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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.   www.foodfraud.org.
  • Food Fraud Advisors’ Food Fraud Risk Information Database is a free and open-access online database of food fraud incidences and emerging threats 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 which are available here.

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

Visit our training academy today

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Announcing our new online training course

Food fraud requirements of BRC, SQF, FSSC and other food safety standards

How to meet the food fraud prevention requirements of major food safety standards

This course will make audit preparation a breeze.  It contains step-by-step instructions, worked examples and downloadable templates to help you meet the food fraud requirements of all major food safety standards.

sqf edition 8 food fraud

 

  • Learn why food fraud prevention has been included food safety standards
  • Hear food fraud stories that will surprise you and learn ways to protect your business
  • Get step-by-step instructions for food fraud vulnerability assessments and food fraud mitigation plans, using real life examples
  • Download templates for vulnerability assessments, mitigation plans and food fraud prevention procedures
  • Proceed at your own pace; skip forward and back through the lessons, start and stop at your convenience*

The content is a mix of written words and short video clips, plus downloadable worked examples.

Ask the trainer a question at any time.

What’s included?

  • Food Fraud Commonly Affected Foods Ebook
  • Food Fraud Vulnerability Assessment template
  • Food Fraud Prevention Procedure template
  • Food Fraud Mitigation Plan template
  • Vulnerability assessment document – worked example
  • Raw Material Specification template
  • Food Fraud Team Job Descriptions
  • Top tips for audit preparation
  • Special 40% discount code for use on www.foodfraudadvisors.com
  • Optional exam and Certificate of Competency

Duration: 3.5 hours

Visit our training academy today

* course is available for 6 months after commencement

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September food fraud update; trade wars, fruit scares and spuds

The ‘trade war’ between the USA and China is really hotting up, with China having imposed import tariffs of up to 25% on US lobsters and other food products in the previous 2 months.  The presence of tariffs greatly increases the risk of fraudulent cross-border activities; Food Fraud Advisors predicts that the new China tariffs will lead to significantly more food fraud within the Chinese-American trade sector as well as having a knock-on affect on food trade internationally.

There have already been allegations of fraud related to the tariff imposition in the North American lobster market.  Canadian lobsters can be imported to China without incurring the tariffs imposed on lobsters from the United States.  It has been alleged that lobsters grown in the USA are being shipped to Canada, re-labeled as Canadian lobsters then exported to China.  Canadian lobster growers fear damage to the ‘Canada’ brand from these activities.

The strawberry scandal in Australia has hit local consumers, retailers and growers hard.  It started with two consumers in the state of Queensland finding metal needles inside fresh strawberries.  The affected brand and its sister brand from the same grower were pulled from shelves.  Within days another needle-like object was found in strawberries from a different brand in a different state; the fruit source was completely different and the incident was labelled a ‘copycat crime’.  In Australia strawberries are typically sold to consumers in clear clam-shell containers with four air holes in the top surface.  The air holes are large enough to allow access to the fruit inside with a small sharp object like a needle while the strawberries are displayed on a supermarket (grocery store) shelf.  Public response has been confusion; why would anyone want to do such a thing?  Since then, other fruits, including apples and bananas have been similarly affected, again, in what appear to be completely independent occurrences.  The food safety sector in Australia is at a loss as to how to prevent this type of incident; fruit is by necessity displayed and accessible for consumers to touch prior to purchase, leaving it vulnerable to malicious adulteration.

Meanwhile, strawberry growers in Australia, who were already struggling to get good prices for their bumper harvest, have seen demand for their fruit plummet.  Media outlets have published reports about farmers who are dumping tonnes of unwanted fruit because the wholesale price has fallen below the cost of production.

Whole potatoes are generally thought to be at low risk of food fraud because of their relatively low value and because of their easily recognisable form.  However, like all fruit and vegetables, they are at risk of being misrepresented with respect to their geographic origin and their variety.  Growers groups have demanded that government authorities investigate allegations of potato fraud in Ireland, after a successful campaign to encourage consumption of locally-grown Queen potatoes.  It has been alleged that imported potatoes and potatoes of other varieties are being re-labelled as Irish Queen potatoes, providing an economic gain for the perpetrators of this fraud.

 

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HACCP, VACCP and TACCP

HACCP (Hazard Analysis Critical Control Point)  Pronounced ‘hassup’.  HACCP = food safety.

VACCP (Vulnerability Assessment Critical Control Point) Pronounced ‘vassup’.  VACCP = prevention of economically motivated food fraud.

TACCP (Threat Assessment Critical Control Point) Pronounced ‘tassup’.  TACCP = prevention of malicious threats to food, such as sabotage, extortion or terrorism.

HACCP is a set of principles designed to control and prevent food safety risks during food production.  The ideas of HACCP form the basis of every food safety standard that is in use today.  HACCP is not owned or regulated by any organisation.  The principles of HACCP are codified (written down) by the World Health Organisation (WHO), which is part of the United Nations (UN), in a set of documents called the Codex Alimentarius , a latin phrase which translates to “Book of Food”.   The principles of HACCP are described in the Annex of the Codex document GENERAL PRINCIPLES OF FOOD HYGIENE CAC/RCP 1-1969.  You can download a copy of the code of practice here and you can view the Annex containing the principles of HACCP here.

