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Beyond vulnerability assessments

How to verify a food defense plan

The USA FSMA Intentional Adulteration Rule deadline is fast approaching, with implementation required by 26th July.  Food defense plans are our most requested service this month, and not just for companies in the United States.  Businesses that export to the US are also affected.

The Intentional Adulteration (IA) rule

The Intentional Adulteration (IA) rule requires food businesses to identify vulnerable parts of their food manufacturing processes, implement strategies to reduce the vulnerabilities and monitor and verify that those strategies are working.  As part of the verification processes, some experts are recommending that food businesses challenge their food defense system on a regular basis.  Food safety management system standards, including SQF Edition 8, also require that manufacturing facilities challenge their food defense system.  What exactly does it mean to ‘challenge’ a food defense system, and how is that different to monitoring and verification of the system?

Monitoring vs verification vs challenge testing

Monitoring, verification and challenge testing are different, but the terminology can be confusing when used with food defense plans.  Some commentators and trainers are using the three words almost interchangeably; however, the three words actually refer to different elements of a food defense plan.

Monitoring means, at its most basic level, to check that procedures are being followed and that processes are happening as they should.  The checking process must be documented.  So, the act of monitoring is documenting in real time the actions taken to follow a given procedure or the measured outputs of a specific process.

Within a food safety plan, an example of monitoring would be checking the internal temperature of three pies from each batch after a cooling step and recording the temperature on a form.  Within a food defense system, a mitigation strategy might be the implementation of a procedure to lock all external doors, or to leave all external doors locked.  For this procedure, the monitoring activity could be a once-per-shift process of checking and recording the lock/unlock status of each door.

Verification is the process of making sure that monitoring has been done properly.  When cooling pies, for example, verification could include a once-per-shift check by a supervisor or manager that the cooled pie temperatures are being recorded AND that appropriate action has been taken if the temperature has exceeded critical limits.  Verification also includes internal audits; the internal auditor checks that the managers have been signing off the monitoring records, that the records are complete and available for all shifts and that corrective actions have been properly recorded.

In our food defense example, verification could include a check of the door lock monitoring records by a manager or supervisor.  The manager would review the records to see that they were completed on time, at the correct frequency and that any deviations, such as a broken lock, have been identified and actioned correctly.  Verification of door lock status could also be included in a weekly plant walk-through by a manager.  Internal audits would check that all these activities were being done and recorded properly.

Challenge testing is real-world scenario testing of a system’s efficacy.  A challenge test aims to validate whether procedures are effective when implemented as expected, as well as highlighting any failures in implementation.  A challenge test is different to a verification process because it would usually test the implementation and effectiveness of many food defense mitigation strategies rather than focussing on one element such as door locks.

What is the weakest link in your food defense plan?

 

How to conduct a food defense challenge

  1. Decide on a challenge action. For example, a common food defense challenge test is a penetration test, in which an unauthorised person attempts to gain access to a sensitive area.
  2. Create a food defense challenge report. In the report document exactly what you plan to do in the challenge test.  Include what, when, how, who and next steps.

For example: A person unknown to staff (Ms Jane Doe, of Acme Services) will attempt to get from the main reception area into ingredient weighing area A.  She will be wearing a business suit covered by a lab coat.  Once there, she will remain for up to twenty minutes unless challenged by an employee.  She will then leave.

If the intruder is challenged, she will claim to be a new food safety consultant/pest control account manager/new human resources manager and attempt to remain in the area.

  1. Include written contingency plans in case of escalation, for example, what will be done if police are called.
  2. Get approval for the plan from senior management.
  3. In the report record the following:
    • Name of Senior manager who has signed off on this plan.
    • Names of people who have been informed of the challenge test
    • Names of people who will be working in the affected areas at the time of the challenge, have they been trained in food defense?
    • A description of what staff are supposed to do in this scenario; what procedures should be followed.
  4. Define and document the criteria for failure and success; what will happen if the food defense procedures are working 100% correctly; what will happen if the food defense procedures are working only partially; and finally, how might the scenario progress if there is a complete fail of procedures and systems?

For example, if the ‘intruder’ is able to remain in the ingredient weighing area for 20 minutes without being challenged by an employee this could be considered a complete fail of the food defense system.  If the intruder is challenged but can convince the employee to allow them to remain in the area unattended, this could be considered a partial fail; if the employee chooses to remain with the intruder to ‘keep an eye on them’ this could be considered a better outcome than leaving the intruder unattended.

  1. Run the challenge. Have a trusted staff member observe from a discreet distance.
  2. Describe in the report what happened.
  3. Convene a meeting of the food defense team and analyse the results of the challenge test.
  4. Perform root cause analyses and raise corrective action/s for any failures in the system.
  5. Close out corrective action/s
  6. Take action to prevent a scenario like this from reoccurring, based on the root cause analyses.

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About that “16 easy tests for fake food” video

A video about easy tests for food fraud went viral on Facebook on 1st Jun 2019.  It purports to show how consumers can test for real and fake foods at home.   Food fraud is estimated to affect 10% of all foods worldwide, so it’s a pretty big problem.  At Food Fraud Advisors we are in favour of increasing awareness about food fraud but that particular video is not a good way to do it; it’s full of scare tactics and misinformation.

Much of video in question, published by First Media under their banner Blossom is based on online articles published in India, where food fraud and unethical food business practices are a massive problem that presents both economic and public health risks.  In that country, it is not uncommon for powdered tea to be dyed with textile dyes and for ghee (clarified butter) to be adulterated with undeclared vegetable oil.  Likewise, there is a long history of adulteration of dairy products like milk with chemicals such as urea which is added to trick protein tests, vegetable oil and sugar.   Sadly, in that country, as in other developing countries, it is also common for some fruits, vegetables and dried pulses to be dyed with undeclared chemical dyes.

In India, consumers and government authorities are very aware of food fraud and there is much information online for consumer ‘fraud detection’ tests that can be done at home.   Many of the ‘tests’ in the Blossom video appear to be based on these methods.  Most of them don’t work, or show chemical characteristics that are not evidence of fraud or fakery.

