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Preventing food fraud: testing is not the answer

Fraudulently adulterated food is receiving a lot of attention at the moment. While it is widely acknowledged that food fraud is a large and expensive problem requiring urgent action there is not a lot of practical advice available about exactly what actions food businesses should take to prevent, deter and detect food fraud. And, although published advice about direct action is rare, there is plenty of commentary that discusses the issue in general terms, including one very common refrain: food testing is not the answer.

Food safety hang-ups

One of the reasons we so often hear that testing is not the answer is that many food fraud commentators come from a food safety and quality assurance background. As such, our unwillingness to rely on testing for food fraud can be explained in part by our familiarity with food safety systems. Within the realms of food safety, testing can achieve nothing on its own; the prevention of risks and control of hazards is much more effective and efficient, with testing used simply to verify that the system is working.

For those who are less familiar with food safety systems, let’s take a closer look. For the sake of simplicity, imagine a hypothetical food safety system that is designed solely to prevent the growth of a pathogenic microorganism in salami. If the system relied solely on testing, one would have to take a sample from every pack of salami, test for pathogens and then discard packs which were found to be contaminated. A missed test could have deadly consequences. Worse still, the sampling itself could lead to contamination. A better way is to use preventive control methods to stop hazards before they arise and carefully monitor critical operations in the production process so that the finished product is safe. This combination of prevention and monitoring is the basis for every modern food safety system. Within those systems the food must still be tested to verify that the system is working but in fact every piece of salami that is consumed without causing illness is a form of ongoing verification.

Dairy Processing

Fraudulently adulterated food is very different from accidentally contaminated food. It usually doesn’t make people sick and can rarely be identified as fraudulent by the consumer. People who adulterate food for financial gain aim to avoid detection and for that reason adulterated food rarely causes acute illness. In fact, the Chinese government is currently assuring its citizens that the large volumes of counterfeit baby formula within that market are safe to consume. There have been instances of fraudulent food that caused illness and death, including the melamine milk scandal in China and toxic mineral oil passed off as olive oil in Spain. In another famous case, a carcinogenic industrial dye was used to make paprika powder appear fresher. In each of these cases it was some time before the link between illness and adulterated food was found.

Criminals are smarter than Salmonella.

The prevention of microbial contamination and growth in food can be achieved in a few simple steps using well-understood methods; Salmonella hasn’t figured out how to outsmart a thermal kill step yet. But people who seek to make money from adulterating food have much more imagination than your average bacterium. While there are only about 120 food borne pathogens known to man, there are almost unlimited ways to tamper with food, meaning many different types of controls are required. Unfortunately, any effective control method can be discovered and then outsmarted by a clever fraudster, making reliance on prevention a risky proposition. And the worst part is that no matter how effective a fraud prevention system is, at the end of the day it is indistinguishable from an ineffective fraud prevention system to the naked eye; without very frequent testing there is no way to know the system is working.

More testing?

Testing is a key element of effective fraud prevention. I envisage a day when every food manufacturer tests vulnerable raw materials before they are used in production, where every supermarket has the technology to verify that their food is authentic before they place it on their shelves and where even local restaurants will have access to cheap and fast authenticity testing. Testing holds the answers to many of our current food fraud challenges.  However, testing can be expensive, time consuming and much less effective than we would like.

Pesticide residue in food

A key challenge to the efficacy of testing is that when it comes to food fraud we can never be sure of the adulterant that might be present. Many currently available test methods are targeted for a particular adulterant, and are not designed to detect adulterants that are unexpected. Non-targetted tests are rapidly being developed but there are still relatively few that have been properly validated, a process that requires expensive cross-testing against other methods such as botanical testing, DNA-based methods and classical chemistry.

In less than five years, claim the makers of new rapid testing technology, we will be able to hold a scanner in our hand that can tell us the entire molecular makeup of our food. I think we will have to wait a little longer than that; food is complex and a huge amount of research will be required before we can properly interpret the results of complex molecular ‘scans’ of every food on the planet. But testing is an important tool in our fight to ensure an authentic food supply, and that’s a goal worth striving for.

