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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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Vulnerability Assessments

What is a vulnerability assessment?

In the food industry, the term vulnerability assessment refers to a risk-assessment-style evaluation of a food’s vulnerability to food fraud.  Food fraud is deception, using food, for economic gain (Food Fraud Initiative, Michigan State University 2016).  Some organisations, particularly in the United States of America, use the phrase vulnerability assessment when referring to malicious attacks on food, such as those conducted for extortion, ideological reasons or terrorism. However those types of risks are issues of food defense rather than food fraud and those risks are not considered here.  To learn more about vulnerability assessments for food defense (intentional adulteration), click here.

A food fraud vulnerability assessment is a documented assessment that identifies vulnerabilities to food fraud and explains how those vulnerabilities were identified.

 

Why ‘vulnerability’ and not ‘risk’? 

A vulnerability assessment is slightly different to a risk assessment; risk is something that has occurred before and will occur again, it can be quantified using existing data.  A vulnerability is a weakness that can be exploited by someone or something who wishes to profit or intends harm.  A vulnerability can lead to a risk.  Because food fraud is difficult to estimate and quantify, we use the word vulnerability rather than risk.  In addition, using the word ‘vulnerability’ helps to minimise confusion in the food industry where risk assessments for food safety are commonly performed and well understood.

Why do a vulnerability assessment?

  1. To protect consumers: Food that is vulnerable to food fraud presents significant risks to consumers.  Food that is adulterated or diluted   [Read more…]

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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.