FAQs

Responses to Advertisement
Responses to Advertisement about Certified Organic Spirulina issued jointly by Cyanotech Corp. & Earthrise Nutritionals LLC and FAQ's issued by Cyanotech Corp.

May 25, 2006
Responses by
John R. Benemann,
Agent (jbenemann@aol.com)
925 352 33352

Sebastian Thomas, CEO,
SebastianT@pai.murugappa.com
+91-44-2530 6816
Parry Nutraceuticals,
Chennai, India.

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USDA NOP rules is "unsafe" for consumers and asking customers to write to the USDA for organic certification to be withdrawn from Spirulina.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, 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 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.

Why did The Companies stop producing Organic Spirulina October 21, 2005, when growers in other countries are
still producing it?

Answer by Cyanotech:
Because this is when new rules from the USDA-NOP went into effect.
Response by Parry Nutraceuticals:
False. Of course, if the word "potential" means that anything is possible, that could be true for some products on the market. We cannot comment on some of the products now on the market as we have not carried out any independent studies of those (and neither have The Companies). But we categorically reject such statements as applying to our products. The "new nitrogen sources" would be no more potential sources of toxins, etc., than any other inputs to the production process. It is totally false and irresponsible to make this statement. Parry Nutraceuticals has made a large investment identifying the best alternative to mined Chilean Nitrate and has replaced this inorganic mined chemical with a safe 100% plant-based nutrient as a source of nitrogen and phosphorous.

Why can foreign Spirulina growers produce Certified Organic Spirulina and American growers cannot?

Answer by Cyanotech:

Technical requirements are exactly the same within the USA and outside. New Organic Spirulina can be produced within the United States if the growers choose to do so. The reason they do not is one related to safety and risk management/liability in growing Spirulina under the new USDA rules. American growers have decided the risks area too high when using the new organic rules for Spirulina production. New organic rules require 10 times more organic fertilizer, which is not completely water soluble, and remains in direct contact with Spirulina. Risks from high organic fertilizer loading include potential toxins and disease organisms.

Response by Parry Nutraceuticals:

Claims and accusations that food products present safety risks to the public and contain "potential toxins and disease organisms" are extremely serious and should not be made lightly without proof. If indeed they had any shred of evidence of this, or even a well founded basis for such a belief that this product is indeed dangerous, they should raise the alarm or at least informed public health authorities, to avoid a disaster, one that would affect the entire Spirulina industry, most particularly themselves. Their failure to take any action, asides from this advertising and FAQs suggests a lack of conviction about the reality of their very serious accusations. The rationale provided for these statements, that the rules "require 10 times more fertilizer that is not completely water soluble and remains in direct contact with Spirulina" is no rationale whatever. The rules have no such requirement and, indeed, Spirulina, however grown, contains the same amount of nutrients (nitrogen and phosphorous), no matter what the origin of the fertilizer. All fertilizer, whether organic (used by Parry Nutraceuticals .), mined or synthetic (as used by The Companies), is in contact with the Spirulina cells and Spirulina uses only soluble nutrients. Thus these statements are technically not correct. In any event, The Companies do not provide a single shred of evidence for any "toxins or disease organisms" that are alleged to be contaminating, actually or potentially, Certified Organic Spirulina.

Parry Nutraceuticals . has invested considerable funds and efforts into the development of plant-based nutrients for the cultivation of Parry's Vegetarian Certified Organic Spirulina^TM, and has successfully produced a 100% Vegetarian Certified Organic Spirulina. The entire process, including the nature and origin of the nutrient inputs is, as stated above, fully inspected and certified under standards of both the USDA NOP and the European Naturland (accredited to the International Federation of Organic Agriculture Movement). These assure that no animal products or wastes of any type are used at any stage of the process of organic Spirulina cultivation and the certifying body provides written declarations to this effect. The statements made by The Companies are, at best, based on only their own limited research and knowledge, as, indeed, they have admitted. In any event they are wrong in every respect regarding Parry's Vegetarian Certified Organic Spirulina™.