Read about the latest food fraud analytical technologies here.

Are you ready to start testing for food fraud? Use our testing checklist to find out.

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Honey Fraud This Month: The Good, The Bad and The Ugly

Honey authenticity is all over the (food fraud) news this month.  There’s good news.  And bad.

Here’s what’s happening in honey fraud right now, from Karen Constable of authenticfood.co and Food Fraud Advisors.

 

 

Video transcript:

(Karen Constable) “It’s been a tough year for honey.  There has been lots of commentary about food fraud in honey, following a big recall in the UK at the end of last year and controversy over honey testing methods.  It’s never good to hear about food fraud issues, but there is a silver lining.

The Good

The Canadian government last year committed to spending more than $20 million on food fraud testing and intelligence gathering over a five year period.  Honey is one food product that has been chosen for surveillance by the Canadian Food Inspection Agency.

The CFIA published their honey surveillance results this month and guess what?! Authenticity is up and food fraud is down compared to last year.

The CFIA sampled both the marketplace at large and also a number of bulk honey importers and processors that were deemed to be high risk.  Only 13% of samples were deemed not-authentic, compared to 22% the previous year.  That’s a significant improvement!

The CFIA used the results of their previous honey surveillance work to design a targeted sampling plan.  Those samples that they targeted had risk factors such as a history of non-compliance, known preventive controls deficits and unusual trading patterns.  This type of targeting sampling, in which previous results are used to focus on known problem areas, is a great way to maximise the value of authenticity testing (which can be expensive).  Way to go, Canadia! (PS for more on sampling methodology, click here)

Of those samples collected from the marketplace (that is, without being targeted towards high-risk products), 98% were authentic and the only products that had ‘unsatisfactory results’ were imported products.

So testing = good.  For my food safety viewers, it’s worth noting that – unlike micro testing – food authenticity testing can not only provide valuable insights into the occurrence of food fraud but also helps to prevent it.  The fact that someone is paying attention, and doing testing can effectively drive reductions in fraud, as we have seen with the Canadian honey testing regime.  My prediction is that next year’s surveillance will have even better results than this year’s.  And that’s something to be happy about!

The Bad

The Canadian government isn’t the only one that’s been testing honey this year.  The Indian Centre for Science and Environment and a government-funded institute in the Philippines have also published honey testing results this month.

In the Philippines, a survey of 74 locally-produced honeys purchased online found that 87% of them contained sugar syrup.  Ie rendering them NOT authentic honey.  More than 80% of these products actually contained no honey at all and were just made from sugar syrup.

These are some of the worst authenticity statistics that I have ever seen!

Local products purchased in brick and mortar stores fared a little better in this study, but the results were still bad, with around 75% of samples containing adulterant(s). Interestingly, in the Philippines, imported honeys performed significantly better than the locally-produced honeys, the opposite of what was seen in Canada.

So those results were pretty bad, but it is good to see authenticity testing being done in the public arena more frequently than in the past.

The Ugly

Yep, this is really ugly.

There’s testing and then there’s testing….

India is another country that is funding food adulteration prevention. And, of course, that’s a good thing.  And they are testing honey.

However, like many countries, India’s legal definition of honey is based on the chemical signature of the sugars in the product, which is verified using C3 and C4 testing.

In December, The Centre for Science and Environment (CSE, India) reported a very high proportion of ‘inauthentic’ honeys in a survey that made use of both C3/C4 tests and more sophisticated testing that makes use of NMR (nuclear magnetic resonance) analysis.   Some honeys passed the C3/C4 tests but ‘failed’ the NMR tests.

Investigators from CSE claim this is due to the products being made with special syrups that are designed to ‘trick’ the C3/C4 tests. They allege that these syrups can be purchased cheaply via online trade portals.  The syrups are apparently marketed as “all pass” syrups because the suppliers claim they can pass the Indian government’s authenticity tests.

