nOf course, market demand and consumer interest are important or marketing any product, including which insect one should produce. Beyond that, we prefer to focus on the following parameters when selecting the ideal insect or an application or production endear: 1) efficiency of production, 2) simplicity of production, 3) how prolific is this species, 4) growth rate and overall productivity relative to resource inputs), 5) hygiene \u2013 how clean can this insect be produced without risk o microbial or other contaminations (ideally insects who can live in dryer vs wet environments\/substrates are ideal for human food applications: e.g.: mealworm better than black soldier fly etc.), 6) cost, simplicity and locally availability of feed inputs, 7) quality of feed inputs (can quality and safety be reliably controlled), 8) what is the food or feed application? (is a high fat or low at insect best?), 9) regulations (is it approved for food? Can it be grown in that location without risk of escape and becoming invasive?), 10) how easy the insect is to handle (harvest, move etc.) \u2013 insects that do not fly or jump far are idea as well as those with sleek body shapes which can be handled by machines without being caught in machines (e.g.: are amenable to modern mechanization and automation) and 11) the efficiency and environmental impact of producing a particular species including the impact of its feed inputs and energy needed to maintain its growth conditions (this is absolutely critical).<\/p>\n
\n\u25cb Start-up funding or generating profits: 1) government grants (but these are not sufficient and do not cover critical costs such as major equipment, marketing, property, and facilities), 2) selling cricket powder (startups at a massive disadvantage and competitiveness\/scale is extremely difficult without additional financial support).
\n\u25cb Finding local partners and connections in developing countries: I have tried to reach out to reach out to academics in food and agriculture in developing countries with little or no responses. It seems academics are typically focused very narrowly on their own research and do not have contacts in government agencies or industry, or simply respond only to a tiny fraction of their emails. Some of this could be language barrier but usually the contacts we reach out to show evidence of understanding English.
\n\u25cb Negative environmental impacts: We have not gotten this are yet. However, I am extremely concerned that government laws which are reported to exist to protect biodiversity are more in favor of local human population interests and detrimental to biodiversity (such as permits).
\n\u25cb Entering the market and establishing supply chains (local, national, international): We have not gotten quite this far, but the major challenges I foresee here are largely logistical and financial, and to a lesser degree establishing a market\/customer. One would need to build a modern farming facility and identify a nearby modern processing plant to convert the insects into powder ingredient at industrial scale as well as frozen product transportation.
\n\u25cb Technical and\/or production processes: This is our forte as one of the world\u2019s leading innovation\/research\/technology startups in this space. So long as we can purchase the equipment and facilities needed, our company can tackle any technological challenge needed or success.
\n\u25cb Cultural barriers to adoption: for us, language would be the only such barrier as currently we do not have team members who speak languages besides English. Of course, marketing and product development would take into account culture preferences and needs to assure market success.
\n\u25cb Other? Our greatest challenges to establish insect protein production in other countries are: 1) need to find partners and collaborators in-country (government, academic and industry) and 2) financial resources to pay for building the facility and starting the new business\/farm.<\/p>\n
\nCurrently we do not have collaborators, partners or contacts in any other country. It would likely be easiest to start with some such in-country contact who wanted to work with us. Aside from partners\/collaborators, and obvious financial needs to build\/equip the facility and establish the market, we would need to identify a modern contract food processing plant to convert the insects into powder (in our case a toll spray drying plant \u2013 but potentially other types of drying could be utilized in early stages of the business). We would also need to identify frozen product transport to move the frozen insects to the processing plant. Modern food processing equipment and facilities, to be efficient and at scale, are prohibitively expensive for startups and unnecessary if you can outsource the processing (which is most typical in the food industry). However, if sufficient investment were in place, an insect farm with its own spray drying facility would be maximally cost and environmentally efficient.<\/p>\n
\nIt would help tremendously to move our field forward I we could work with USAID and USDA to ind connections and resources to establish insect protein industry in other countries (and even do more in the US). I would prefer to start talks through email and online meeting first, then follow up with phone calls and in person meetings as things progress. If there is a conference (online or in person) of course I would be happy to attend and speak at it and make connections that way as well. for endeavors in other countries, I would prefer to start with online meetings and follow up with emails and additional video calls. Or connections that seem to be promising I would prefer to then go to their country or an in person meeting \u2013 possibly as an invited speaker (I government or academia) or simply an in person meeting to see and discuss things like facility locations and other details.<\/p>\n
\nWe have not exported yet, but the biggest challenge is simply finding out exactly what the regulations are and how to comply with them. That is even true in the US.<\/p>\n
\nWe can handle those ourselves given funding and resources. We believe the following research areas have the biggest need to move the industry forward: 1) food product development, 2) automated arming technology and 3) insect genomics\/genetics. Additionally, rigorous animal and human food safety and health impact research involving insect consumption would be extremely beneficial. Again, we are capable o working in all o these areas given resources and\/or collaborations\/partners.<\/p>\n
\nThe following would be most critical or us to establish a successful insect protein industry in a particular area: 1) Indoor facilities and resources for building the farm including modern equipment, some of which we are currently inventing or have invented), 2) a supply chain of quality insect feed ingredients, 3) access to contract food processing plant (ideally spray drying the insect powder ingredient & other food processing like contract extruder and bakery producing various food products using insect powder). Additionally, access to marketing resources and potential partners\/customers (retailers, etc.) would be an ideal or optimal success.<\/p>\n
\nWe are comfortable with our ability to develop technologies, innovate and conduct research of any type. We need resources and opportunities to implement, build, commercialize and scale up our technologies.<\/p>\n
\n1) freezing the insects prior to shipping to a processing plant and 2) spray drying the insects to produce a high quality powder ingredient with optimal shelf life due to the act that spray drying minimizes heat exposure to the insects while still being very cost effective at scale. We have already conducted shelf lie and other studies on spray dried cricket and mealworm powders.<\/p>\n
\nPrimarily microbiological. We pasteurize insects in liquid form prior to spray drying them which successfully knocks down micro levels while minimizing the heat needed to do so (thus protecting product quality and shelf life).<\/p>\n
\nThere are many benefits. Please review our website www.cricketpowder.com and the book I published on this topic. I can provide details on downsides too, but to date, we only know of a few including costs to scale up, consumer\/industry perceptions and the need or technologies to automate and mechanize insect production \u2013 additionally small scale (and thus high per unit pricing) and lack o insect based products by major manufacturers that would provide a market or insect protein and farm raised insects. However, we are actively solving the technological challenges and look forward to the opportunity to find partners to commercialize these. Additionally, the benefits o insects as sustainable food ingredients far outweigh the temporary downsides based on our current knowledge (again, largely soled by increasing market scale).<\/p>\n
\n20. What are the minimum biosafety protocols you recommend to avoid the spread of disease, environmental contamination and other negative environmental impacts?
