VEGA's Response to an ACNFP consultation on a vegetarian glucosamine product
Our comments below are based on the ACNFP consulatation documents.
Our comments are based on the Draft Opinion issued for public consultation, dated 5 July 2007. We agree with the Advisory Committee’s advice in the Conclusion (para 46) that “additional assessment” is required. Specific needs for consideration (some apply to production of glucosamine from any source) are as follows:
Para 8: The method of production suggests that contamination with acrylamide and chloropronanols should be excluded as a possibility.
Para 10: We repeat our reservations on the widespread applications in foods of bioactive substances used in more controlled conditions and in a manner more accessible to statistical evaluation. The substances should be introduced at first as supplements and be given a specified period of testing and proving before they are used widely in commercial foods. Analogies can be drawn from the precautions applied in fortification with folate and with reservations over widespread additions of, say, vitamin D to liquid milk. Statins are widely available, almost in a supplement manner: are they to be regarded as suitable means of fortifying common foods, since they have been derived from fungi (eg oyster mushrooms) in common cuisines? In the instance of glucosamine, alternative usage, as opposed to cumulative consumption, eg by food, supplement, or topical application (thus by-passing the first phase of absorption) and the concerns of certain groups, eg athletes and bodybuilders (and in the present specification, vegetarians) must be accommodated. Are we approaching the point where OTC NSAIDs might be considered as food ingredients?
Para 25: The products of metabolism should be identified and assessed.
Para 41: Maillard products (likely to be colored) might arise in the process of manufacture. They should be taken into account. The products should be white.
Para 43: We agree that the fungal source should be named. As chitin is an essential component of fungi, some pathogenic, and a number with properties similar to A. niger (and GM modifications), the applicant should detail the specification of the applied organism and of the commercial property, eg patents, attaching to it; and the possibilities of development and innovations allowing competition may result in many requirements for the ACNFP’s attention or generic approval.