The CSE say that their own testing has confirmed that samples containing up to 50 percent of “all pass” syrup pass the tests.

Wrap up

There’s big money to be made from food fraud, as I have said before.  I have even heard it said that olive oil fraud is 3 times more profitable than smuggling cocaine – as well as being much less risky. (I haven’t been able to find the original source of that comment, I heard it at a food fraud conference in 2017).  And where there is money to be made, criminals will find ways to cheat the system.

Sadly, worldwide volumes of honey production are way down and predicted to fall even further due to climate change and bee colony diseases. That makes genuine honey more scarce, more valuable and, as a result, more profitable to fake.  Honey fraud is – unfortunately – here to stay.

My hope is that organisations like the Canadian Food Inspection Agency and the CSE in India continue to keep the pressure on honey fraudsters. Let’s keep making their lives hell!”

 

 

 

 

 

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The Cost of Deception (the not-so-sweet-story of an ice cream company’s food fraud)

Food fraud takes many forms.  When a food company makes deceptive claims about its products to gain an economic advantage, that is food fraud.  The American company Blue Bell Creameries created a deadly food fraud incident in 2015.  Now the former president is facing a grand jury and potential jail time over his role in the affair.

At a glance:

  • Blue Bell and its former president have been accused of covering up food safety problems.
  • Three people died and at least 10 more were sickened by dangerous bacteria after eating Blue Bell ice cream.
  • After authorities stepped in, the company had to shut down production, lay off a third of its workforce and risked liquidation.
  • The former president of the company is facing a grand jury on fraud charges and, if found guilty, could be jailed.
  • The company has already paid fines and penalties totaling more than $19 million.

Blue Bell Creameries is one of America’s largest ice cream manufacturers.  Early in 2015, Texan authorities notified Blue Bell that two of its products contained a dangerous bacterium: Listeria monocytogenes. Listeria isn’t your average run-of-the-mill food poisoning bacterium; it has a high mortality rate in vulnerable populations, affects pregnant mothers and older people severely, causes miscarriages, stillbirths and deaths.  The other scary thing about Listeria is that it survives – even thrives – in low temperatures.  Like in ice cream.

For an ice cream company, finding Listeria in your product is a terrible thing.  Your consumers are in danger and should be protected at all costs.  All the affected product should be immediately recalled from the marketplace, customers should be informed of the problems, consumers should be told to discard the food, more testing should be done to see how many other products are affected and manufacturing should be halted until the source of the contamination has been found and eliminated.  As you might imagine, the costs to the company can be astronomical.  Worse still, the damage to a brand from having to tell consumers that there is a dangerous pathogen in your food can be severe.

In February 2015, Blue Bell knew there was Listeria in its products.  Yet it did not tell its customers.  Instead, it’s alleged that Blue Bell’s president, Paul Kruse, chose to cover up the Listeria problem.  He allegedly directed that the Listeria testing program be discontinued. He did not immediately initiate a recall, despite supposedly telling authorities that one was underway.   He put consumers at risk.  Three people died and at least 10 became ill from the Blue Bell outbreak.  Paul Kruse has been charged with seven counts of wire fraud and conspiracy to commit wire fraud and will be appearing before a grand jury in Texas next week.  If found guilty he could be jailed.

A recall did eventually get underway, in April 2015.  Consumers were alerted, the company had to shut down production, resulting in mass lay offs and causing liquidity problems.

The company has already pleaded guilty to distributing adulterated food products.  It was sentenced to pay criminal penalties of $17.25 million.  Separate civil claims have been paid out by Blue Bell after shareholders and customers, including the American military, alleged that the ice cream was manufactured in unsanitary conditions and that management paid little regard to food safety ‘red flags’.  The total monies paid in fines, forfeits and civil settlements amount to $19.35 million, the second largest amount paid for a food safety matter.

Often, when people talk about food fraud, they focus on adulteration, like ‘fake’ honey made from sugar water.  But food fraud takes many forms.  In the case of the deadly Blue Bell Listeria Outbreak, it can come at a high cost to the perpetrators and an even higher cost to consumers.