Food fraud occurs more often in developed countries in North America, Europe and Australia, than many people might imagine.  However, it rarely occurs in the ways that are shown in the video Is your food fake or real? Find out with these 16 easy tests.   Lets take a closer look at each of the ‘tests’ in the video with Karen Constable, Food Fraud Advisors Principal Consultant, a food scientist and food fraud specialist.

Melting ‘plastic cheese’

The first part of the video shows a person holding a naked flame to processed cheese and claims this shows that it contains chemicals.  It’s tempting to imagine that all food manufacturers are evil multinationals full of mad, greedy scientists.  But the reason that food companies make and sell processed cheese is because it is convenient to use and it melts really beautifully, so people buy it.  Some people even buy it for the taste!  To achieve the pliable, smooth texture and perfect melting profile loved by consumers, manufacturers add emulsifiers when they make processed cheese.  The emulsifiers tightly bind the protein and fat in the cheese and this means that it behaves differently to non-processed cheese when exposed to a cigarette lighter.  No kidding.  This video by Kraft food scientists explains it perfectly: https://youtu.be/OTH11_oPT20.  Conclusion; processed cheese melts differently to unprocessed cheese and that’s why we buy it!  Conclusion:  this is not a test for ‘fake’ food.

Plastic rice

This part of the video shows a non-stick pan with rice grains interspersed with other white particles that turn clear as the pan is heated.  Rumours of plastic rice have surfaced in various developing countries a number of times since 2011, however none have been substantiated.  There have been credible reports of sacks of rice within large shipments being replaced with sacks of other materials, including paper pellets, sweet potato pellets or plastic resin, to increase the apparent value of the shipment, however there is no evidence that this ‘fake’ rice ever reached consumers.  Food scientists and government authorities in India have investigated but never found plastic rice.  However they acknowledge that rice in India has occasionally been adulterated with chemicals, including boric acid, to close its pores and make it appear shinier and brighter.  These chemicals could give the rice a strange texture or behave strangely when cooked.  This occurs only very rarely.

Rice-like granules made from plastic resins would be completely unchanged by cooking in boiling water, which does not match descriptions provided by consumers who claim to have cooked ‘fake rice’.  In the video, the melting crystals in the pan look like something you could buy in a see-through window art hobby kit.  Just sayin’.  Conclusion:  Reports of consumers cooking or eating plastic rice have never been substantiated.  This is not a test for ‘fake’ food.

Black calcium rocks in baby food

The ‘rocks in baby food’ part of the video is a great example of  how “a little learning is a dangerous thing” (Alexander Pope, 1709).  In the video, a person runs a magnet over a plastic bag of baby food and collects black particles.  Baby food manufacturers deliberately and legally add minerals like calcium and iron to their products, a practice which is called ‘fortification’.  Babies (and adults) need these minerals to grow and thrive.  The minerals used to fortify foods do ultimately come from the earth’s crust, so it’s probably fair – though somewhat disingenuous – to claim that they are ‘crushed up rocks’.  It is indeed possible to get tiny black particles out of fortified foods with a magnet, as you can see in this awesome food science experiment by Scientific American.  However, the magnetic particles are iron, not calcium; calcium is not magnetic.  (Food scientists around the word give a collective face-palm).  Conclusion:  Minerals added to baby food keep babies alive.  Black stuff in baby food is not calcium, it is iron and it is supposed to be present.  Conclusion:  this is not a test for ‘fake’ food.

Baking vitamins

My gosh where do I start with this one?  In the video, a person puts a collection of different coloured and shaped pills and capsules on a tray in an oven and shows some of them bubbling and melting.  Put any collection of different pills in the oven and they will behave differently.  That’s because they contain different things.  Legitimate, authentic vitamins and supplements contain fillers, active ingredients and casings that have both high melting points, low melting points and many different kinds of smoking, burning and bubbling behaviours when heated.  The video claims ‘Synthetic supplements burn; natural supplements don’t‘ but if I made a ‘fake’ pill with chalk or talcum powder it most certainly wouldn’t melt or burn in a domestic oven.

This video is the perfect visual ‘filler’; no real claims, no real evidence, I didn’t even find a historical or anecdotal basis for this one.  Having said that, there have been credible reports of supplements containing smaller quantities of authentic ingredients than they claimed to contain.  Worse, there have been cases of supplements that have been spiked with illegal and undeclared drugs to boost their efficacy.  Conclusion:  supplement fraud does occur, but the oven test in the video will not reveal ‘fake’ supplements.

supplements. authentic, ignite, burn, test
Supplements can be affected by fraudulent adulteration, but you cannot detect inauthentic supplements by baking them in the oven

Glue in meat

In most countries, it is legal to add binders, enzymes and edible ‘glues’ to processed meats and most of those ingredients must be declared on the package.   It is not legal to add chunks of ‘fake’ fatty substances to meat pieces and then sell them as if they were whole cuts.  The video shows what looks like a whole cut of meat, possibly lamb, with fat and connective tissue on and within the muscle.  (Yes, meat is animal muscle, people!)  The meat and fat is prodded and pulled by a fork to supposedly show ‘glue’.

Why on earth a food company would bother making fake, unappealing grisly, fatty bits to add to their ‘whole’ cuts of meat is beyond me; it would be expensive, technically difficult and result in an undesirable product.  Having said that,  there are legal and safe enzymes, including transglutaminase that can be used to bind muscle pieces to make larger pieces of meat.  Pulling such meat apart with a fork would not reveal enzymic binders like transglutaminase.  If binders are present, this ‘test’ would do nothing to reveal them.  Conclusion:  this is not a test for ‘fake’ food.

Bubbling ice cream

I wish I had some ice cream and bicarbonate of soda with me now so I could try to replicate this trick.  The video shows ‘bad’ ice cream which bubbles if you douse it with lemon juice, supposedly because it contains washing powder.  The basis for this myth is probably the very sad situation in India in which local, small-volume suppliers of fresh cows milk have been caught adding detergent to the milk.  The adulteration makes the milk look fresh and foamy when poured from small milk cans into the larger containers used to collect local milk supplies in rural areas.  As for ice cream, I only found one obscure Indian post that suggests washing powder might be found in ice cream.  Perhaps instead, this is a nod to an incident in which noodles were adulterated non-approved optical brighteners in Vietnam.  Optical brighteners make things look whiter and are found in washing powder.

