“Food is our common ground, a universal experience.” - James Beard
Our first big hurdle was that our collagen sequence has never been utilized in ingestibles. Further research classified our protein as a ‘novel food’.
The concept of novel foods is relatively new, and there is no agreed upon definition by all competent authorities. That being said, the general consensus is that novel foods are any food items that satisfy one of four criteria.
In the case of HypeColl, three of the four criteria, shown below, confirm its status as a novel food.
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Newly developed food
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Food produced using new technologies
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Precision fermentation is considered a new technology in the food industry
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Food or ingredients from new sources
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Our collagen alternative is the first to be isolated from group A Streptococcus M2 serotype
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New substances used in food
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As collagen is often a secondary ingredient in food and beverages, it qualifies as a ‘new substance used in food’, rather than a ‘newly developed food’
Value-Sensitive Design.
In seeking novel food pre-market approval for HypeColl, we prioritized a human-centered approach. To do so, we employed a Value-Sensitive Design (VSD) to identify relevant values and expected norms
Regulations
Very few countries have developed regulatory frameworks concerned specifically with novel foods. Our meeting with Professor Mutamed Ayyash, an Associate Professor of Food Science at the United Arab Emirates University, informed us that no regulations surrounding precision fermentation are in place in the United Arab Emirates. Thus, we examined the regulatory frameworks of three relevant competent authorities across three different region
European Union - European Food Safety Authority (EFSA)
Why the European Union? The European Union’s EFSA has a very detailed pre-market approval process, in addition to an extensive catalogue of foods subjected to novel food regulations.
The EFSA regulates the food safety and relevant risks of any food products to be placed on the European Union’s market. When it comes to novel foods, the EFSA released Regulation (EU) 2015/2283 ‘Novel Foods’, which lays down the rules for placing such foods on the European Union market. According to the EFSA, novel foods are any foods that do not have a significant history of consumption in the region prior to May 1997. Any proposed novel foods must not pose any risk to human health, must not mislead consumers, and must not be nutritionally disadvantageous.
Singapore - Singapore Food Agency (SFA)
Why Singapore? Singapore is a major hub for food innovation, with regulations across different categories of novel food. In fact, Singapore was the first country to approve the placement of lab-grown meat on the market.
The SFA is the competent authority which oversees food security and hazard management in Singapore. In terms of novel foods, the SFA released a document titled ‘Requirements for the Safety Assessment of Novel Foods and Novel Food Ingredients’, which covers all aspects of the approval process, from pre-market consultations to required documents and tests. According to the SFA, novel foods are any foods that do not have a significant history of consumption in the region over the prior 20 years. Proposed novel foods must be shown to be safe for human consumption through extensive hazard management and safety tests.
Kingdom of Saudi Arabia - Saudi Food and Drug Authority (SFDA)
Why Saudi Arabia? The Kingdom of Saudi Arabia is unique in the GCC for introducing novel food regulations, potentially leading to alignment with the UAE. Additionally, this makes it easier for food products to enter other GCC markets once they've entered one country.
The SFDA is the competent authority responsible for establishing food, beverage, and drug regulations and standards, and for inspection of both domestic and international products. In December 2020, the SFDA published SFDA.FD 5013:2020 ‘General Requirements for Novel Foods’, highlighting the requirements for pre-market approval of novel foods. The aforementioned regulations are heavily based on EFSA’s Regulation 2015/2283 on Novel Foods. SFDA dictates that novel foods are any foods that do not have a significant history of consumption in the region prior to January 1, 2021. In general, novel foods must have a composition that does not pose any health risks, must be safe for human consumption, and, if set to replace another food product, it should not differ from that product in a way that makes it inappropriate for human use.
Health and Safety
Geltor informed us that their latest product, PrimaColl, is intended for use in supplements. However, as imagined, it is much more difficult to get a novel ingestible product on the market, than a product intended for dermal use, with the main concern being the product’s safety. All of the aforementioned competent authorities necessitate that novel food products be tested for the absence of hazards. To learn more about the potential hazards associated with synthetic biology products, we consulted with Professor Ayyash, whose role as a Food Safety Trainer was of extreme benefit to our project. Professor Ayyash informed us that precision fermentation hazards can arise from chemical, physical, or biological sources. He further reconfirmed the need for extensive tests for allergens, toxins, and health risks. In the case of HypeColl, the main hazard sources are residual chemicals or host-strain DNA, which may result in allergenicity, cross-reactivity, and/or toxicity. We compiled a non-comprehensive list of the hazards that HypeColl may be subjected to, in addition to potential mitigation and testing techniques, in the table below..