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Nutraceuticals; a growing risk

A nutraceutical is a food or food component that is designed to provide health benefits when ingested.  The term is derived from the words nutrition and pharmaceutical.  Nutraceuticals may claim to promote health, prevent and even treat disease.  Nutraceuticals are big business; their global sales volume is estimated to be more than $382 billion in 2019.  Demand for nutraceuticals is at an all time high and growing year on year as the idea of ‘nutrition for health’ becomes more popular.

Both consumers and businesses purchase nutraceuticals; consumers buy supplements to add to food or as stand-alone pills, powders and tonics.  Businesses purchase nutraceuticals to add to the food and beverage products that they manufacture.  Nutraceuticals are also used in personal care products like face creams and in animal feed.

Nutraceuticals are not regulated in the same way as pharmaceuticals, so their claimed benefits do not necessarily have to be proven.  In many countries, they are not covered by food laws either.  As a result, nutraceuticals receive minimal regulatory oversight in many countries, including the USA.

Nutraceuticals are big business with a large global market and fast-growing demand

Fraud in nutraceuticals

Nutraceuticals are a good target for food fraud because of their high prices and high demand.  They are manufactured from specialist agricultural commodities that are often only produced in one or two locations worldwide.  As a result their global supply chains can be complicated.

Fraud in pharmaceuticals can take the form of:

  • Adulteration or dilution
  • Counterfeiting
  • Diversion and grey market

Adulteration and dilution

Adulteration and dilution fraud occurs when the claimed active ingredient is not present in the quantities that are declared by the manufacturer.  Sometimes, the ‘correct’ ingredients are replaced with cheaper ingredients that do not have the functional properties of the genuine ingredients.

Adulteration fraud is thought to occur often in nutraceuticals.  A survey of raw botanical plant parts and powders in the USA found 53% of them contained plant material that did not match the label.   In a separate study, cranberry extracts were found to have been adulterated with cheaper and more abundant grape seed extracts.  A range of aloe vera products contained no evidence of aloe vera ingredients at all.

Adulteration also takes a more insidious form, when fraudsters add extra functional ingredients without declaring them on the label.  This can put consumers’ lives at risk.  The fraud is usually perpetrated to boost the efficacy of nutraceuticals that are claimed to be natural.  For example, grapefruit seed extract, a dietary supplement that is said to have natural antimicrobial properties has been found to contain undeclared added chemical biocides such as benzylkonium chloride, methyl paraben and triclosan.  The biocides are added to mimic or increase the antimicrobial properties of the grapefruit seed.

Adulteration with pharmaceutical drugs also occurs.  Supplements for body-building and weight loss have been spiked with drugs that enhance their effects.  In 2017, the US FDA warned consumers  that body building supplements sometimes contain undeclared and illegal selective androgen receptor modulators (SARMS), which mimic the effects of testosterone.  Liver injuries and other serious side-effects occurred in people who took the so-called ‘natural’ supplements.

A 2019 study conducted in The Netherlands found 64% of supplements contained pharmacologically active substances or plant toxins such as caffeine or ephedrine.

Counterfeiting

Counterfeiting is the copying of a product by an entity other than the brand owner, so that it appears exactly the same as the legitimate product.  Counterfeited supplements may be produced in unlicensed facilities under unhygienic conditions.  They may contain less of the functional ingredients than the authentic product, or perhaps none at all.

Diversion of nutraceuticals. 1. The manufacturer sells their product into multiple countries at different price points. 2. A wholesaler in a lower-price-tier country purchases bulk quantities. 3. The wholesaler diverts the product from authorised sales channels in their own country to sell the product into markets with higher prices.

Diversion and Grey Market Fraud

Diversion and grey market fraud occurs when goods are directed away from their expected supply chain, being sold to places unintended by the brand owner.  This can be profitable if, for example, a product is sold at a higher price in one country but a lower price in another.