When it comes to making bubbles with lemon juice, ice cream would need to contain a significant amount of washing powder to achieve the result shown in the video; a small amount of adulteration with washing powder is unlikely to be detectable with lemon juice while a large amount of washing powder would affect the product in other ways, including changing taste.  Let me assure you that of all the food frauds you might encounter in a developed country, washing powder in ice cream is not one of them:  I guarantee that even an unethical ice cream manufacturer is much too smart to feed their consumers washing powder.  Conclusion:  this would be a fun experiment.  It is not a test for ‘fake’ food.

Testing for rice in milk with seaweed

In this part of the video, seaweed is mixed into milk that is said to contain ‘rice water’ and the liquid turns blue.  In most – if not all – countries, it is illegal to add rice to milk without declaring it on the label.  As bizarre as this seems, this ‘test’ is actually plausible: rice starch would make a good adulterant for milk powder in developing countries and seaweed naturally contains iodine which forms blue-black-coloured reactants when exposed to starch, including the starch found in rice.  However I am not sure that seaweed contains enough iodine to produce the strong blue colour in the video.  Conclusion: if you had reason to believe that your milk contained a significant quantity of rice, this test might actually work.  But note that if you live in North America, Europe, Australia or New Zealand, the chances of your milk containing rice water is vanishingly small.

Floating coffee grounds

Ground coffee containing ‘additives’ is shown floating on water in this part of the video, which claims that pure ground coffee will sink quickly.  I don’t know enough about ground coffee to confirm or deny the claims that fresher coffee floats more than stale coffee due to its carbon dioxide content or not, however it sounds plausible to my food scientist brain, as does the claim that different degrees of roasting will result in different densities after grinding.   However I do know that there are many historical records of both coffee beans and ground coffee being adulterated with cheaper fillers like sticks, stones and corn husk to increase profits, most commonly in developing countries.

Coffee consumers in wealthy countries are unlikely to be affected by this type of food fraud.  It is possible that consumers in poor countries could detect adulterants like corn husks or undeclared chicory in ground coffee using a ‘float’ test but I can’t confirm that such a test would be accurate or repeatable.  Conclusion:  this test might be able to reveal certain unexpected contaminants in coffee grounds, however it is unlikely to be reliable.

Cloudy ‘fake’ salt

Sadly, there have been reports of industrial grade salt being repackaged as food grade salt in some African countries in recent years.  The video claims that if the water turns cloudy when you dissolve table salt that the salt contains chalk and is ‘fake’.  The test in the video is not effective, but chalky salt would be easy to identify: if salt contained chalk it would leave undissolved powder in the bottom of the glass when added to water.  Authentic, pure salt will result in cloudy water if the salt has been shaken with air before adding to water or if the water is warm and contains dissolved air before the salt is added.  Chalk in salt is NOT a common type of food fraud, probably because chalk powder (calcium carbonate) is up to ten times more expensive than salt.  Conclusion:  this ‘test’ is a trick that can be done with pure salt.

salt chalk
Chalk in table salt? Unlikely!

Illegal dyes in tea, peas and sweet potatoes

Unfortunately, unscrupulous food sellers have been known to add undeclared, illegal colourants to food.  If you live in North America, Europe or Australia you are most likely to have encountered this type of food fraud in olive oil, green olives or chilli powder.  There isn’t a lot of evidence of it occurring frequently in dried peas, which are shown in the video being cooked in water that turns a pale green colour.   Tea that is claimed to be ‘impure’ is also shown leaching colour in the video.  In some countries, authorities have seized tea powder that contains illegal dyes or other materials such as brick dust.  As for rubbing sweet potatoes with cotton wool, which is done in the video to supposedly prove the presence of illegal dye, I’m not at all surprised to see red colour on the cotton after it has been rubbed on the sweet potato.

In my country (Australia) our tubers often have a reddish colour on their surface from the red-coloured soil in which they were grown.  Illegal dye-ing of fresh produce is thought to occur very rarely if ever in wealthy countries.  In poorer countries it does occur but is most frequent in produce for which quality and  price are determined by the intensity of colour of the fruit or vegetable.  Sweet potatoes are less frequently affected than table grapes or leafy greens.  Conclusion: this ‘test’ is a trick that relies on red soil found naturally on the surface of some sweet potatoes.

Turmeric adulteration

In this part of the video, two spoonfuls of ground turmeric are exposed to a naked flame.  One burns more readily than the other and the video claims that ‘pure’ spice burns more easily than impure spice.  It is interesting that the video makers chose turmeric to represent spices because it has been associated with numerous recalls due to adulteration with lead-containing colourants  in the USA.  This is very worrying given turmeric’s current popularity as a ‘health’ product in North America and Europe.  The lead colourant used to adulerate turmeric is bright yellow and enhances the colour of the turmeric, increasing its apparent value and hence its price.  This type of fraud is not common but does occur in developed countries as well as developing countries.

As for the test, it is possible, though unlikely, that adulterated turmeric powder would consistently burn in a different way to authentic, pure turmeric powder.  It is more likely that the moisture and oil content of each ‘batch’ or brand of powdered spice would result in different burning characteristics.   Conclusion:  adulterated turmeric might behave differently to pure turmeric when burnt however the test is unlikely to be a reliable indicator of purity.

Honey candle trick

I am sorry to say that adulterating honey by adding water, sugars and syrups is a practice that is as old as human trade.  Honey is valuable and adulterating honey, or diluting it with water is profitable, making it an attractive food fraud.  You can read more about the long and sordid history of food fraud in honey here.  In this part of the video, two samples of honey are applied to candle wicks and the wicks lit.  One candle burns properly while the other doesn’t.  I don’t know anyone who has tried burning honey on a candle wick, but it sounds fun (I’m beginning to wonder if the people who made this video are closet pyromaniacs!)

