VEGA comments on an ACNFP consultation on echium ingredients in food
Below is our comments to an ACNFP consultation on echium ingredients in food.
Echium is a genus of 60 species of flowering plants in the family Boraginaceae, native to North Africa, Southern Africa, Europe, Madeira and the Canary Islands, as well as parts of East Asia.
Re: Views on baobab and echium ingredients
1. In the very short period we have been given to express our views on baobab and echium ingredients being assessed by the ACNFP in its preparation of a draft opinion (the despatch dated 11/06/07) we have been unable to resolve all our doubts over echium and stearidonic acid, and we have been unable to study the matter with the baobab dried fruit pulp.
2. Use of alternatives to fish oil to fortify and supplement diets nutritionally would be very useful for many consumers with aversions to marine-derived harvests unless they were of algal origin or algae farmed in appropriate waters. The issue is particularly relevant to vegetarians for whom the novelties would comprise the population likely to be consuming the highest levels of these products.
3. However, vegetarians – and especially strict vegetarians, who call themselves vegans – are notable for their acceptance of highly fortified products and resource to supplements. On the other hand consumers and producers of “normal” and traditional diets containing dairy products resist attempts for fortify frequently consumed foods for which enhancements might be perceived as beneficial for some people: in the UK liquid animal milks, for instance, are not fortified with vitamin D or iodide as is the practice in other countries. Although fortification of the national loaf with refined or synthesized substances was easily accepted in the post WW2 exigencies of rationing and control, the FSA is now involved in protracted consultations, in which special interests for vegetarians have to be considered, in fortifying flour and breads with synthetic folates.
4. There being no evidence that echium or borage seeds have been used as foods in Europe – unlike, say, linseeds or hempseeds – it would be advisable to restrict sales of refined echium oil to supplements, rather than as ingredients that may become difficult for objectors to avoid in commonly-consumed staple foods. Similar reservations also attend the introduction of these specialized products derived from microalgae; and their application in foods for particular groups, such as babies and women of child-bearing age should be subject to review and control more in keeping with pharmaceutical products intended for longterm use and OTC sales.
5. Production of fruit drinks and wines, as well as normal intakes of food, must yield plentiful sources of seeds and pips and rosehips from plants considered eminently edible. Cereal seeds and germ also are likely sources that can be commercially utilized even without “super refining” and “very different” processes (which may have a place if the normal consumption of seeds and pulps, mastication, and metabolism fails to extract nutrients or toxicants and leave the gut unchanged).
6. In the absence of details of the modes of extraction in “super refining” (which may include use of super cooled solvents) and the probable patent property and information we cannot comment further on super refining of the echium oils and the resort to hi-tech chromatographic processes. Nonetheless, we note the absence of complete stereochemical details in the formula for stearodonic acid in the specification: the mixture may contain isomers with trans-double bonds and be linked in various ways and chiralities with esterifying compounds such as glycerol (which would be significant in the actions of enzymes, hydrolyses, and inter-esterifications). Similar reservations attend assessments of fats in breast milk and CLAs.
7. Echium appears to be eaten in some form by grazing animals (whose meat and milk may therefore contain elevated contents of interesting lipids) and oils and creams have been applied for dermatological purposes. We may suppose therefore that consumption of the refined oils will not result in phototoxicity on skin exposed to sunshine. Work in progress in the European Lipgene project augmenting enzymatically the “missing” acids in the biochemical pathway might rely on echium as a substrate and provide further sources of DHA and EPA from purely plant sources; and “biomass” being fed to grazing animals and pigs, poultry, and farmed fish may yield elevated levels of stabilized DHA and EPA in meat, milk, and eggs. Public attitudes to this work are unpredictable: like the REACH project they entail experimentation on animals, for instance, and they may have recourse to GM.
8. Allergic reactions are difficult to predict, especially in combination with already risky components derived, say, from peanuts or tree nuts.
9. We hope that the final draft of the ACNFP’s opinion will comprehend these matters and lead to development of research to the common good and to accommodation of special interests.