Distributors or importers of a nutraceutical can participate in diversion if they purchase more than they expect to sell through legitimate channels, obtaining a bulk quantity discount in the process.  The excess stock can then be sold to discount outlets or individuals who sell it on the internet or other channels that have not been authorised by the brand owner.

Products that have been diverted may be expired (past ‘best before’) or may have been held in conditions such as hot warehouses that degrade the product, causing it to lose its potency.

 

Protection from fakes and diversions

Manufacturers can protect their brands from counterfeiting and grey market sales by adding anti-counterfeiting features to product packaging.  The features can be overt or convert. Often a combination of both overt and covert features is used.

Overt brand protection features are obvious to the consumers.  They include holograms, tamper-evident labels, seals and stickers.  Overt brand protection features are used to provide consumers with a sense of safety and trust in the brand. Unfortunately, counterfeiters can easily copy overt features.

QR codes and bar codes can be added to packages so that purchasers can check the authenticity of the product.  However, barcodes and QR codes can be copied by counterfeiters.  Unless the QR or bar code is unique to a single batch or single product, then anyone who checks a counterfeit product that carries a copied bar code or QR code will be fooled into thinking it is legitimate.

Covert brand protection features are designed to be invisible.  They often require special scanners for reading and verification.  They can include fluorescing inks that can be read only under invisible wavelengths of light.  Chemically unique inks can be customised for a single manufacturer so that they are difficult for counterfeiters to reverse engineer.  These are called ‘taggant inks’.

Covert features are most useful for brand owners when they need to investigate a problem with product; they reveal whether the problematic product is genuine or not. They can also be used to find counterfeit products in authorised sales outlets and trace products that have been diverted.

Unique, serialised product identification codes provide an extra layer of protection.  Each product or product batch carries a different code.  The codes can be scanned by distributors, retailers and consumers to provide assurance that the product is authentic.

Protection from counterfeits and diversions using digital authentication. The product is marked with a unique code that can be scanned by distributors, retailers and consumers.  The code is checked against digital product information to check its authenticity.

Digital authentication as a protection against nutraceutical fraud. The product is marked with a unique code that can be scanned by distributors, retailers and consumers. The code is checked against digital product information to check its authenticity.

 

When the unique identifier is scanned, the brand owner can find out where the product is geographically located.  If that does not match the expected location of that product within the authorised supply chain that could signal diversion.  Likewise, if a single ‘unique’ barcode or QR code is scanned by multiple consumers that would indicate fakes in the market; counterfeiters have copied one code and applied it to whole batches of product.

One company to have benefitted from such a system is Windmill, a well-known Dutch brand of potato starch.  The company claims that its products were affected ‘up to 50%’ by counterfeits and look-alikes in overseas markets until it implemented digital security features including a unique ID code on each pack.  The code allows the purchaser to confirm authenticity, while the act of checking provides the brand owner with “valuable data… which can be used to make the entire supply chain more transparent and to generate crucial market insights.”

Nutraceuticals are high value products with complex global supply chains, making them an attractive target for food fraud.  Brand owners have been caught manufacturing and supplying products that contain less than the amount of functional ingredients.  Other brands have been found to contain undeclared pharmacological components, which can be dangerous. Diversion and counterfeiting of legitimate product also affects nutraceuticals.  With growing global demand for nutraceuticals, consumers and businesses alike need to be on the look out for food fraud in this sector.

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Investigating susceptibility to food fraud

This page contains information and links to help you investigate, understand and summarise incidences of food fraud that have occurred or may occur within a food or food ingredient.  Some foods are more susceptible than others to economically motivated adulteration, substitution and dilution.  Understanding the susceptibility of an ingredient or raw material type is an important part of every vulnerability assessment process.

Susceptibility is investigated in two parts.  The first part is the general susceptibility of the food and is irrespective of  where it is purchased or sold; this can be determined using publicly available information.  The second part is specific to an individual food business.  The specific susceptibility of a food or ingredient is dependent on the characteristics of the supply chain, management of the supply chain and testing and auditing activities.