I have no reason to doubt that putting pure honey on a candle wick will result in a good flame.  Likewise if you put watered-down honey on a candle wick it seems very likely that the water in the honey will stop the wick from burning.   So this test seems somewhat plausible.  However, what we don’t know is (1) how much water do you have to add to pure honey for it to stop a candle wick from burning and (2) what about all the other types of honey fraud; the ones that don’t involve adding water?  Honey fraud can include the addition of other sugars, syrups and colours, rather than the addition of water.  Misrepresentation of variety, geographical origin and organic status are also common types of honey fraud.  These could not be detected using the candle wick test.  Conclusion: this test will show if your honey has lots of moisture in it but is not a reliable indicator of authenticity or adulteration.

Oil in butter test

In the video, it is claimed that if butter contains oil then adding sugar to the mix will result in a pink colour.  This is not true; try it yourself!  The claims are based on a test published in Indian media for checking the purity of ghee.  Ghee is clarified butter and used commonly in Indian cooking.  By law, ghee should not contain anything except butter fat.  Unfortunately there is a long history of ghee fraud in countries where it is popular.  Often the fraud occurs when an unauthorized manufacturer counterfeits an expensive brand which can be sold for a high price.  This ‘fake’ ghee isn’t really ‘fake’ but it does often contain vegetable oils, which are cheaper than butter fat.  There are articles published in Indian media that explain how to check ghee for the presence of vegetable oil by adding hydrochloric acid and sugar.  I haven’t been able to confirm or deny the efficacy of that test.  However, without the hydrochloric acid it most certainly won’t work!  Conclusion:  the test shown in the video is not a legitimate test and it wouldn’t work as a test for ‘fake’ food.

Wax on fruit

Have you ever bought an apple from the farm gate, or picked one yourself to take home and eat later?  Freshly picked apples taste great but if you keep them for more than a few days they soon lose their freshness and begin to shrink and become soft.  This is because apples, like many fruits and vegetables, start to lose moisture from the moment they are picked.  To prevent this, fruit growers apply a thin layer of edible wax to retain moisture and keep the produce fresh and tasty.  The wax is inert and safe to eat.  In the video a fresh, juicy bell pepper, also known as a sweet pepper or capsicum, is dipped into a bowl of warm water and a significant quantity of what looks like vegetable oil can be seen floating on the surface of the water afterwards.

I am not sure if the video is actually depicting fruit-coating wax, since I have never observed this much oily substance coming off any fruit or vegetable.  However it is true that bell peppers and many other fresh fruits and vegetables are routinely coated with wax.  And I am glad of it, since I don’t have time to drive to an apple orchard every time I want a fresh, crisp apple. Conclusion:  this is not a test for ‘fake’ food.

Food fraud does occur in both wealthy and developing countries, but almost never in the ways shown in the video.  When it does occur, unfortunately it is difficult for consumers to identify at home.

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Food safety hazards from food fraud (EMA)

Are you confident in your FSMA preventive controls for hazards from food fraud? Here’s a quick reminder about economically motivated adulteration hazards.

Hazards are chemical, physical and biological agents that may be present in food and that are capable of causing harm to consumers of the food.  (Find the official FDA definition here)

FSMA (The food safety modernization act of USA) requires that preventive controls are implemented by food manufactures to prevent hazards to human health.  The relevant regulation is called the preventive controls rule.

The preventive controls must be described by the food manufacturer in a food safety plan.

The US Food and Drug Administration (FDA) is responsible for enforcement of the rules.

The Preventive controls rules requires food manufacturers to identify and control hazards that could arise from:

  • natural occurrences (for example, some raw meat products naturally contain certain human pathogens);
  • unintentional contamination (for example food may be accidentally contaminated with a pesticide during a pest control treatment), and
  • economically motivated adulteration (EMA).

A separate part of the FSMA rules also requires food manufactures to create and implement systems to prevent adulteration of food that is perpetrated for the purposes of causing large-scale harm to consumers.  The FDA calls this type of adulteration Intentional Adulteration (IA).  The Intentional Adulteration rule, which addresses the risks from deliberate attempts to create large-scale harm, relates to issues of food defense rather than food fraud and is not related to economically motivated hazards.  Click here to learn more about food defense.

Hazards are chemical, physical and biological agents that may be present in food and that are capable of causing harm to consumers of the food

 

HAZARDS from economically motivated adulteration (EMA)

Economically motivated adulteration (EMA) is a subset of food fraud.   Food fraud includes many types of deception carried out for the purposes of economic gain.  It includes activities such as mislabeling (for example making false claims about the geographical origin of a food product) and other fraudulent activities that do not involve adulteration of food.  Economically motivated adulteration is a type of food fraud in which a person has added a substance to food to enhance its apparent value or profitability.  Often the added substance will boost the apparent quality or appearance of the food, other times the substance will be a diluent, which dilutes or replaces the genuine material with a cheaper material, thereby increasing the profitability of the resulting mix.

According to food safety laws, food manufacturers must know about hazards that may be in their products and must create and implement systems that will prevent, minimize or eliminate those hazards.  The systems must be documented in a food safety plan.

How to identify hazards from economically motivated adulteration (EMA):

  1. For each raw material used in a food manufacturing process, investigate whether economically motivated adulteration is likely to occur within the supply chain; that is, could there be adulterants present in the raw material when it is purchased?  Learn how to investigate susceptibility to food fraud here.
  2. For each raw material and each finished product, investigate whether economically motivated adulteration could occur when the product is within the manufacturing facility.  This is sometimes known as ‘insider activity’.
  3. After you have understood whether adulteration is likely to occur for each food type, make a list of adulterants that could be added to each of the susceptible food types.   Historical records of past incidences of food fraud provide the best indication of the types of adulterants that can be expected in different foods and ingredients.  This page has a list of databases you can use to find historical records. .
  4. For each possible adulterant, make a note of whether it could be hazardous to human health if present in the food.  As an example, olive oil is commonly adulterated with (non-olive) vegetable oils.  That type of adulteration is unlikely to be hazardous and as such it would not require a preventive control.   Document your decisions and justifications for such.
  5. Within the food safety plan, add the economically motivated hazards you have identified to the preventive controls systems.  Implement effective controls to  prevent or control each hazard.  Supplier approvals programs are commonly used for control of economically motivated hazards in incoming raw materials.