Parry Nutraceuticals . has carried out the most rigorous testing and certification for its plants, processes, and products, far beyond what The Companies or any other Spirulina producers have achieved.The Parry Nutraceutical’s Spirulina plant operates under HACCP-food safety standards, ISO 9001-quality standards, and ISO 14001 Environment management standards certified by the BVQI, Amsterdam.Parry' s Certification program for quality and safety is far beyond anything that the U.S. producers have in place or can claim (with the last four applicable to both Certified Organic Spirulina and the "all natural" product).

Certified as	Parry Nutraceuticals Ltd. Organic Spirulina	US producers "Natural" Spirulina
USDA-NOP (1)	YES	No
Naturland Certification (2)	YES	No
Vegetarian (3)	YES	No
HACCP (4)	YES	No
ISO 14001 (5)	YES	No

Notes:
1) IMO, Switzerland
2) Naturland - Germany
3) IMO - Switzerland and Naturland - Germany declarations
4) BVQI, Amsterdam
5) BVQI, London

In addition, Parry's product is routinely independently tested for presence of bacteria and heavy metals, which are below or equal to those typical of the U.S. produced Spirulina. . Algal toxins (microcystins) are tested on each batch and are absent. Microbiology is tested on every batch and plate counts are actually well below the standards of The Companies. Heavy metals are checked frequently by independent outside laboratories. In brief, the Companies do not have the quality control of Parry Nutraceuticals . and certifications to back up their own claims for safety and quality, and their own product specifications and standards are more lax than those of Parry Nutraceuticals .

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?

Answer by Cyanotech:
Required before October 21, 2005 did not pose a risk to consumers.
Response by Parry Nutraceuticals:
Of course, the question itself is incorrect - Parry's Vegetarian Certified Organic Spirulina^TM is not higher in heavy metals than the "all natural" product of The Companies. Parry's Vegetarian Certified Organic Spirulina^TM has the same or lower heavy metals and bacterial count specifications as the non-organic (now so-called "all natural") Spirulina produced by The Companies. Anyway, if these companies had invested, as did Parry Nutraceuticals ., into developing vegetarian organic nutrients for organic Spirulina cultivation, they would now also be able to produce a wholesome Certified Organic Spirulina without any risk to the consumer. They did not and to cover-up their failure now claim that any Certified Organic Spirulina produced under the USDA NOP regulations is inherently unsafe.

Would The Companies consider organic production again if all conditions for its production were favorable?

Answer by Cyanotech:
Yes
Response by Parry Nutraceuticals:
None required.

Product Profile (Difference)
- Is Organic Spirulina better than All Natural Spirulina?
  
  Answer by Cyanotech:
  Organic Spirulina is not better than All Natural Spirulina in terms of its nutritional composition. However, various factors, such has increased growth rates, higher culture purity and non-animal fertilizers for All Natural Spirulina as well as the potential for higher heavy metal and bacterial levels in Organic Spirulina under the new rules, indicate that All Natural Spirulina may be a superior product.
  Response by Parry Nutraceuticals:
  Consumers prefer certified organic products because such certification assures that they are produced without chemical fertilizers and other synthetic and potentially harmful chemicals. Anyone can call their Spirulina "all natural", and produce it without any independent audit, oversight or certification. As already stated, Parry's Vegetarian Certified Organic Spirulina^TM is certified under both the USDA NOP and Naturland standards by the prestigious IMO (Institut fur Marktoekologie) in Switzerland, as being produced with only plant nutrients, without any animal inputs or chemical fertilizers. And also again, the levels of heavy metals and bacterial levels in Parry's Vegetarian
  
  Certified Organic Spirulina is similar or lower than in the so-called "all natural" Spirulina produced by The Companies .Technically and scientifically, there is no effect of "increased growth rates" on nutritional quality, and, anyway, this is not technically correct - they probably mean "increased productivity". Of course, organic fertilizers do result in somewhat reduced production, that is yields per acre, as is the case for organic production in general. Actually, in general, lower productivity increases the nutritive value of plant products, as forced growth with chemical fertilizers is well known to reduce the content of essential nutrients (vitamins, trace elements, antioxidants) in plants. Indeed, Parry's Vegetarian Certified Organic Spirulina ^TM has greater antioxidant values (carotenoids, phycocyanin) than the "all natural" Spirulina sold by The Companies. Some other vitamins, such as folic acid, and nutrients are also higher in Parry's Vegetarian Certified Organic Spirulina^TM. However Parry Nutraeuticals . makes no claims for any increased nutritional values for its product, at least for now.
- Is All Natural Spirulina better than Certified Organic Spirulina?
  