\nI would recommend using one of the following 2 sources of insect: 1) domesticated species commonly farmed around the world (crickets and mealworms in particular) and\/or 2) species native to the location where the production endeavor will be established. The commonly farmed species such as mealworms would be my first choice due to existing knowledge. If importing commonly farmed species, I would recommend molecular screening for insect diseases (viruses, bacteria, other microbes and parasites) to assure a clean stock is being imported. I would source from at least 3 locations to establish genetic diversity (we could also help to develop genetic screening or this as well). At the farm, if the insects are free of insect pathogens, use of air filters for incoming and outgoing air would help limit contamination in the farm and local environment. Sanitizing (using heat, steam, hot water or liquid such as detergent or alcohol) equipment and materials in contact with the insects before they go out would also be ideal. However, the primary risk would be from escape and invasiveness of the farmed insects (which would also be related to risk of environmental contamination of foreign pathogens\/microbes). For this, layers of indoor space, walls and multiple doors to get from the outside to the live insects is the best containment strategy. Also use of adhesive mats at entries and around areas of potential escape would be helpful for monitoring and mitigate escape. Any air vents or openings should be covered in screens through which the armed species cannot escape. If a local native species is selected for farming, there should be nearly no risks to the local environment. It would be ideal to limit escape of the insects to limit risk of increasing local populations. Also, once the farm population is established, it would be ideal to treat them similarly to an imported species, as the high densities may breed pathogens that would not be likely in wild dispersed populations. Even local species should be screened or pathogens before they enter the farm. The benefit of local species is that once a clean farm is established, the risk to the local environment is very small, and replenishing genetic stocks from the wild is theoretically simpler with no risk to the local environment. However, with experience, even imported species (such as mealworms) likely pose a rather small risk. Outgoing materials should be harvested and processed (frozen etc.) in an area separate from the area of the farm for insect growing. We have developed technologies which can assist with this. In the ideal situation, if sufficient funding\/capital is available, insect powder (food processing) facilities can be attached to a farm, but this will not typically initially be practical for most farms until they make enough money to afford to build their own processing plant, hence the typical situation would require the insects to be shipped frozen to a food processing plant.<\/p>\n
\nWe are one of the leading R&D \/ innovation firms in the world developing technologies in all aspects of insects as sustainable food ingredients\/products from farming to genetics to processing and food ingredient\/product development. In addition to the intrinsic environmental benefits, insects offer when displacing other protein sources, all of our technologies are developed to minimize their environmental impact. We select insect species, feed ingredients, equipment, materials and other aspects to maximize efficiency and minimize energy use, land use, water use, pollution and use of plastics.<\/p>\n
\nEdible insect feed inputs should be carefully vetted and treated. Depending on the insect species, many types of biomass could be accepted. The most important method to assure safety, quality and environmental benefit to edible insect feed inputs is vetting the sources in advance. This would mean identifying reliable, stable and consistent (content\/nutrient\/hygiene, supply and cost consistency) sources and establish contracts with those suppliers. Additionally, depending on the material, it could be heat treated and pelletized, or simply dried and fed to the insects if it is a dry product. It should be screened or aflatoxins. Again, quality and safety parameters may be handled by the source organization, so minimal testing by the arm would be required. Or environmental benefits and sustainability, carbon\/nitrogen efficiency, resources required to produce and deliver the feed inputs should be considered. Additionally, when possible, byproducts and\/or ingredients that do not compete with human food supply (like grasses etc.) should be considered if they can be produced and processed as insect feed with minimal or no impact on the environment (based on land, water and energy use). Land and water use should always be the primary 2 parameters used to evaluate the environmental safety, impact and sustainability of any product, followed by toxin pollution and plastic use.<\/p>\n
\nWe are prepared to mitigate these risks using our technologies as opportunities are presented.<\/p>\n
\n25. What illustrative or specific roles could you envision for USAID or USDA to support insect production?
\n1) direct investment via grants (research and facility development), 2) partner or collaborator matchmaker (including connections to government, NGOs in developing countries as well as with big food and ag corporations). Maybe hold a conference or 1 on 1 web calls with interested parties.<\/p>\n
\nSee previous sections. Farmed insects are probably the most sustainable protein source on earth.<\/p>\n