GENERAL SUSCEPTIBILITY

To investigate the general susceptibility of a food or ingredient to food fraud, use publicly available information about incidences of fraud that have occurred in the past and that might occur in the future.

There are a few different ways to access information about previous incidences and emerging issues with a raw material type, as shown below.

how to investigate info graphic

1. Online databases – access to historical data:

  • Decernis has an extremely comprehensive database of food fraud incidents which can be searched by food type and by adulterant type.  This database was developed and formerly operated by the US Pharmacopeial Convention (UPS). It also contains information about analytical methods.   https://decernis.com/solutions/food-fraud-database/.
  • Food Fraud Advisors’ Food Fraud Risk Information Database is a free and open-access online database of food fraud incidences and emerging threats, organised by food type.  No log-in required.
  • HorizonScan contains historical data about both commodities and suppliers.  Users can set up email alerts for issues relevant to them.
  • FoodSHIELD was created by The Food Protection and Defense Institute, which is part of the University of Minnesota and partially funded by the USA Department of Homeland Security.  FoodSHIELD resources, including a database of economically motivated adulteration incidences are available to members.  Unfortunately membership is limited to representatives from local, state, and federal governments, the military and laboratories that perform analyses.  Members must first pass a membership checking process to ensure they are eligible to access the information. https://www.foodshield.org and https://www.foodshield.org/index.cfm/discover-tools-links/what-is-foodshield/foodshield-brochure/
  • The Food Protection and Defense Institute also operates a Food Adulteration Incidents Registry.
  • EMAlert is software that helps USA businesses with commodity scanning and assessing vulnerabilities for USA regulatory compliance.  Subscriptions start at US$2,500 per year.
  • The Rapid Alert System for Food and Feed (RASFF) is managed by a group of European national food safety authorities and alerts its member states to incidences of food and feed safety and integrity.  RASFF publishes a searchable database for investigating incidences of food fraud.  To learn more about RASFF click here.  For direct access to the database, open the RASFF Portal.
  • The US FDA has a searchable list of food recalls and food safety alerts, including those related to food fraud.  http://www.fda.gov/Safety/Recalls/

2. Email alerts via subscription service:

  • Food Forensics, a laboratory located in United Kingdom, offer a monthly horizon scanning risk newsletter to members.
  • FoodChainID Horizon Scan is a paid subscription service that provides alerts on adulteration and fraud, as well as food safety contamination events.
  • Some trade associations provide email services to members.
  • Government-run food safety and food regulatory bodies in some jurisdictions send emails to interested parties.  Contact your local authority for more information.

3.  Direct intelligence:

  • Information can be obtained by asking law enforcement officials and government departments.
  • Suppliers can provide information about their material types.
  • Trade associations can be approached for information on food fraud and emerging issues.
  • Conferences and webinars about food fraud and food defence are held regularly and these can be a good source of information.

SPECIFIC SUSCEPTIBILITY

Specific susceptibility is investigated by considering all the characteristics of a specific material as it is purchased by an individual food business.  Characteristics that should be considered include those associated with the supply chain, purchasing policies and the format of the material.   Each characteristic should be considered with regards to how it could affect the degree to which a person may be motivated to fraudulently adulterate the material and how it could allow a person to:

a) gain access to the material,

b) commit fraud by adulterating, substituting or diluting the material or

c) avoid detection.

To ensure that all relevant characteristics are considered it is best to use a checklist and record observations against each item in the checklist.  Create your own checklist or use a checklist prepared by experts such as those found in a proprietary Vulnerability Assessment Tool.  There are a number of fraud assessment tools available on-line, with differing degrees of usefulness to anyone conducting a food fraud assessment.  The most comprehensive checklist for food fraud vulnerability assessments can be found in Food Fraud Advisors’ Vulnerability Assessment Tools.

Need more help?  Get easy-to-use, comprehensive downloadable templates in our online training course.

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