By Amit Tewari

The Impossible Burger is out right now, and there has been a lot of angry discussion online around the question below:

What should we think of Impossible conducting animal testing on rats, resulting in over 180 rats killed, to get through FDA Approval?

We’ve promoted the Impossible online (which is weird as currently it’s only available to Grill’d nationally), and in doing so, have caused a stir amongst some of our customers.

We’re an early stage company, and so the reality is the vision and values of Soul Burger is really the values and vision I have for Soul Burger. So I’m going to make a new rule where everyone time we do something controversial, and it prompts a mini backlash, I’m going to explain why we’re doing it and what we believe.

So let’s begin

  1. Why is Impossible Foods Different? (You’ll notice Beyond and co. haven’t caused such controversy)

Impossible Foods is a company trying to emulate meat as closely as possible. They’ve raised $100’s of millions in their quest to do so. This doesn’t make them unique, as thankfully, there are hundreds of plant-based companies out there doing the same thing.

The distinction with Impossible Foods is they believe that leghemoglobin, an oxygen carrying protein similar in structure to hemoglobin, is a critical plant-based protein that has been missed by every other company. They believe that leghemoglobin, when cooked, is absolutely critical in emulating the magic taste of cooked meat.

This is essentially the point of difference for Impossible. Without that, they are basically another plant-based company using soy and coconut fats to make burgers.

The reason for their astronomical valuation ($7 Billion), is due to their technology involving recombinant yeast product. From Forbes: “A simplified explanation of the process is that they insert the DNA for soy leghemoglobin into yeast, grow yeast through fermentation, isolate the soy leghemoglobin and add it to the burgers”. This is similar to how we make insulin, beer and is also the technology behind the soon-to-come “dairy-free milk/cheese” company’s like Perfect Day.

2. The Animal Testing Incident

The TLDR version is this: In order to be able to actually sell their burgers using leghemoglobin, Impossible Foods had to get FDA approval through a process called GRAS. The FDA *sort of* requires animal testing be conducting to get GRAS status, by only granting “No Question” letters to companies who do this testing. As someone in reddit wrote, trying to retail national and internationally without this letter is kind of like going to job interviews without a shirt. Technically you can do it, but you probably won’t get the job (i.e. Impossible will be extremely unlikely to sell their product nationally or internationally and could potentially have their products pulled from shelves.)

Here is an excerpt from the Good Food International explaining this:

Establishing that such new ingredients are safe requires participation in the FDA food safety process called Generally Recognized As Safe (GRAS). Establishing the GRAS status of a new protein through the FDA process is an important part of providing assurance to consumers that new ingredients are safe to consume, as well as satisfying the needs of retailers and governmental agencies worldwide.

Unfortunately, FDA essentially requires that companies conduct animal tests if they want to introduce novel ingredients into the food supply. Although these tests have been painted as discretionary in some quarters, in fact, FDA appears to require animal tests of any company that wishes to receive explicit acknowledgment from FDA that its new ingredient is safe (called a “no questions” letter).

For example, this letter may be required by major retailers like Walmart, by other significant customers (e.g., McDonald’s would almost certainly not sell a product that did not have such a letter), and by governments considering import of a product. Additionally, the lack of such a letter could result in FDA finding that a company’s products were “adulterated” (because the company had not shown safety to FDA’s satisfaction). This would cause all of the product to be pulled from shelves and sale prohibited. 

So while some might argue that testing is not legally required, the alternative is that companies may be unable to sell their products to some major U.S. retail outlets and internationally, and it could result in the product not being allowed to be sold at all, thwarting the goal of replacing animals in the food system.

3. How most vegans think about tricky moral dilemmas

The next part I’m going to write about is the way most vegans think about moral dilemmas.

Most vegans try to do their best to reduce animal harm and exploitation. Most vegans also support the following 2 practices:

  1. Using modern technology and medicines testing on animals
  2. The spay and neutering of pets (despite the process violating autonomy of cats/dogs and killing 0.3% in the process).

The first practice indicates most vegans agree that we live in an imperfect world and we should ensure our health is not compromised by a steadfast holding to principles against animal testing (though the hope is, in the future, animals are no longer exploited and killed in this way).

The second practice indicates that most vegans, on some level, believe the ends justifies the means. They acknowledge there is potential non-consensual harm being done to cats and dogs but believe we should do it anyway for the greater good. I got this analogy from Bettereating.orgread here for more.

Regarding the second scenario, the thinking looks like the below:

  1. How many animals would be harmed if there was no spaying and neutering of pets? (backyard breeding would be rife, pounds even more overrun, more euthanasia and so on)
  2. How many animals would be harmed if there was widespread or mandatory spaying and neutering of pets? (take the statistic 0.3% of animals are unfortunately killed)
  3. Which practice is best for animals altogether? (weigh up the two practices and choose which practice results in less suffering and death for animals).

Broadly, this is utilitarian thinking, and most of us use it until the conclusions become a little too repugnant.  

4. Applying this thinking to the Impossible Burger

How you think about Impossible Foods, also depends on what you think Impossible Foods *represents* and the potential impact it can have.

If you think Impossible is just a place that makes burgers, and ffs that isn’t comparable to medicines, then you’ll rightly think *more* animal testing isn’t morally justifiable.

