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Responses to Advertisement about Certified Organic Spirulina
issued jointly by Cyanotech Corp. & Earthrise Nutritionals LLC and FAQ's issued by Cyanotech Corp.
Responses by John R. Benemann, Agent (jbenemann@aol.com) 925 352 33352, and
Sebastian Thomas, CEO, SebastianT@pai.murugappa.com +91-44-2530 6816
Parry Nutraceuticals Ltd., Chennai, India
May 25, 2006
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Introduction: An advertisement by Earthrise Nutritionals LLC and Cyanotech Corp. has been running since March in the National Food Merchandiser headlined "Notice to Customers: 'Organic' Spirulina" is no longer being produced" . The Companies claim that complying with the USDA NOP (National Organic Program) rules effective October 21, 2005, governing production of Certified Organic Spirulina, "may compromise safety and quality resulting in inferior Spirulina products and at a much higher cost". The advertisement also provides a checklist comparing "organic" and so-called "all natural" Spirulina, alleging that Certified Organic Spirulina is produced using animal products, has high heavy metals and bacteria contents and has lower growth rates than "all natural" Spirulina. The advertisement further claims that only Spirulina produced by The Companies is "recognized as safe for use in foods" by the FDA. These statements are false and incorrect both in general and in their specifics and these issues are addressed herein.
In addition to the advertisement, a list of 32 FAQs was sent to customers by Cyanotech Corp, expanding on these claims that Spirulina produced under USDA NOP rules is "unsafe" for consumers and asking customers to write to the USDA for organic certification to be withdrawn from Spirulina.
Parry Nutraceuticals Ltd. produces Parry's Vegetarian Certified Organic Spirulina™ and is the leading producer of Certified Organic Spirulina in the world. It is thus the immediate and obvious target of this negative advertisement campaign. We take these accusations, that we are producing an "unsafe" product, extremely seriously. It has been argued in private conversations by representatives of The Companies that the basis for their advertisements is not based on any analysis or studies of Parry's Vegetarian Certified Organic Spirulina™, but, rather, only on their own in-house studies and research. However, they have refused to release any data supporting their assertions. In brief, they were not successful in meeting the requirements for certification under the USDA NOP regulations as of October 21, 2005, and now make serious allegations about all Certified Organic Spirulina without any evidence or proof to back up these claims.
This response addresses and rebuts in detail their 32 FAQs with ANSWERS by Cyanotech along with RESPONSES by Parry Nutraceuticals Ltd. Note: these FAQs are by Cyanotech, but are reproduced here generically. Further, note that these Responses only address the issues related to Parry's Vegetarian Certified Organic Spirulina™, and do not address any other Certified Organic Spirulina products.
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Why did The Companies stop producing Organic Spirulina October 21, 2005, when growers in other countries are still producing it?
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Why can foreign Spirulina growers produce Certified Organic Spirulina and American growers cannot?
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If the all natural Spirulina product produced by The Companies is herbicide free, pesticide free, and lower in heavy metals than the organic product, why did The Companies begin organic production in the first place?
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Would The Companies consider organic production again if all conditions for its production were favorable?
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Product Profile (Difference)
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Is Organic Spirulina better than All Natural Spirulina?
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Is All Natural Spirulina better than Certified Organic Spirulina?
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Product Profile (Definition)
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Can Organic Spirulina be considered Vegetarian or even Vegan?
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What is the definition of 100% Vegetarian?
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What does New Certified Organic Spirulina mean?
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What does All Natural Spirulina mean?
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How can you use the term "all natural" when you are using purified nutrients?
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Product Profile (Heavy Metal)
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When you say that there is a low heavy metal level, does this mean that the Spirulina that I have been using all of these years has heavy metals?
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In the advertisements and product literature, All Natural US Grown Spirulina has a checkmark for Low Heavy Metal Level. Does this mean Organic Spirulina results in high heavy metal? Why?
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You state that your product has a lower heavy metal content than that of Organic Spirulina. Do you have data to support that?
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The Companies supplied Organic Spirulina before. Was the product higher in heavy metals than All Natural Spirulina.
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Product Profile (Bacteria)
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All Natural US Grown Spirulina also has a checkmark (in advertising) for Low Bacterial Count. Does this mean Organic Spirulina results in high bacterial count?