Hazard |
Mitigation |
Testing |
Allergenicity |
Hydrolysis or similar |
- Assessing percent homology to known allergens (e.g. via AllergenOnline)
- Residue testing of product
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Toxicity |
- Use of generally recognized as safe species and/or strains
- Minimizing drastic genetic changes
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- Chronic toxicity tests (OECD 451, 452, or 453)
- ADME studies (OECD 417) (e.g. via SwissADME)
- 90-day oral toxicity studies (OECD 408)
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Mutagenicity, Carcinogenicity, and Embryotoxicity |
- Use of Generally Recognized as Safe (GRAS) species and/or strains
- Minimizing drastic genetic changes
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- Ames test (OECD 471)
- Comet assay (OECD 489)
- Multigenerational animal reproductive studies (OECD 413, 421 and 443)
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Microbial Contamination |
- Addition of antimicrobials
- Sterilization (heat, irradiation, filtration, etc.)
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Chemical Residues |
- Use of safe chemicals
- Use of minimal chemical levels
- Washing procedures
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Quantification of chemical levels in the final product |
Genetic/ Epigenetic Drift |
- Following related good practices
- Limiting subculturing
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- Sequence analysis
- Toxicity testing
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We employed as many mitigation strategies as possible, starting with the use of a non-pathogenic E. coli strain to limiting the number of subcultures.
When it came to hazard testing, limitations in both time and resources prohibited us from carrying out most of the experiments.
That being said, we resorted to literature reviews, simulations, and bioinformatics analyses to identify biological hazards.
Source |
Hazard |
Hazard Identification, Mitigation, and/or Testing |
Result |
Original Strain (group A Streptococcus M2 serotype) |
Pathogenicity |
Literature Review |
Moderate (linked to pyoderma and acute glomerulonephritis) |
Original Strain (group A Streptococcus M2 serotype) |
Toxicity |
Literature Review |
Unknown |
Host Strain (Auxotrophic/BL21 E. coli) |
Pathogenicity |
Literature Review |
Non-pathogenic |
Host Strain (Auxotrophic/BL21 E. coli) |
Toxicity |
Literature Review |
Non-toxic (endotoxin-free strains can be used) |
Expressed Protein (Scl2.28) |
Pathogenicity |
Literature Review |
Very low |
Expressed Protein (Scl2.28) |
Toxicity |
Literature Review |
Very low |
Expressed Protein (Scl2.28) |
Allergenicity |
Bioinformatics Analysis |
- Gluten allergens (number of Gluten-like Q repeats): 0
- Most similar protein allergen: Par ol alpha2I (collagen-derived protein), present in Paralichthys olivaceus
- Cross-reactivity with known allergens: 8 (Par ol alpha2I, Bos d alpha2I, Dan re alpha2I, Onc m alpha2I, Sal s 6, Bos d Collagen 140 kD, Lat c 6)
- Similarity to low allergenic protein: 0
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Expressed Protein (Scl2.28) |
Immunogenicity |
Literature Review |
Very low(1.38%) |
Expressed Protein (Scl2.28) |
Cross-reactivity with Collagen |
Literature Review |
None |
Expressed Protein (Scl2.28) |
Antigenicity |
Literature Review |
Very low |
It is worth clarifying that while the Streptococcus M2 serotype is associated with pyoderma and glomerulonephritis, these conditions are not linked to the Scl2.28 antigen, but are caused by other proteins, including M proteins, streptococcal pyrogenic exotoxins (Spe), and fibronectin-binding proteins (FBI).
This explains the low antigenicity and pathogenicity of Scl2.28. Other Scl proteins, including Scl1.1 and Scl1.28, still show a higher seroconversion rate and a higher pathogenicity than Scl2.28, indicating that while the host strain may be pathogenic, this pathogenicity is not associated with our protein of interest. Furthermore, the toxicity of the M2 serotype is not well-documented. Other Group A Streptococcus serotypes, including T1M1, T28R28, and T3M3 release exotoxins associated with toxic shock syndrome; however, data about the M2 serotype is scarce. Furthermore, while HypeColl exhibits cross-reactivity with eight known allergens, these allergies are not very common.
All in all, the results indicate that HypeColl presents low-to-moderate hazard levels; that being said, further in vivo and in vitro tests should be performed for quality assurance.
Transparency
It is worth clarifying that while the Streptococcus M2 serotype is associated with pyoderma and glomerulonephritis, these conditions are not linked to the Scl2.28 antigen, but are caused by other proteins, including M proteins, streptococcal pyrogenic exotoxins (Spe), and fibronectin-binding proteins (FBI).
This explains the low antigenicity and pathogenicity of Scl2.28. Other Scl proteins, including Scl1.1 and Scl1.28, still show a higher seroconversion rate and a higher pathogenicity than Scl2.28, indicating that while the host strain may be pathogenic, this pathogenicity is not associated with our protein of interest. Furthermore, the toxicity of the M2 serotype is not well-documented. Other Group A Streptococcus serotypes, including T1M1, T28R28, and T3M3 release exotoxins associated with toxic shock syndrome; however, data about the M2 serotype is scarce. Furthermore, while HypeColl exhibits cross-reactivity with eight known allergens, these allergies are not very common.
All in all, the results indicate that HypeColl presents low-to-moderate hazard levels; that being said, further in vivo and in vitro tests should be performed for quality assurance.