Those items up for review included carrageenan. As you know, carrageenan is a non-synthetic stabilizer with a long history of safe use in a variety of food and drinks, including those certified by the United States Department of Agriculture (USDA) as worthy of the U.S. organic label.
The NOSB committee is made up of four organic farmers, three conservationists, three public interest representatives, two organic handlers, one retailer, one scientist and one certified USDA agent. (A full description of the NOSB and its relationship to the National Organics Program (NOP) and the USDA is available at https://www.ams.usda.gov/rules-regulations/organic/nosb.
A final (NOSB) recommendation on the re-listing of carrageenan will not come until late in the fall and the recommendation could then undergo further review by the USDA. All the items undergoing review this year are being evaluated as part of a five-year period that ends in 2018.
On behalf of our customers, FMC was determined to present a convincing science-based case for the safety of carrageenan, as well as commentary on its essential value to many food formulations and its eco-friendly profile.
To that end FMC subject matter experts participated in both the webinar and in-person comment portions of the NOSB meeting, and enlisted written commentary to the docket.
FMC was not alone. The effort was joined by scientists, other carrageenan suppliers, as well as trade groups speaking for organic and conventional food producers.
In addition, commentary was provided by those representing more than 32,000 family farmers who cultivate red seaweed in the Philippines, Indonesia and Africa.
While no one can, or should, predict the outcome of the upcoming NOSB recommendation, it was clear that the 15-member NOSB committee was committed to a careful review of the facts.
The Preponderance of Science
Three research scientists supported by FMC, provided commentary, while also participating in either the webinar or the public commentary sessions.
They included Myra L. Weiner, PhD, James McKim, PhD and William Blakemore. You may read their comments at https://www.regulations.gov/#!documentDetail;D=AMS-NOP-15-0085-2938, https://www.regulations.gov/#!documentDetail;D=AMS-NOP-15-0085-2136 and https://www.regulations.gov/#!documentDetail;D=AMS-NOP-15-0085-1765. Comments by Dr. Weiner addressed questions related to her piglet study and pitfalls in some carrageenan research. Comments by Dr. McKim addressed in vitro study issues and William Blakemore gave a full definition of ‘low molecular weight tail’ and tendencies to confuse LMT with poligeenan.
In addition, the committee paid particular attention to the most recent independent review of carrageenan safety conducted by the Joint FAO/WHO Expert Committee on Food Additives (JECFA).
The JECFA review was concerned with carrageenan suitability in infant formula and examined a wealth of relevant science, including the research performed by a carrageenan detractor. The JECFA review found carrageenan was ‘not of concern’ for use in infant formula. A summary of the report can be found at http://www.fao.org/fileadmin/user_upload/agns/news_events/JECFA%2079%20Summary%20Version%20Final.pdf.
Opposition to carrageenan continues to come primarily from the Cornucopia Institute and Dr. Joanne Tobacman, of the University of Illinois. Both provided commentary and the Cornucopia Institute cited other researchers who have alleged the harmful effects of carrageenan.
However, no other opposing scientist who has conducted actual research on carrageenan besides Dr. Tobacman participated in the webinar, provided commentary or participated in the public sessions.
Dr. Tobacman’s work has been reviewed by independent panels and food regulatory agencies all around the world and has been found unconvincing. The Food and Drug Administration (FDA) had previously rejected a citizen petition of hers regarding carrageenan. That rejection can be viewed at https://www.regulations.gov/#!documentDetail;D=FDA-2008-P-0347-0003.
The JECFA review of carrageenan safety for infant formula also found Dr. Tobacman’s work unconvincing, along with animal studies that administered carrageenan in drinking water or injected it into the animals.
Concurrent with the NOSB session, the Cornucopia Institute issued a ‘report’ on carrageenan that was deliberately misleading and fraught with inaccuracy. The rebuttal to the Cornucopia report can be found at http://www.foodsciencematters.com/wp-content/uploads/2014/10/Counter-To-Flawed-Science.pdf.
‘Essentiality’ was one of the items addressed by the NOSB. FMC and others discussed the fact that all hydrocolloids do not perform the same way in all formulations.
FMC and others described specific end uses where carrageenan is essential to product nutrition and/or performance. Robert Rankin of the Infant Nutrition Council of America commented that carrageenan is the only additive currently used in U.S. organic infant formula.
One company that produces organic yogurt admitted that they had serious challenges achieving the right consistency across all flavors, even abandoning one flavor.
The committee was told that to get the same performance as carrageenan in some formulations would require more than one ingredient. It was also noted that price, availability and consistent quality were also concerns in some alternative additives.
Sustainable and Sustaining
The environmental profile of carrageenan was of particular interest to the committee – and should be to our customers, as well. In parts of the world where jobs that provide a safe, sustainable path of upward mobility are exceedingly scarce, seaweed farming is often the career of choice.
The committee heard that red seaweed farming has replaced more destructive and more dangerous activities related to the fishing industry in these countries.
In some Muslim countries, the farming of red seaweed provides substantial employment to women, who are not allowed other employment opportunities.
The affinity between these seaweed farmers and the farming members of the NOSB committee was palpable. If you operate a small organic farm in the United States there is more that connects you to these 32,000 seaweed farm families than you might think at first glance.
Our support of these families as providers and customers is something we should be mindful of during and after the NOSB deliberations.
We will continue our full support of carrageenan as a safe ingredient in the months and years ahead.
Details of the spring 2016 NOSB meeting are found at https://www.ams.usda.gov/event/nosb-spring-2016-meeting-washington-dc.