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Do you have data to support that All Natural Spirulina has a lower bacterial content?
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Nutrient (Nitrogen)
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Why is nitrogen important to the growth of Spirulina?
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What does the "new nitrogen sources compromise safety & quality" statement mean?
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What are the "new nitrogen sources" allowed by the National Organic Standards that may compromise safety & quality?
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Nutrient (Animal Fertilizer)
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All Natural US Grown Spirulina has a checkmark for Non-Animal Fertilizer. Does it mean that Organic Spirulina is grown with Animal Fertilizer?
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What are the Animal Fertilizers used to grow Organic Spirulina?
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Does that mean the organic product The Companies used to produce was grown with animal fertilizers?
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If the use of Animal Fertilizer presents a hazard to health, why then are such fertilizers used to produce organic produce like fruits and vegetables that are consumed in much higher quantities than Spirulina.
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Nutrient (Purified Nutrients)
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What do you mean by "Purified Nutrients"?
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What happens to the unused "purified" nutrient during the production process or when production is finished? Don't they pose more of an environmental problem compared to organic nutrients?
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Safety
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American grown Spirulina is GRAS (Generally Recognized As Safe) by the US FDA - what does this mean?
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Others
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Why would it cost more for The Companies to produce Organic Spirulina under the new Standard?
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Is it important to know that there is a high growth rate for All Natural Spirulina?
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What do you mean by minimally processed?
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Do The Companies have supporting data for all the contention made on the checkbox in the press release and advertising?
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How does Spirulina grow naturally in lakes in Africa and formally in Mexico?
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Who would I contact if I want to express my concerns about these changes?
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IN CONCLUSION
The statements in the advertisement by The Companies, and the above FAQs (by Cyanotech) are mostly false, generally misleading, and often malicious, always without any basis, asides the sour grapes that they were not able to produce a Vegetarian Certified Organic Spirulina themselves. Thus they now attack the entire category, and ask, in what is really at play here, for the organic designation to be lifted from Certified Organic Spirulina so they will have no competition from this category. The Companies are colluding to exclude others from the marketplace that produce a product in great demand by the public, by falsely alleging that the competing product is "unsafe".
We at Parry Nutraceuticals Ltd., as leading producers world-wide of Certified Organic Spirulina, are now forced to publicly respond to this malicious and misguided attempt to call into question not only the category of Certified Organic Spirulina, but, by implication, the entire organic consumer movement. Parry Nutraceuticals Ltd. has taken great care to provide to its customers and consumers the highest quality 100% vegetarian Certified Organic Spirulina. Indeed, our Spirulina has received all the certifications that can be applied to this product. US producers have lagged far behind in this effort, as the prior discussion amply documented.
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WHAT DOES THE USP Ingredient Verification Program assure?
It assures that:
 Products are consistent in quality from batch to batch.
Products meet Certificate of Analysis claims for identity, strength, purity and quality.
Products are prepared in accordance with accepted manufacturing processes.
Products meet requirements for acceptable limits of contamination (heavy metals, bacterial
count etc)
Note
What is HACCP?
Hazard Analysis Critical Control Points is a process control system designed to identify and prevent various hazards like microbial contamination and other hazards in food production. HACCP involves seven principles:
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Analyze hazards
Potential hazards associated with a food and measures to control those hazards are identified. The hazard could be biological, such as a microbe; chemical, such as a toxin; or physical, such as ground glass or metal fragments.
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Identify critical control points
These are points in a food's production--from its raw state through processing and shipping to consumption by the consumer--at which the potential hazard can be controlled or eliminated.
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Establish preventive measures with critical limits for each control point.
For example, this includes setting the minimum processing temperature and time required ensuring the elimination of any harmful microbes.
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Establish procedures to monitor the critical control points.
Such procedures might include determining how the processing of food product has to be done at various stages and hence avoid contamination and hazardous consequences.
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Establish corrective actions to be taken when monitoring shows that a critical limit has not been met
For example, reprocessing or disposing of food if the minimum processing temperature is not met.
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Establish procedures to verify that the system is working properly
For example, testing time-and-temperature recording devices to verify that processing equipment is working properly.
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Establish effective recordkeeping to document the HACCP system.
For example, published microbiological studies on time and temperature factors for controlling foodborne pathogens
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