VACCP and TACCP are relatively new terms that have emerged in the last ten years as standards agencies, government regulators and industry groups have been talking more about how to prevent food fraud and malicious tampering.  The general idea is to create new preventive systems similar to the ideas behind HACCP.  We know that HACCP is effective at preventing inadvertent contamination, and more importantly it is well understood by food businesses, auditors, standards writers and regulators.  So take the ideas of HACCP, replace the ‘Hazard’ with ‘Vulnerability’ or ‘Threat’ and go for it, right?

The idea sounds good in theory, but what about in practice?  The critical control ‘points’ in a VACCP and TACCP plan do not look much like the ‘control points’ in a HACCP plan at all. The control points in a HACCP plan are operational steps in a manufacturing process; the process is generally linear and the ‘control points’ are operational processes over which the food manufacturer can exercise direct control.

In contrast, the actions that are required to prevent deliberate tampering within a food supply chain do not sit comfortably on a linear set of operations.  The terms VACCP and TACCP are falling out of favour within the food fraud and food defense communities.  They are not referenced specifically within any of the GFSI food safety standards, nor within the USA’s FSMA.  It is much better practice to say “Vulnerabilities to food fraud” or “threats of malicious tampering”.

More acronyms demystified here.

Learn more about food fraud here.

Or start one of our online, on-demand training courses today.

food safety food fraud

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How to design a food fraud testing plan

Authenticity testing of ingredients and foods is an important tool in the fight against food fraud, but it’s not easy to get it right.  Here are our recommendations to help you design a food authenticity testing plan.

  1. First define the goals of the testing plan.  Because different materials have different food fraud risk profiles, you will need a different testing protocol for each material that you want to test.  For each material to be tested, choose a test type and laboratory and set accept-reject criteria for test results.  Use our testing checklist to help.
  2. Decide how samples will be collected, and define the sample size with the help of your chosen laboratory. For each lot or batch of material that needs to be tested, figure out how to obtain a sample that is properly representative of that batch. Sampling protocols will depend on the size of the lot, the form of the food (solid, liquid, bulk, etc.) and the practicalities of accessing materials within the batch.  Learn more about sampling protocols from the US FDA’s laboratory manual.
  3. Choose a frequency of testing for each material and document it in the plan.
  4. Write down your goals, test methods, accept/reject criteria, sampling procedures and approved laboratories.  This written information will be the foundation for your testing plan document. Add a description of what action you will take if you get results that confirm or imply authenticity problems with the sample. Who will you report the results to? Who is responsible for making decisions about actions to be taken?  Add document control features and file the plan within the food fraud section of your food safety management system.
  5. Implement your plan.  Be prepared to change your test frequencies or test methods as new information becomes available.  Review your test plan at least annually to make sure it aligns with your food fraud vulnerability assessment results.

 

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Food testing checklist

Like many other food safety and quality professionals, perhaps you are thinking about implementing a testing program for food fraud detection.  Are there vulnerabilities in your supply chain? Maybe you are buying products or raw materials that are on our food fraud hot list, or perhaps your food fraud vulnerability assessments identified materials that might be affected by food fraud.

Food authenticity testing laboratory lab

Testing is an important tool in the fight against food fraud, but it’s not always easy to get it right. Are you prepared for testing? Before you begin to contact laboratories, make sure you can answer these questions:

  • Do you need a ‘snap-shot’ of a product at a single point in time or are you aiming to build a longer-term picture of authenticity?
  • Are you acting on any specific information, such as a tip-off or allegation from a competitor?
  • Is there a particular adulterant you need to look for?
  • Are you a brand owner checking possible counterfeits or diverted products to determine if they are legitimate?
  • Do you need the test results to stand up in a court of law or other legal scenario?
  • Is the test material a single agricultural product or a processed multi-component food?
  • Is the material shelf stable or will it need special sample storage/transport conditions between sampling and testing?
  • Is the testing needed to check on credence claims, for example, organic, free-range, country of origin?
  • Do you need qualitative or quantitative results? For example do you need to know if an adulterant is present or absent in the tested material or do you also need to know the amount of the adulterant that might be present?
  • What level of certainty do you require?
  • How much time have you got?
  • What’s your budget?

And finally…

  • Are you prepared for what you might find; do you have a plan of action to take if food fraud is detected?

There are many laboratories that perform some type of food authenticity testing, but few that perform many types. Expect to speak to a number of different laboratories before you find one that can meet your needs.

Coming soon: How to design an authenticity testing program

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Fraudulent practices cost chicken processor £37m

A large chicken processing business, 2 Sisters was the biggest supplier of supermarket chicken in the United Kingdom with a turnover of £1.1 billion in 2017.  During that year, an undercover investigation revealed poor hygiene practices and tampering with date codes was taking place at one of the firm’s processing plants in West Bromwich.  Investigators also alleged that products returned from distribution centres that should have been destroyed were repackaged as if they were fresh, and that the ‘kill dates’ for chickens were deliberately misrepresented so as to extend the expiry date of the finished products.

The Food Standards Agency investigated and in addition found fraudulent practices within the Salmonella testing of the carcasses.  Salmonella testing is a regulatory requirement in the United Kingdom.  In the wake of the investigations, operations at one plant were suspended for 2 weeks, while another was closed permanently.  In April, it was announced that another plant, in Scotland will be closed later this year.

This week, 2 Sisters reported losses of £38 million for the year, a figure that was reported to have ‘ballooned’ by 80% after the fraudulent practices were uncovered.