Livestock Feed Controls in Scotland review

The Society for the Protection of Insects strongly opposes the approval of insect processed animal protein (PAP) in pig and poultry feed based on substantial environmental, biosecurity, and animal and public health concerns supported by recent scientific evidence.

Environmental Impact and Biosecurity Risks:

The environmental case for insect farming is significantly weaker than initially assumed. Current research demonstrates that insect farming poses several serious environmental risks:

1. Resource Intensity: Contrary to industry claims, insect farming requires significant water and energy resources, particularly for heating tropical species in temperate climates like Scotland. Recent Life Cycle Assessments report concerning levels of water usage in insect farming operations (Biteau et al. 2024c).

2. Feed Conversion Inefficiency: Adding insects as an intermediate step between plant protein and livestock creates an additional trophic level, reducing overall system efficiency. The majority of insect farms rely on materials like brewers' grains, corn starch, or wheat bran that could be more efficiently used directly as animal feed or human food (Biteau et al. 2024b).

3. Biosecurity Threats: Research documents "frequent and high number" of insect escapes from farming facilities (Bang and Courchamp 2021). These escapes present multiple risks:
- Potential spread of diseases to wild insect populations
- Introduction of selectively bred or genetically modified insects into natural ecosystems
- Establishment of invasive species
- Gene pollution through escaped insects breeding with wild populations, threatening biodiversity through genomic homogenisation (Generalovic et al. 2023)

Health and Safety Concerns:

Current scientific literature identifies significant risks and knowledge gaps regarding the safety of insect-based feed for livestock:

1. Animal Health Risks: Research has documented serious health concerns when insects are used as feed:
- Parasites have been detected in 81% of insect farms examined, with potentially harmful parasites present in 30% of farms
- Disease outbreaks in insect farming facilities pose risks of pathogen transmission to livestock
- Uncertainty surrounding the long-term effects of insect-based feed on animal health and development

2. Cross-Contamination Risk: Feed substrate has been identified as the primary concern for microbiological and chemical food safety, raising serious questions about the enforcement of safety protocols (Traynor et al. 2024).

3. Supply Chain Integrity: As insect supply chains extend globally, ensuring product integrity and compliance with safety controls becomes increasingly challenging, with direct implications for animal health and consumer protection (Fuso et al. 2024).

4. Knowledge Gaps: Recent research emphasizes "substantial food safety and authenticity information gaps in this industry that need to be addressed before edible insects can be viewed as a safe and sustainable protein source" (Traynor et al. 2024).

Economic Considerations:

The economic case for insect PAP in animal feed is not viable:

1. Cost Barriers: Including processed insects at just a 10% rate in broiler chicken feed would increase breast meat prices by over 50% (Leipertz 2024b).

2. Offshoring Risks: The high costs of energy and labor in Europe make domestic production economically unviable without substantial subsidies, likely leading to offshoring to regions with lower environmental and safety standards (Ryba 2024).

We strongly recommend:

1. Maintaining current restrictions on insect PAP in animal feed until comprehensive safety protocols are developed and validated
2. Conducting thorough environmental impact assessments specifically focused on escape prevention and biosecurity
3. Developing stronger regulatory frameworks for monitoring and controlling disease transmission risks
4. Investigating alternative, more efficient uses of agricultural byproducts currently proposed as insect feed

The Society for the Protection of Insects urges regulators to apply the precautionary principle given the significant environmental and animal health risks identified in current research. The potential consequences of approving insect PAP in pig and poultry feed outweigh any projected benefits, particularly given the questionable economic viability of insect farming in domestic markets.

References:

Bang, A. and Courchamp, F. (2021). Industrial rearing of edible insects could be a major source of new biological invasions. Ecology Letters, 24(3), 393-397.

Biteau, C. et al. (2024a). Environmental and economic assessment of insect farming: A critical review. npj Sustainable Agriculture (forthcoming).

Biteau, C. et al. (2024b). Feed substrates in commercial insect farming: A systematic review of current practices and future challenges. Journal of Cleaner Production.

Biteau, C. et al. (2024c). Environmental impacts of insect farming: A comprehensive life cycle assessment. EcoEvoRxiv.

Fuso, A. et al. (2024). Safety and quality control challenges in global insect protein supply chains. Food Control.

Generalovic, T. et al. (2023). Genomic evidence of escaped flies from commercial farms and implications for wild populations. bioRxiv.

Leipertz, H. (2024b). Economic analysis of insect-based feed incorporation in poultry production systems. Poultry Science.

Ryba, M. (2024). Offshoring insect farms may jeopardize Europe's food sovereignty. Global Sustainability.

Traynor, S. et al. (2024). Food safety and authenticity challenges in the emerging insect protein industry. npj Science of Food.