  Answer by Cyanotech:
  All Natural Spirulina is not better than Organic Spirulina in terms of its nutritional composition. However, All Natural Spirulina has increased safety compared with Organic Spirulina grown under the new rules.
  Response by Parry Nutraceuticals:
  We agree that so-called "all natural" Spirulina is not better than Parry's Vegetarian Certified Organic Spirulina^TM. We strongly disagree with the statement of "increased safety". As before, there is no basis for such a statement, The Companies provide no support for this statement, and it is not based on any theory, science or data. It is just fear mongering without the slightest shred of evidence to back it up. Again, Parry Nutraceuticals . produces its Certified Organic Spirulina at a production facility certified under HACCP (food safety management), ISO 14001 (environmental management), and cGMP.The Companies have not been able or willing to qualify for any of these quality and safety certifications! Thus, their "all natural" Spirulina is relatively LESS safe than Parry's Vegetarian Certified Organic Spirulina^TM. However, unlike The Companies, we in no way claim or imply that their product is unsafe or dangerous, or contaminated with toxins or disease organisms. We merely point out that our safety is assured by the highest possible standards under independent audits and certifications, something that the "all natural" Spirulina produced by The Companies has not achieved.

Product Profile (Definition)
- Can Organic Spirulina be considered Vegetarian or even Vegan?
  
  Answer by Cyanotech:
  Since the organic nutrient used is an animal-based fertilizer, it may not be considered Vegan or Vegetarian.
  Response by Parry Nutraceuticals:
  This is completely false for Parry's Vegetarian Certified Organic Spirulina^TMwhich, as amply discussed above, is produced "without any animal inputs/wastes, but with a vegetarian source of nitrogen and phosphorous" (see Declarations by IMO, Certifying Agency and Naturland, available in our website). It is thus truly Vegetarian and Vegan. (NOTE: We do not address or comment herein the nutrient status or production methods of any other "Certified Organic Spirulina" product currently being marketed as meeting USDA NOP standards).
- What is the definition of 100% Vegetarian?
  
  Answer by Cyanotech:
  Containing no animal-based substances.
  Response by Parry Nutraceuticals:
  This is correct and it applies to Parry's Vegetarian Certified Organic Spirulina.
- What does New Certified Organic Spirulina mean?
  
  Answer by Cyanotech:
  Spirulina produced under the new USDA National Organic Program, which was effective for Spirulina as of October 21, 2005. The rules eliminate Chilean Sodium Nitrate as an approved fertilizer. Chilean Sodium Nitrate is created through natural atmospheric processes and is completely natural and organic; however, it has potential to contaminate ground water when used to grow crops on soil. The USDA did not make an exception for Spirulina even though US growers use liners to prevent contact with soil and ground water.
  Response by Parry Nutraceuticals:
  Chilean Sodium Nitrate is not, by any definition, an "organic" nutrient, it is a mined inorganic mineral which, like other mineral and synthetic fertilizers has significant actual and potential environmental impacts, including to the atmosphere, at each stage of its production, transportation and use - asides from being a depleting non-renewable resource. For one example only, considerable nitrate is lost in the Spirulina ponds to denitrification, resulting in emission of nitrous oxide, N2O, a potent greenhouse gas and air pollutant. The residues of synthetic or Chilean nitrate nitrogen used in "all natural" Spirulina production eventually will find its way into the water, air and soils. By using plant sources of nitrogen, Parry Nutraceuticals . recycles nitrogen and minimizes or avoids these environmental damages, a major objective of the organic movement.
- What does All Natural Spirulina mean?
  
  Answer by Cyanotech:
  All Natural Spirulina is grown with mineral fertilizers, using Chilean Sodium Nitrate as a nitrogen source. No pesticides, herbicides, hormones, pasteurization, radiation or fumigation is used for its production. It is non-GMO and totally vegetarian.
  Response by Parry Nutraceuticals:
  There are no definitions, legal or even generally accepted, that define "all natural", so The Companies are free to use such terminology as they wish. Parry's Vegetarian Certified Organic Spirulina^TM also does not contain any pesticides, herbicides, hormones and the products are not exposed to irradiation or fumigation and its organic certification by independent agencies, assures customers that this is the case. The Companies can only make self-affirmations.
- How can you use the term "all natural" when you are using purified nutrients?
  