Need to learn more about food fraud prevention?  Visit our online training school.  Courses start at just US$29.

 

 

 

 

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Secrets of the horsemeat scandal

How did the enactment of an obscure transport law in Eastern Europe change the face of food manufacturing forever?  Karen Constable investigates the link between Romanian road rules and the horsemeat scandal.

More than six years after it first made headlines, the series of incidents that became known ‘horsegate’ continues to impact the global food industry.  It began in January 2013, when Irish authorities revealed they had discovered horsemeat in burgers that were supposed to contain 100% beef.  The discovery sparked a frenzy of testing and soon horsemeat was being discovered in dozens of different products in countries all over Europe and beyond.  The sheer scale of the contamination sent shock waves through the food manufacturing world.  Occurring five years after the melamine in milk powder scandal of 2008, which sickened over 300,000 babies in China, this incident was unfolding much closer to home for food manufacturers in Europe.  It was a wakeup call for our industry: we could no longer pretend that food fraud of a similar scale and impact as the melamine milk scandal could not happen in the western world.

Numerous massive recalls

The scandal resulted in market withdrawals of tens of millions of food products across Europe, millions of euros of lost business and multiple prosecutions.  Consumers’ trust in manufactured food plummeted and sales of frozen hamburgers and frozen ready meals dropped by 43% and 13% respectively in the United Kingdom in the month following the first product withdrawal.

Multiple investigations

Despite some media reports claiming that the first horsemeat discovery was the result of ‘routine’ testing, it is now known that the scandal was uncovered almost by accident.  As strange as it may seem to the wider community, it is unusual for food manufacturers and regulatory authorities to test foods for materials that are not expected to be present.  This is, of course, how the perpetrators of the Chinese melamine fraud could conduct their activities on such a large scale for what is thought to be a significant length of time.  The original horsemeat tests were conducted by the Food Safety Authority of Ireland because a sharp-eyed inspector had noticed a discrepancy between packaging and labelling of frozen meat.

As the investigations began it became apparent that law enforcement and regulatory authorities were ill-equipped to manage the complex cross-border issues that arose.  Supply chains seemed hopelessly complicated to unravel, with on-paper ownership of meat often disconnected from the physical whereabouts of the food.  By the time the scandal was declared over, investigators had identified at least three entirely separate supply chains involving different slaughterhouses, traders, processors and criminals.

Beef an easy target

Horsemeat and beef meat are similar in appearance, texture and flavour.  Yet the European market for horsemeat is relatively small compared with beef; it is not consumed by people in many Western European cultures. For unscrupulous merchants, however, horsemeat’s abundance and low price made it the perfect substitute for beef.   With access to a cheap, abundant adulterant, the criminals appeared to have an easy job of it.  It was so easy, in fact, that swapping horse for beef appears to have been a long-term business plan for at least one of the meat traders involved in the scandal, Jan Fasen.  Fasen had been convicted and jailed for a similar fraud in 2007.  The name of his company, Draap, is the Dutch word for horse spelt backwards.

In 2019, Fasen and his partner Hendricus Windmeijer were convicted of false labelling by a court in Paris for their role in the supply of 500 tons of meat to ready-to-eat meal-maker Comigel in France in 2012 and 2013.

Complex supply chains

Much of the horsemeat found in the affected products originated in Romania, the by-product of a unique set of circumstances which affected the availability and price of horse meat in that country.  Six years prior to the scandal, a law had been passed banning horse drawn vehicles from the streets of cities and towns in Romania.  Within a few years there was a surplus of unwanted horses, with abandoned animals roaming city streets and parks.  The horses were rounded up and exported to slaughterhouses in neighbouring countries where they were slaughtered for legitimate human and pet food.  By 2007, however, concerns about the spread of equine infectious anaemia, a disease which was endemic in Romania, resulted in a ban on the trading of live Romanian horses.  With live exports stopped, there was nowhere for the horses to go.  Enterprising local businessmen built their own slaughterhouses in Romania and began to export horse meat to Europe.

Draap Trading, a company operated from Belgium and registered in Cyprus, was among those that purchased Romanian horsemeat.  It shipped the meat to the Netherlands where it was re-labelled as beef.  From there it was sold to legitimate meat processors, including one in France who supplied the factory in Luxembourg that manufactured lasagne and spaghetti bolognese for Findus and Aldi.

Separately, a French meat processing company, À la Table de Spanghero was also purchasing horsemeat from Romania and selling it to food manufacturers labelled as beef.  The former director and manager of Spanghero were convicted for their crimes in Paris in April 2019, with the former director being jailed for his role in the saga.

Romania was not the only source, however: the burgers at the centre of the initial discovery in Ireland contained horsemeat that came not from Romania but from Britain, Germany and Poland, via another Dutch trader, Willy Selten.  In 2015 Selten was jailed for 2.5 years for crimes related to the fraudulent supply of horsemeat in 2011 and 2012.  In November 2016 he was ordered to pay €1.2m – the estimated proceeds of his crimes – to the Dutch government.

A long history of horsemeat adulteration?

Given the history of Selten and Fasen, it seems likely that undeclared horse was present in the European food supply for many years, remaining undetected and causing no apparent harm to consumers.  We will never know whether those responsible considered the safety of consumers when planning their crimes.  We do know that unsafe adulterants are more likely to be detected, which makes them less attractive to fraudsters.  Certainly, in the melamine scandal in China, just a few years prior, consumer harm played an important role in the detection of the fraud.  In that case, it is likely that low levels of melamine had been added to milk powder and other products for many months or years without causing any immediate or obvious harm to anyone.  It is thought that the concentration of melamine in baby formula increased in 2007 and 2008 and it was the higher levels that caused kidney problems in babies.  The fraud was uncovered by authorities investigating the illnesses.  Perhaps the extra melamine had been added by mistake, or perhaps the fraudsters got greedy.  Either way, the adulteration was costly for the criminals as well as their victims: two of the people responsible were executed by firing squad in China in 2009.