You’ll say, “Yes it’s true that pea proteins, hemp proteins etc have also been tested on animals. BUT Impossible should just use whatever is already in the market (and has already been animal tested)! Why would they create more animal suffering just for a “food colouring”? Are vegans really this glutinous and immoral? Just a for a burger you would support 180 rodents being killed? Wtf kinda veganism is this?”

In the words of Samuel L Jackson from Pulp Fiction, allow me to retort.

This isn’t just about a burger. I view plant-based/vegan restaurants, manufacturers, influencers, consulting groups, investors etc. all part of a market-based *movement* to replace animal use and suffering. Essentially we are working *within* peoples choices to persuade them to make choices that don’t harm animals (or harm them less).

This market-based movement works synergistically with non-market based movements (like charities, activists, politicians etc) that aim for the same goal (but will often act to confront people’s choices through disruption, protest etc).

Our goal is, at some point in the future, the combination of social pressure, cultural change and ridiculously good meat-alternatives, will render the whole industry of industrial animal agriculture obsolete.

We want industrial animal agriculture to go the way of the horse and buggy (more on this later).

If that *does* happen, and whole system becomes obsolete, you are now talking about *BILLIONS* of animals being spared a horrible reality *each year*.

To put this another way – every year we do not innovate fast enough in all these categories, is another year that delays this reality we want. We are talking about potentially billions of lost lives with every year of delay

5. The current state of the meat-alternative industry

Here is how I view the current alternative meat industry

  1. We are currently at Stage 3 (randomly picked number) out of Stage 10 in regards to meat alternative innovation. Market penetration is very low and most customers still look at these alternatives as the not-as-good cousin of regular meat.
  2. The *current* Beyond Burger and the Impossible Burger (Stage 3), will in 15 years, *hopefully* look like those old potato patties from the 80’s look to us today (lets call this Stage 1). They will be super average, because the innovation by then will be amazing (we may be at Stage 6).
  3. However, this is not inevitable. In order to get beyond Stage 3, we need to keep innovating past cooked Soy TVP and Pea Proteins. We need to push the envelope dramatically, because today, the impact of plant-based foods is not even remotely strong enough to warrant closing factory farms due to a lack of demand. We need to get much, much better.
  4. This involves trying everything science has to offer to truly replace and *exceed* the current taste of animal meats. Cell-cultured meats. Plant-based 3D Printing. Using recombinant yeast to produce proteins found in animals. Anything that has a hope, we should encourage companies to pursue.

So… we have a lot of work to do!

I hold Soul Burger in this category of market-based actors trying to bring about a world without using animals for food. As opposed to *making* plant-based foods, our goal is to retail plant-based foods so brilliantly that we spur cultural change and mainstream consumer adoption.

And it works! Without vegan restaurants, mainstream restaurants like Zambreros, GYG, Grill’d, Schnitz etc wouldn’t be retailing plant-based foods. They watch us, see that we have a market, and then try to capitalise on this market. It’s a little ruthless, and it often means the original innovators die in the process, but it’s also the only way mainstream change is going to occur.

A post-animal food system probably won’t see MacDonalds go bankrupt. Instead, it will probably see Macdonalds gradually retail cultured and plant-based proteins because they taste better, are less expensive and are what younger, progressive customers want.

6. So what’s the main takeaway

Firstly, we need to innovate much more, and much faster, if plant-based foods and spaces are actually going to make a tangible impact on animal suffering.

Secondly, to do this, we need to continue to use new and innovative proteins and methods to create alternatives to meat that not only match, but exceed, current animal protein.

Thirdly, and sadly, Food Authorities will require animal testing to occur for these new methods and proteins. We should try to change this, but given the reality, we should *not* stop innovating. We will have to work within this to spare much more animal suffering in the future.

This doesn’t mean we should randomly encourage companies to conduct animal testing. Rather, on a case by case basis, if the novel ingredient/method has genuine promise to spare much more harm to animals in the future, then we should morally approve of testing that has to take place.

When it comes to thinking about animal welfare, *the animals* don’t have time for purist thinking. We need to do what helps the most amount of animals the fastest. For restaurants this can involve doing council mandated pest controls. For food manufacturers, this can involve the same dilemma, as well as introducing new innovative methods that require animal testing.

I’ve made my peace with this a long time ago. I remember chatting to Uma Valeti from Upside a couple years back, and telling him I hope one day Soul Burger would have a national presence and we would be influential in pushing mainstream adoption of cultured meat (even though I knew they were using foetal calf serum in their research).

Remember –

  1. People didn’t stop using paper and start using USBs because they loved trees.
  2. People didn’t stop farming pigs for insulin (2 tonnes of pig parts for 8 ounces of insulin!) because they loved pigs.
  3. People didn’t give up the horse and buggy because they loved horses.

In all these cases, and many more, the existing technology was literally rendered obsolete.

My hope is for a future where animal-based meat will one day share the same fate.

I appreciate there will be some folks who just can’t get behind this kind of thinking. I get it. But don’t be the ones to literally *stop* the innovation occurring. Because if you do, you’re essentially holding hands with the meat industry in trying to stop innovation in this space occurring. And this is what keeps there CEOs up at night.

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