  Answer by Cyanotech:
  All natural food products use purified fertilizers during growth. Indeed some purified nutrients are allowed even in Organic Spirulina production. The Companies reproduce the same growing conditions found in wild Spirulina cultures, but takes additional steps to optimize safety.
  Response by Parry Nutraceuticals:
  Conventional foods, like "all natural" Spirulina, are grown with synthetic chemical nitrogen fertilizers and chemically treated mineral fertilizers (phosphates), produced using fossil fuels, and strong acids or bases, all processes that damage our environment during the fertilizer production. The desire to avoid the use of such chemical fertilizers is a major reason for the organic movement. Equally important, such "purified" nutrients lack important trace elements, which are provided by the nutrients used in organic agriculture. Claims by these companies that they reproduce the same growing conditions as in the wild, is as true as claiming that large-scale rice farming is equivalent to harvesting wild-crafted rice. Here the issue of safety is again raised, again without any basis or evidence.

Product Profile (Heavy Metal)
- 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?
  
  Answer by Cyanotech:
  Most natural foods contain trace amounts of heavy metals. The heavy metal content of the Spirulina produced by The Companies meets all state, federal and international standards.
  Response by Parry Nutraceuticals:
  As already stated Parry Nutraceuticals Vegetarian Certified Organic Spirulina^TM is as low as or lower in heavy metals than the "all natural" Spirulina and also meets all state, federal and international standards. Parry Nutraceuticals Vegetarian Certified Organic Spirulina is tested frequently in independent third party laboratories for heavy metal content. In fact, evidence of low heavy metal content and other contaminants is part of the USP Ingredient Verification Program under which Parry's Vegetarian Certified Organic Spirulina^TM product and facility is certified.
- 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?
  
  Answer by Cyanotech:
  Organic Spirulina produced under the new regulations may contain higher heavy metal content because of the use of nutrients that are derived from the digestion of animal and plant matter. These animals and plants would have accumulated heavy metals during their lifetime and this is further concentrated during the processing of the nutrients.
  Response by Parry Nutraceuticals:
  Of course, it "may", if produced carelessly or with contaminated fertilizers, as is also the case with "all natural" Spirulina. It depends on the care taken in production: that the fertilizers do not contain heavy metals, that the water is pure, that air depositions from adjacent industrial or agricultural areas are not a problem, etc. The implication that Organic Spirulina will by necessity be contaminated with heavy metals is completely wrong. If plants routinely had high heavy metal content, they would be unsafe for consumption. Again, the heavy metal content in Parry's Vegetarian Certified Organic Spirulina^TM is very low, with our specifications (the higher allowed limit), similar or lower than that of "All Natura", as verified by frequent analyses carried out by acclaimed third party laboratories.
- You state that your product has lower heavy metal content than that of Organic Spirulina. Do you have data
  to support that?
  
  Answer by Cyanotech:
  Yes
  Response by Parry Nutraceuticals:
  So where is the data? Why did they not release it? Of course, only an independent third party investigation of this issue would be credible. We challengeThe Companies to join Parry Nutraceuticals. and carry out such an independent study!
- The Companies supplied Organic Spirulina before. Was the product higher in heavy metals than All Natural Spirulina.
  
  Answer by Cyanotech:
  No, because the amount of non-mineral fertilizer required at that time was minimal. If we continue to grow Organic Spirulina with the new regulation we will have to use ten times the amount of organic nutrients, which would certainly result in a heavy metal content that exceeds regulatory requirements.
  Response by Parry Nutraceuticals:
  There is absolutely no reason that an organic fertilizer must be high in heavy metals. Of course, if not produced properly, it could be, as is also the case for mined fertilizers. This statement again demonstrates at best the very limited research and development efforts by The Companies to identify a good alternative to mined and synthetic fertilizers. And, also again, the claim that the regulations would require them to use "ten times the amount of organic nutrients" is without any basis whatsoever.

Product Profile (Bacteria)
- 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?
  