During the horsemeat fiasco, and to the relief of the entire industry, no person was sickened or injured by the presence of horse in ‘beef’ products.  There was, however, a major health scare: horsemeat can contain veterinary drugs, including phenylbutazone – “bute”, which can be harmful to human health.  It was a lucky coincidence that the overwhelming majority of the contaminated products proved not to contain phenylbutazone.

From horse and beef to chicken, donkey and buffalo

As investigators worked behind the scenes, public events in the European food industry took on the appearance of collapsing dominoes: first was the withdrawal of 10 million burgers by Tesco, Lidl, Aldi, Dunnes Stores and Iceland in United Kingdom.  Tesco lost £300m in market value overnight.  In the following weeks, Asda also removed tens of thousands of products from its shelves; Tesco and Aldi extended their withdrawal from burgers to ready meals; Waitrose withdrew meatballs because of fears they might contain pork; slaughterhouses in Yorkshire and Wales were raided by regulatory authorities; the scandal spread to France and multiple arrests were made on both sides of the English Channel.

By the end of March 2013, authorities had found horse labelled as beef in three Polish factories; equine DNA had been found in chicken nuggets in Greece; water buffalo and donkey had been found in South African burgers and more big brands, including Ikea, Birdseye and Nestle had been affected with their products withdrawn from markets in Cyprus, Belgium, Spain and Czech Republic.

By year’s end, Tesco’s annual profits had fallen by 52%.  Consumer trust in large food manufacturers and retailers was at an all-time low: British consumer organisation ‘Which?’ reported that sixty percent of consumers had changed their shopping habits because of the scandal.

Standards updated

The British government commissioned Professor Chris Elliott to review and report on the implications of the horsemeat contamination for the British food industry.  The Elliott review, as it became known, resulted in the creation of a special food fraud crime unit in that country and the development of a range of other collaborative enterprises across Europe including special functions within the European Joint Research Council (JRC) and food-focussed operations by Interpol known as Operation Opson, now in its sixth year.

The food safety community, initially shocked and alarmed at the potential safety implications of the adulteration soon began a period of discussion and introspection, which often centred around the unspoken question ‘What if the meat had been dangerous?’.  The scandal broke at a time when the GFSI food safety standards were consolidating their revered positions at the pinnacle of ‘best practice’ manufacturing: the standards were being strengthened, lengthened and broadened.  Audit durations were increasing, auditor qualifications and certification systems had become more stringent and standards for packaging, storage and distribution had been upgraded.  And yet these GFSI-endorsed food safety management systems, considered to be the gold-standard for food manufacturing and administered with the strictest oversight, had revealed an Achilles heel the size of Bucharest.   The GFSI promptly created the ‘Food Fraud Think Tank‘ to address the gaps and suggest solutions.  This resulted in changes to GFSI’s guidance for food safety standards, with GFSI-endorsed standards being updated to reflect the updated guidance.  The new guidance requires food businesses to formally address the risks from fraudulently adulterated ingredients when they design their food safety management systems.

The food safety landscape had changed, seemingly overnight, from one that was focussed almost exclusively on unintentional or natural contamination to one that requires food manufacturers to consider, control and prevent more unpredictable and sinister events.

In the wake of these changes, a new discipline of food study has appeared.  It is now possible to study food fraud at prestigious educational institutions, attend international conferences devoted to the topic and tune in to webinars conducted by specialists in compliance, legislation and testing.  Analytical chemistry researchers are developing ever-more sophisticated test methods for detecting adulterants.  Food businesses large and small are developing better systems to prevent, deter and detect economically motivated adulteration within their supply chains.

Food manufacturers are slowly regaining the trust of consumers, helped by the visible presence of enforcement operations and government initiatives such as the United Kingdom’s Food Crime Unit and Interpol’s Operation Opson in Europe as well as the Food Safety Modernisation Act (FSMA) in the United States.

And what of the adulterated beef?  We can only guess at how many tonnes of it was eaten by unsuspecting consumers in countries all over Europe before the scandal broke.  Contaminated product that was withdrawn from the market – tens of millions of units – was destroyed; either buried in landfill or used as animal feed.  It seems a sad and wasteful journey for the unwanted horses of Romania; a journey conceived by men who wanted to be rich and one that ultimately changed the face of food manufacturing forever.

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How food fraud is uncovered; two cases of origin fraud

Origin fraud occurs when a food is misrepresented with respect to its geographical origin; it’s a type of fraud that can be categorised as ‘mislabeling’.

Examples of mislabeling include:

  • describing a fruit or vegetable as ‘organic’ when it was conventionally grown
  • cheeses and meats labeled as kosher or halal that are not
  • Spanish olive oil falsely declared as being ‘Italian’.  This is origin fraud.

Mislabeling is also called misbranding in some countries.  Because it is intended to deceive customers and consumers it is illegal under consumer protection laws and trade/contract laws just about everywhere.  Because almost every type of food fraud involves mislabeling to some extent, quoting statistics on mislabeling is difficult.  As an example, a botanical supplement labelled as 100% turmeric extract but that actually contains 15% filler is both mislabeled and diluted.  To make it even trickier, different organisations using different words to describe similar food fraud activities.  Learn more about classifying food fraud types in this great Food Safety Tech Article.  Suffice to say, mislabeling fraud is very common and, according to US Grocery Manufacturers Association, it affects around 10% of food products globally.

Coffee growers in Hawaii have launched a class action to protect their products

How do we expose origin fraud?  Typically, origin fraud is uncovered after authorities have been tipped off about suspect activity in a supply chain, either by people from within the supply chain or by competitors of the mislabeled product.   The evidence used to pursue the fraudsters often comes from either fraudulent documentation, or from testing of finished products.  This year we have seen an increase in the use of authenticity testing by representatives of ‘authentic’ brands to expose fraudulent products.  This is a trend that I expect to continue as test methods are improved, refined and can more easily be extended to assess specific product attributes.

