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Acetobacter Aceti and Kluyveromyces Lactis August 2016

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Acetobacter Aceti and Kluyveromyces Lactis August 2016 Staff Assessment Report APP202920: to determine the new organism status of Acetobacter aceti and Kluyveromyces lactis August 2016 Purpose To determine if Acetobacter aceti and Kluyveromyces lactis are new organisms under Section 26 of the HSNO Act Application number APP202920 Application type Statutory Determination Applicant Natural Solutions NZ Ltd Date formally received 21 July 2016 EPA Staff Assessment Report: Application APP202920 Executive Summary and Recommendation Natural Solutions New Zealand Ltd has submitted the application APP202920 in order to seek a determination on the new organism status of Acetobacter aceti and Kluyveromyces lactis. After reviewing the information provided by the applicant, EPA staff recommends the Hazardous Substances and New Organisms (HSNO) Decision-making Committee determine that Acetobacter aceti and Kluyveromyces lactis are not new organisms for the purpose of the HSNO Act. 2 EPA Staff Assessment Report: Application APP202920 Table of Contents Executive Summary and Recommendation ........................................................................................ 2 Table of Contents .................................................................................................................................. 3 1. Introduction .................................................................................................................................. 4 Purpose of this document .............................................................................................................. 4 The application .............................................................................................................................. 4 2. Summary of information ............................................................................................................. 4 Acetobacter aceti ........................................................................................................................... 4 Table 1: Summary of locations Acetobacter aceti has been isolated from: ........................ 6 Kluyveromyces lactis ..................................................................................................................... 6 Table 2: Summary of environments Kluyveromyces lactis has been isolated from: ........... 7 Ubiquity of microorganisms ........................................................................................................... 7 3. Evaluation against legislative criteria ....................................................................................... 7 Acetobacter aceti ........................................................................................................................... 8 Kluyveromyces lactis ..................................................................................................................... 8 4. Comments from government agencies ..................................................................................... 9 5. Overall findings and conclusion ................................................................................................ 9 6. References ................................................................................................................................. 10 Appendix 1: Correspondence ............................................................................................................ 13 Appendix 2: Comments from MPI ...................................................................................................... 14 Appendix 3: Decision path for section 26 determination ................................................................ 16 Context ........................................................................................................................................ 16 Introduction .................................................................................................................................. 16 Figure 1 Flowchart: Decision path for applications under Section 26 for determination as to whether an organism is a new organism ........................................................................................................ 17 Figure 1 Explanatory Notes ......................................................................................................... 18 3 EPA Staff Assessment Report: Application APP202920 1. Introduction Purpose of this document This document has been prepared by Environmental Protection Authority (EPA) staff to advise the Hazardous Substances and New Organisms (HSNO) Decision-making Committee (the Committee) of our assessment of application APP202920 submitted under the HSNO Act (the Act). This document discusses information provided in the application and various other sources. The application The application from Natural Solutions NZ Ltd was submitted under section 26 of the Act to determine whether Acetobacter aceti (Pasteur 1864) Beijerinck 1898 and Kluyveromyces lactis (Dombrowski) van der Walt 1971 are new organisms for the purpose of the Act. This application was formally received by the EPA on 27 July 2016. The applicant had previously been importing these organisms contained within a kefir starter culture trading under the name Bravo manufactured in Switzerland by Silver Spring Sagl. Prior to June 2016 the applicant had imported this product under the Import Health Standard for the Importation into New Zealand of Specified Animal Products and Biologicals (INEPROIC.ALL). This import health standard allows for the import of ‘commercially manufactured food cultures, enzymes or starters derived from or consisting of micro-organisms’ and ‘brewer’s yeast, baker’s yeast or any other yeast products in the food industry’ from any country. As of 27 August 2015 a clause was added to the import health standard stating that there may be additional requirements for microorganisms under the HSNO Act. Therefore the applicant contacted the EPA for a formal determination on Acetobacter aceti and Kluyveromyces lactis to be able to continue importing the starter culture product into New Zealand. The applicant considers Acetobacter aceti and Kluyveromyces lactis to be naturally occurring in the New Zealand environment and widely used in the food industry. Therefore, the applicant considers these organisms to be not new for the purpose of the HSNO Act. Our assessment considers the information contained within the application and any other relevant information that we found in scientific literature or elsewhere. 2. Summary of information Acetobacter aceti Acetobacter aceti bacteria are gram-negative, obligate aerobic rods which can oxidise ethanol into acetic acid (Matsushita et al 2005). Acetobacter aceti is ubiquitous in the environment, existing in alcoholic niches in flowers and fruit, and in soil and water. The main industrial use of A. aceti is for the production of vinegar (US EPA 1997). 4 EPA Staff Assessment Report: Application APP202920 Worldwide, acetic acid bacteria (AAB) play a large part in the production and spoilage of wine. Acetobacter aceti is an AAB that is normally associated with grapes and wine. The exposure of wine to oxygen during the production process often leads to a proliferation of A. aceti bacteria. High numbers of A. aceti bacteria in wine results in a product with undesirable traits such as high volatile acidity and a vinegary taint (Du Toit et al 2005). Acetobacter aceti can be isolated from unspoiled grapes in low amounts, and from damaged grapes in much higher numbers (Guillamón and Mas, 2009). Work has also been done on the main species of AAB present on grapes/musts and wine. Acetobacter aceti is found throughout the production process (i.e. on grapes/must, mid fermentation and end fermentation) particularly on botrytized grapes1 in France, cabernet sauvignon in South Africa, and red Grenache in Spain (Unden and Frohlich, 2009). While we could find no evidence that A. aceti had been isolated in grapes and wine in New Zealand it is unlikely that New Zealand remains untouched by A. aceti given its ubiquity in the wine industry. Commercially, A. aceti is commonly used to ferment alcohol into vinegar. There are several companies in New Zealand that produce vinegar for the domestic market. There are also companies that export vinegar to New Zealand. Dominion Yeast Company Ltd (DYC) was established in Christchurch in 1915 and produces a range of vinegar products. These products are made in New Zealand by natural fermentation using A. aceti (DYC, 2016). Another New Zealand based company, Ceres Organics, produces a raw apple cider vinegar that ferments New Zealand apples with A. aceti. This product is unpasteurised, unfiltered, and undiluted. Bragg Live Foods is an American company that produces a variety of organic foodstuffs. Braggs have been exporting raw apple cider vinegar to New Zealand since 2002. Braggs apple cider vinegar is unfiltered and unpasteurized, and is fermented with A. aceti (Appendix 1). These three companies, and other vinegar producers in New Zealand (Coraltree Organics, Artisan Vinegar, Chantal Organics, Goulter’s Vinegar Products) mention that, over time, their products may develop the ‘mother of vinegar’. The mother is a non-toxic film that accumulates on the surface of vinegar during oxidisation and is made up of AAB and cellulose. Acetobacter aceti, along with several other species from the Acetobacter, Gluconacetobacter and Komagataeibacter genera are commonly detected in the mother of vinegar (Yetiman and Kesmen 2015). All of these products
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