  Answer by Cyanotech:
  Spirulina grown in a high concentration of organic nutrients may have a higher bacterial count since bacteria thrive on such organic nutrients. However this may not be noticeable in the final product if producers take further processing steps like pasteurizing, irradiating, fumigation, etc. The Company's production methods are extremely hygienic and sterile, so their All Natural Spirulina has naturally occurring low levels of bacteria and is minimally processed.
  Response by Parry Nutraceuticals:
  Bacterial counts are similar or lower for Parry's Vegetarian Certified Organic Spirulina^TM than for so-called Natural Spirulina. We pride ourselves in our careful washing and drying techniques that produces a low bacterial plate count and nutritious product. Irradiation and fumigation are not allowed as per the SOP's of HACCP and the organic certification standards of USDA NOP and Naturland, Germany. These competitors have no HACCP or GMP certification; all their claims are self-affirmations. Indeed, it is incorrect to state that their production facility is "sterile"; that is technically impossible, and suggests that these FAQs were written without review by the scientists at these Companies. As already stated, Parry Nutraceuticals ' Certified Organic Spirulina is not subjected to any of the "processing" steps listed by The Companies: after harvesting with screens it is just washed, spray dried, and packaged.
- Do you have data to support that All Natural Spirulina has a lower bacterial content?
  
  Answer by Cyanotech:
  Yes
  Response by Parry Nutraceuticals:
  Again, we would like to see that data, but even long-term customers of theirs do not get to see it. Every batch of Parry's Vegetarian Certified Organic Spirulina^TM is tested for microbiology and it is as good as or better than any other Spirulina manufacturers in the world and in particular better than that of The Companies. We also do specific analysis in third party laboratories in India, US, EU, Japan etc. for proving conformance to the local food standards.

Nutrient (Nitrogen)
- Why is nitrogen important to the growth of Spirulina?
  
  Answer by Cyanotech:
  Nitrogen is an important component of amino acids, the building blocks of protein. It is also a component of many important enzymes that are themselves proteins. Since Spirulina is approximately 60% protein, it requires a large amount of nitrogen for growth.
  Response by Parry Nutraceuticals:
  True
- What does the "new nitrogen sources compromise safety & quality" statement mean?
  
  Answer by Cyanotech:
  The new nitrogen sources are potential sources of toxins, disease organisms and heavy metals.
  Response by Parry Nutraceuticals:
  False. Of course, if the word "potential" means that anything is possible, that could be true for some products on the market. We cannot comment on some of the products now on the market as we have not carried out any independent studies of those (and neither have The Companies). But we categorically reject such statements as applying to our products. The "new nitrogen sources" would be no more potential sources of toxins, etc., than any other inputs to the production process. It is totally false and irresponsible to make this statement. Parry Nutraceuticals has made a large investment identifying the best alternative to mined Chilean Nitrate and has replaced this inorganic mined chemical with a safe 100% plant-based nutrient as a source of nitrogen and phosphorous.
- What are the "new nitrogen sources" allowed by the National Organic Standards that may compromise safety
  & quality?
  
  Answer by Cyanotech:
  There are several sources but they are all derived from plant and animal waste fermentation. Some of the animal-based sources are compost teas and various manures.
  Response by Parry Nutraceuticals:
  True, there are several potential sources, and they must be either animal or vegetal, as mineral (e.g. Chilean Nitrate) is no longer permitted. However, it is unlikely that animal wastes would actually be allowed for organic certification, and, in any event, Parry's Vegetarian Certified Organic Spirulina^TM is produced using only plant-based nutrients, with no animal inputs of any kind. This is independently certified by IMO, Switzerland under USDA NOP and Naturland standards. Thus the entire issue of using animal wastes is not an issue at all.

Nutrient (Animal Fertilizer)
- All Natural US Grown Spirulina has a checkmark for Non-Animal Fertilizer. Does it mean that Organic Spirulina
  is grown with Animal Fertilizer?
  
  Answer by Cyanotech:
  Yes
  Response by Parry Nutraceuticals:
  FALSE! This may have been true for the organic Spirulina that The Companies were thinking of producing, or could be true for other entrants into this market, but it does not apply to Parry's Vegetarian Certified Organic Spirulina^TM which is produced using plant based nutrients certified by IMO (Switzerland) under USDA NOP and Naturland standards.
- What are the Animal Fertilizers used to grow Organic Spirulina?
  