I have been following this trend with interest and was reading, today, about alleged origin fraud in coffee in the United States. This is a case that is representative of the trend to use sophisticated test methods to authenticate finished product attributes.  Another recent example would be honey testing in Australia.  In the coffee case, growers from the Kona district of Hawaii have filed a lawsuit against retailers for allegedly selling ‘Kona’ coffee that does not contain a reasonable amount of coffee from the district. Kona coffee production is 2.7 million pounds, however more than 20 million pounds of coffee labelled ‘Kona’ is sold each year.  The plaintiffs claim to have analytical test results to support their claims.  Nineteen brands of coffee, sold by retailers including Walmart, Cosco and Amazon, have been named in the complaint.  Chemical testing technology underpins this current lawsuit, as it allows the coffee growers to show, for the first time, the actual Kona content of the coffee that is being allegedly mislabeled.  For this to be possible, the coffee growers would have had to organise for testing laboratories to create a database of chemical test results of authentic samples of Kona coffee.  Databases like this are used to model a product’s unique chemical fingerprint using sophisticated mathematical computations.  The test method can then be used to compare the ‘fingerprints’ of suspect brands against those of authentic products, such as Kona-grown coffee, and infer the amount of genuine material in each sample.  Developing databases for this type of testing is expensive and time consuming.  However, there are an increasing number of laboratories that have the machinery, skills and software to perform this work, so it is becoming more accessible to brand owners.

Specialty vinegars fetch high prices and can be vulnerable to economically motivated food fraud.

In cases that do not originate with product testing, it is activities in the supply chain that provide clues to origin fraud.  This month there have been reports of origin fraud for a specialty vinegar, Modena balsamic vinegar.  Modena balsamic is protected by a special geographical designation under European regulations.  According to these rules, Modena balsamic vinegar must be produced using grapes only from certain regions in order to be considered authentically ‘Modena’.  A massive fraud involving 15 million Euros worth of materials has been uncovered in Italy after a special operation by local authorities found that the wrong grapes were being used to produce this very expensive product.  Although operational details about this investigation are scarce, these types of actions by authorities are often initiated after authorities have received a tip off from someone connected with the supply chain.   Another example of such a tip-off includes this recent wine counterfeiting operation in which authorities became aware that a printing shop had received an order for 4,500 wine labels from a company that was not the brand owner.

More tip-offs and more testing are my predictions for 2019 and 2020.  These are going to lead to more investigations, complaints and enforcement actions against perpetrators of food fraud.  And that’s a win for everyone!

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From the food fraud desk

Happy New Year!

Last year was a busy year for Food Fraud Advisors.

Detection and enforcement actions increasing

Food fraud remains a hot topic in the food industry and is garnering stronger interest from the international anti-counterfeiting industry as well as international crime prevention groups like Europol and Interpol.  Recently, the international media have been discussing the role of organised crime syndicates in the food industry, particularly in the produce sector in Italy and in tuna trading in Europe.

Detections of food fraud and seizures have increased: almost a quarter of the 31 m counterfeit items seized by EU customs agents in 2017 were food stuffs.

In 2018 we were pleased to witness a number of serious law enforcement actions across the globe.  This is a trend which I hope will continue.  As an example, the people responsible for a long-running, fraudulent organic grain scheme in the USA were charged and pleaded guilty.  In Pakistan, the authorities have used new laws prohibiting the sale of unpackaged spices, which were created to reduce food adulteration, to seize 165,000 kg of spices and shut down 400 spice processing facilities.

Rising consumer awareness

Meanwhile, consumer awareness of food fraud is also rising.  Nearly three quarters of UK consumers think there is a serious problem with food fraud in their country and one quarter of consumers think they have experienced it first hand.

food fraud worries shoppers

Test method developments

In academia, new test methods for food fraud detection continue to be created and refined.  As exciting as it is to read headlines in journals about the latest scientific breakthrough, many of the research papers report on testing methodology that won’t be ready to be used by food manufacturers, wholesalers and retailers for some time.  One such exciting headline recently gushed that scientists have found a new ‘simple’ method to distinguish organic milk from conventional milk.   The headline did indeed to turn out to be too good to be true, with more work on a larger sample size needed to validate the method.   However, with organic products at very high risk of food fraud and detection being difficult, it’s great to see the analytical community working on these problems.

Our year working for you

Within Food Fraud Advisors we have been focussing on keeping up to date with our customers’ needs for the latest versions of SQF, BRC and IFS food safety standards.  Food fraud documentation is one of the top sources of non-conformities in food safety audits so many of our customers have been seeking help to boost their programs.

SQF’s standard in particular caused a few headaches for our clients.  SQFI did not publish any guidance for food fraud until after the implementation date for Edition 8.  As a result, many SQF-certified facilities needed our help to understand and implement programs to meet the new food fraud requirements before their first audits.  Within the  SQF guidance document there is a recommendation for senior managers to be trained in food fraud awareness and we were pleased to launch a short, practical on-demand training course to meet this requirement.   We’ve had great feedback about this course, and for only $59 it’s a great way to meet your continuous improvement and training requirements for 2019.

Also in 2018, our one-stop, deep-dive food fraud training course was re-launched, with new lessons, more downloadable templates, new content for food fraud teams and step-by-step instructions for creating and implementing a food fraud prevention program from scratch.   Check it out today. 

We look forward to working with you in 2019 and beyond.

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Five things every food safety professional should know about food fraud

1. Food fraud is in the spotlight

Food fraud has been around for thousands of years but has recently become more prominent in the food safety and food certification industry, following the European horse meat scandal of 2013.  Although no food safety problems arose during that incident, it was realised that similar incidences could have serious impacts on food safety.  For that reason, food fraud and food authenticity have been introduced into most major food safety management system standards within the previous two years.