  Answer by Cyanotech:
  Compost tea and various manures.
  Response by Parry Nutraceuticals:
  FALSE for Parry's Vegetarian Certified Organic Spirulina^TM! see above.
- Does that mean the organic product The Companies used to produce was grown with animal fertilizers?
  
  Answer by Cyanotech:
  Yes. One kind of animal fertilizers was used in minimal amounts.
  Response by Parry Nutraceuticals:
  This mean that Organic Spirulina supplied by The Companies was not vegan or vegetarian in the past. Did they inform their customers about this fact previously? How many vegans consumed their Spirulina thinking it was such?
- 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.
  
  Answer by Cyanotech:
  In conventional agriculture the edible part does not come into contact with the fertilizer as such. In aquaculture the nutrient is always in the water in which the Spirulina is suspended. Because of his there is more risk for safety in Organic Spirulina produced during high levels of organic nutrients
  Response by Parry Nutraceuticals:
  There is no basis for an increased risk for chemical vs. organic fertilizers. Food safety must be followed in all cases in all aspects of the process. Only a facility that follows and is certified for having in place internal control and standard operating procedures that are part and parcel of HACCP and USP certification can make this claim. The Companies cannot, only Parry Nutraceuticals . can back up its claims that it produces a safe product with the rigorous and independent certifications.

Nutrient (Purified Nutrients)
- What do you mean by "Purified Nutrients"?
  
  Answer by Cyanotech:
  Fertilizer sourced or processed in such a way as to minimize contamination from potentially toxic or otherwise undesirable substances
  Response by Parry Nutraceuticals:
  Correct. Similarly, Parry Nutraceutical uses purified Vegetarian / plant based nutrients for the production of Parry's Vegetarian Certified Organic Spirulina^TM.
- 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?
  
  Answer by Cyanotech:
  The potential does exist. However, careful management by The Companies ensures that it does not happen. The Companies use closed-loop production systems and lined ponds that assure all the fertilizers are consumed by the algae
  Response by Parry Nutraceuticals:
  Parry Nutraceuticals was the first, and thus far only, Spirulina company to have their production plant and process certified (BVQI, London) for the Environmental Management System ISO 14001. This highly stringent process ensures that the environmental issues are never compromised in and around our facility. The real issue here is that The Companies use chemical and mineral forms of nutrients that by their very nature pollute the environment, during the manufacturing process and during its use. There are real impacts on the environment from using chemical fertilizers.

Others
- Why would it cost more for The Companies to produce Organic Spirulina under the new Standard?
  
  Answer by Cyanotech:
  Because of the high cost of nutrients and high cost of quality assurance. In addition long term studies would be required to assure safety to consumers.
  Response by Parry Nutraceuticals:
  The Companies do not want to spend money on quality assurance, which is no different for Certified Organic vs. "all natural" Spirulina. This is evidenced by their lack of certifications for product quality and food safety. Arguing that change in fertilizers requires new long-term safety studies is incorrect. They did not do such studies when they switched from synthetic chemicals to Chilean nitrate a few years ago. The change in inputs need not change the composition of Spirulina. Parry Nutraceuticals . has done a complete nutritional and safety analysis of our 100% Vegetarian Certified Organic Spirulina in third party labs. As discussed earlier, Parry's Vegetarian Certified Organic Spirulina^TM specification on heavy metals, bacteria, toxins, etc. are similar to the "all natural" Spirulina.
- Is it important to know that there is a high growth rate for All Natural Spirulina?
  
  Answer by Cyanotech:
  Yes. The higher the growth rate is, the more active and viable the algae are.
  Response by Parry Nutraceuticals:
  This is not true. Ponds are operated on a certain cycle, set by the operator trying to maximize production. It has nothing to do with active or viable, or nutrition or safety.
- What do you mean by minimally processed?
  
  Answer by Cyanotech:
  No pasteurization, irradiation or fumigation is used to improve safety and/or quality.
  Response by Parry Nutraceuticals:
  This is also the case for Parry's Vegetarian Certified Organic Spirulina^TM, which is certified not to use such techniques, "all natural" Spirulina is not.
- Do The Companies have supporting data for all the contention made on the checkbox in the press release
  and advertising?
  
  Answer by Cyanotech:
  Yes
  Response by Parry Nutraceuticals:
  Again, where is that supporting data? Why not release it? Parry Nutraceuticals has data to validate from our certifying bodies, third party and our own labs to answer all the blank data spaces given in the advertisement
- How does Spirulina grow naturally in lakes in Africa and formally in Mexico?
  
  Answer by Cyanotech:
  Spirulina grows in the presence of dissolved minerals, exactly the same way that All Natural Spirulina is grown now by The Companies. Animal manures, and compost teas are not added in nature, so in a sense the production methods used by The Companies for their All Natural Spirulina are closer to nature than "organic Spirulina" processed under the new regulations.
  Response by Parry Nutraceuticals:
  There is no synthetic (or even Chilean) nitrate in nature where Spirulina grows. Where does Spirulina growing in the wild get nitrogen and phosphorous from? Yes, from the recycling of the organic N released by decomposing plant matter and other organisms. The process of converting organic vegetable nitrogen to forms available to Spirulina is indeed somewhat laborious and expensive, and clearly these producers have not managed, or even tried, to develop such techniques.
- Who would I contact if I want to express my concerns about these changes?
  
  Answer by Cyanotech:
  You would want to contact the USDA directly
  Mr. Mark Bradley, Associate Deputy Administration
  USDA-AMS-TMP-NOP
  Room 4008, South Building
  1400, Independence Ave. Saw.
  Washington - DC - 20250
  Tel: 202 - 720 - 3252 Fax: 202 - 205 - 7808
  Email: NOPcompliance@usda.gov
  Response by Parry Nutraceuticals:
  So finally they come out with it - if you can't join them try to get the government to regulate them away. This speaks for itself.

What does having the USDA organic Certifications mean?

Having the USDA certification and logo for our Spirulina means that the production, processing and marketing for our Spirulina are in compliance with the control procedures outlined in the USDA (United States Department of Agriculture) AMS 7 CFR part 205, National Organic Program. The IMO (Institute of Marketecology) , based in Switzerland is our certification agency for USDA - NOP standards.
To know more please visit www.usda.gov

What does having the ECOCERT certifications mean?

ECOCERT is a control and certification organization based in France, whose main responsibilities include setting up of control standards for Organic farming, in this case for aquatic plants. ECOCERT activities are governed accordingly by public authorities and Legislation.
To know more please visit www.ecocert.com

What does having the Naturland Certifications mean?

Naturland e. V. is a private organization based in Germany whose organic certification standards are even more stringent that than those of the German national eco label, Bio-Siegel. Here Naturland also confirms that Parry’s Spirulina is grown using vegetarian sources of Nitrogen and Phosphorous, and also that no animal based inputs / wastes are used which are proved during every Naturland inspection. This ensures that Parry’s Spirulina is 100 % vegetarian.
To know more please visit www.naturland.de

What does having the OCIA Certifications mean?

The OCIA (Organic Crop Improvement Association) is a non profit organization that is one of the oldest organic certification bodies based in Nebraska, USA. Our OCIA certification is accredited under IFOAM - the International Federation of Organic Agriculture Movement, which unites 750 International Organizations in 108 countries.
To know more please visit www.Ocia.org

What does having the ISO 9001 Certifications mean?
ISO is the international organization for standardization, the world’s largest developer and publisher of international standards ISO coordinates between public and private sectors.

The ISO 9001 standards are part of the ISO 9000 series of “Quality management”, this means what the organization does to fulfill.
- The customer’s quality requirements, and
- Applicable regulatory requirements, while aiming to
- Enhance customer satisfaction, and
- Achieve continual improvement of its performance in pursuit of these objectives
To know more please visit www.iso.org

What does having the ISO 14001 Certifications mean?
ISO 14001 is part of 1SO 14000 family of standards for “Environmental Management”, this means what the organization does to
- Minimize harmful effects on the environment caused by its activities, and to
- Achieve continual improvement of its environmental performance.
To know more please visit www.iso.org

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 produces a product in great demand by the public, by falsely alleging that the competing product is "unsafe".

We at Parry Nutraceuticals, 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 . 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.

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.

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.

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.

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.

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.

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.

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.

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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