2. New terminology is being developed

Definitions related to food fraud and food integrity have been developed and refined and there is now consensus on the four key terms below, although the term food security still causes confusion at times.

food fraud,defense,safety,security

  • Food safety relates to issues of unintentional contamination, with the aim of reducing exposure to naturally occurring hazards, errors and failures in food systems.
  • Food fraud was defined by  Spink and Moyer (2011) as “a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain.”  More recently that definition has been updated to capture all types of food crime: Food fraud is deception, using food, for economic gain (Food Fraud Initiative, Michigan State University).  Within food fraud there are types of fraud that involve tampering with the food by adulterating or diluting the food.  This type of fraud is sometimes called ‘economically motivated adulteration’ (EMA).  Other types of fraud that do not involve adulteration are also deemed to be ‘food fraud’.  These include black market and grey market sales, theft, illegal importing, avoidance of tax and counterfeiting.
  • Food defence is related to systems that are intended to prevent intentional contamination of food, whether that be for economically motivated reasons or for malicious reasons such as terrorism or extortion.  A food defense plan is a plan that aims to protect food from intentional contamination.
  • Food security is unrelated to food fraud but is instead an issue of food supply and food access for populations who are under threat from food shortages.

Other terms to know:

  • Vulnerability assessments are assessments of vulnerability to food fraud, either at the raw material, product or facility level.  Within the USA the term vulnerability assessment often refers to a food facility’s vulnerability to malicious tampering of product on its site, either by its own employees or external forces.  Within Europe, and particularly as described in the most recent issue of the British Retail Consortium’s (BRC) food safety standard, a vulnerability assessment is an assessment of a food material’s susceptibility to food fraud.  Learn more about vulnerability assessments.
  • Horizon scanning is the act of looking for and analysing threats and opportunities that will emerge in the medium to long term.  Within the food industry, horizon scanning means the act of collecting information about current trends and predicted incidences that could increase the likelihood of food fraud for a particular food material.  For example, climate change is likely to reduce coffee production which could drive up prices and increase fraudulent activity in that sector.
Coffee,authentic,fraud,horizon scanning
Future coffee harvests are likely to be affected by climate change

 

3. Food safety standards have become more rigorous

Food fraud prevention and mitigation measures are being introduced into all major food safety management systems.  The Global Food Safety Initiative (GFSI), a group of food companies whose mission is to harmonize, strengthen, and improve food safety management systems around the globe, sets guidance for food safety standards.  Well known GFSI standards include BRC, FSSC 22000 and SQF.  Between 2015 and 2017, all GFSI food safety standards were updated to include requirements for food companies to perform a food fraud vulnerability assessment and have a food fraud mitigation plan in place.   Click here for the GFSI Food Fraud Position Paper.

The new requirements for vulnerability assessments and mitigation plans require more resources for most food businesses, particularly those with large numbers of raw materials and suppliers.

4. There are new regulatory requirements for food businesses

The Food Safety Modernization Act (FSMA) in the USA has been implemented for most food businesses in the previous few years.  Within the FSMA rules, food businesses are required to address hazards from adulterants introduced for the purposes of economic gain.  These must be included in food safety hazard analyses and if hazards are found, preventive controls must be implemented.  This means that economically motivated adulteration (EMA), a subset of food fraud, must be addressed under the new FSMA rules.

The Food Safety Modernization Act (FSMA) also includes specific requirements for ‘food defense’ which are aimed at preventing malicious adulteration and tampering as well as fraudulent adulteration.  This is known as the Intentional Adulteration (IA) rule.  The IA rule is being progressively implemented in the USA.  FSMA rules for IA will also be enforced internationally for all food facilities that manufacture food for export to America.  Click here for US FDA’s food defense guidance

food defense,vulnerability assessment,FSMA,
All American food companies will be required to have a food defense plan

 

5.  Detection of food fraud remains a challenge, despite new lab techniques

Our ability to detect food fraud has improved over the last few years, but challenges remain.  There are many technologies available, from traditional ‘wet’ chemical tests to spectroscopy and chromatography to modern forensic DNA methods.   Protein isoelectrofocusing (a type of electrophoresis) is a conventional test that provides information about the source of various milk proteins in a cheese and can be used to detect cows milk in “buffalo milk” mozzarella, for example.  PCR (polymerase chain reaction) techniques, in which a cow milk-specific gene is amplified and detected are being developed for cheese testing and they are claimed to be more specific.

Coffee variety testing has traditionally been done using Fourier transform infrared spectroscopy, a method that exploits the different amounts of chlorogenic acid and caffeine in robusta and arabica varieties.  However, a new method that exploits the different mitochondrial genetic markers in the two varieties will soon be able to achieve the same results quickly and easily in the field with ‘lab on a chip’ technology.

Researchers looking for fraudulent aloe vera can exploit its distinctive NMR (nuclear magnetic resonance) profile, due to the position of acetate groups within a key polysaccharide in the plant.  The NMR profile represents a ‘fingerprint’ for aloe vera.

Another type of ‘fingerprinting’ is based on the spectra created by different ratios of stable isotopes.  For example, it is possible to tell the difference between corn-fed and wheat-fed chicken, using stable isotope ratio mass spectrometry by comparison with databases of reference samples.  This method has also been used to check provenance claims for meat and wine products.

Authentic beef mince
What meat is that?

 

Despite the surge in technology surrounding food fraud detection, it remains difficult to detect fraudulent adulteration unless you know what you are looking for.  As an example, DNA testing can be used to determine if beef mince has been made from a cow but can’t tell me whether it has been adulterated with undeclared beef offal.  Olive oil that is suspected of having been adulterated with other edible oil can easily be tested for such adulteration in a lab test, but verifying its country of origin is more difficult.  Adulteration of ‘arabica’ coffee with the cheaper robusta variety can be detected with a simple test but that same test will not disclose whether ground coffee has been adulterated with cheaper fillers such as corn, soybean or wheat, a practice which is common in some markets.  There are new ‘fingerprinting’ techniques that are designed to ‘flag’ any sample that is not authentic, no matter what the adulterant, however they can only be used if there is already an extensive database of authentic samples with which to compare the suspect sample.  Australian honey brand owners who were caught with supposedly inauthentic honey in an NMR-based fingerprint test claimed that the database used in the testing, which was done in Germany, was not suitable for testing Australian honeys.  Read more about the Australian honey scandal.

We have a lot of tools in our arsenal to answer questions about fraudulent food but those tools are only useful if we ask the right questions.

Need to learn more?  Want practical advice from expert food scientists? Click here for a free introductory consultation.