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Food Fraud 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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Oregano Fraud; six things every food professional needs to know

1. What happened?

Testing was conducted by the Australian consumer group Choice, mirroring tests conducted in the UK and published by the UK Consumer Group Which? in 2015.  A selection of packs of dried oregano were purchased from supermarkets (grocery stores), delis (specialty food stores) and grocers (produce stores) in three cities in Australia and a single sample of each was tested.  Seven of the twelve samples, over fifty percent, were found to be inauthentic, with the inauthentic samples containing between 10% and 90% of ingredients other than oregano, including olive leaves and sumac leaves.

2. Why test oregano?  

Herbs and spices are one of the rock-stars of food fraud; their complex cross-border supply chains, high price per kilogram and the fact that they are often sold in powder or particulate forms make them prime targets for adulteration, dilution and substitution with cheaper materials.  

oregano adulteration
Source: Elliott, C. (2016) Addressing complex and critical food integrity issues using the latest analytical technologies

 

Why oregano in particular?  Professor Elliott, Director of the Institute for Global Food Security, and an international authority on food fraud conducted testing on oregano in the UK in 2015, the results of which were published by the UK Consumer group Which?.  It is possible that Prof Elliott used rapid evaporative ionization mass spectrometry (REIMS), a test method recently made available by Waters Corporation, although Which did not disclose the test method. REIMS makes use of a rapid sampling method that produces vapour which is analysed using time of flight mass spectrometry.  Sophisticated software compares molecular markers in the resulting spectrum with those in known materials in a database, allowing a sample to be quickly identified as belonging to a particular product type or not.  The method has huge potential for testing food authenticity, with one of the advantages being that unlike other tests for adulteration there is no need to specify which adulterants to seek.  A downside is that many hundreds or thousands of tests must be performed and compared to traditional analytical methods to create a database before the method can be used with confidence to determine the authenticity of any given material.

Professor Elliott recently revealed that Waters Corporation and Queens University, Belfast worked together to build a database of oregano samples (Elliott, C. (2016) Addressing complex and critical food integrity issues using the latest analytical technologies).  This means that oregano is one of the few materials that can currently benefit from accurate authenticity testing using the REIMS method. 

3.  Are the results unexpected?

Global food fraud commentators attribute the presence of significant concentrations of adulterants or diluents in dried herbs to economically motivated food fraud in most cases, as opposed to seafood mislabelling which sometimes occurs due to unintentional errors in species identification.  Food fraud is estimated to cost the United Kingdom one billion pounds each year.  It is thought to be very common among some food types, including herbs and spices.

4. Who is responsible?

It is highly unlikely that any of the brand owners named in the Choice report were aware that they were selling adulterated herbs.  Most if not all of the brands included the Australian testing would have been sourced and packed under well-controlled systems that include vendor approval processes, formal specifications for incoming materials (such as bulk herbs) as well as certificates of analysis and declarations of conformity to specification.   The fraudulent tampering probably occurred further up the supply chain during drying, bulk packing, shipping or storage.  Interestingly, all seven adulterated samples contained olive leaves and two contained sumac leaves.  It is possible that tampering occurred in two different points within the supply chain for some products; perhaps one fraudster added olive leaves to bulk lots of the herb at a location close to the oregano growing area and sumac leaves were added by someone else at a later date.

5. What are the legal and financial ramifications?

The sale of misrepresented products is a breach of Australian consumer law and ignorance cannot be used as a defense.  The incidences were investigated by the Australian Competition and Consumer Commission (ACCC), an independent authority of the Australian government.  One company was fined a substantial sum for selling product that contained only 50% oregano leaves.  It is likely that other businesses that had been supplied with inauthentic herbs sought financial redress from their suppliers, either through purchasing contract penalties or through private legal action.

When a food business chooses to voluntarily recall or withdraw their products from the marketplace they may try to claim the costs against their business insurance. Insurance companies will seek to recover their costs from further up the food supply chain and this may have an impact on premiums in coming years.

6. What should food businesses do?

No food business is immune from economically motivated food fraud and preventing food fraud from affecting a business is a multi-functional task that should involve personnel from purchasing, finance and legal departments as well as food safety and quality personnel.  In the short term however, there are some things that can be done by food safety and quality personnel to help prevent, deter and detect food fraud without a lot of investment from other parts of a food business: 

  1. Update your purchasing specifications to include authenticity requirements.
  2. Review your vendor approvals systems and revise questionnaires and requirements if required.  Consider implementing more stringent requirements for those suppliers that provide vulnerable materials.
  3. Request certificates of analysis (CofA) from suppliers of vulnerable materials
  4. Begin a testing regime for vulnerable materials
  5. Investigate the costs and benefits of supply chain audits, including whether ad-hoc, one-off visits to certain suppliers might be worthwhile
  6. Request tamper-evident packaging and bulk container tamper seals for vulnerable raw materials
  7. Ask suppliers of vulnerable materials to undertake a mass balance exercise at their facility or further upstream in the supply chain.
  8. Make a business case for switching suppliers of materials that prove to be consistently problematic and present it to your purchasing department.

Want to learn more about food fraud mitigation in the spice industry?  This article in Food Safety Magazine provides an excellent insight. 

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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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Learn the lingo; food fraud terms explained

Food fraud occurs when food or drink is sold in a way that deliberately misleads or deceives consumers or customers for financial gain (Food Fraud Advisors, 2015)

(other definitions)

Food fraud occurs in two different forms:

1. Fraudulent activity that does not involve tampering with the food itself:

This includes activity such as avoidance of taxes, duties and quota restrictions (fishing), fraudulent paperwork such as forged importation documents, misrepresentation of origin, changing best-before dates and counterfeiting of popular brands.

2. Adulteration of food for economic gain:

This is sometimes referred to as economically motivated adulteration or EMA.  In this phrase, the word ‘adulteration’ is used to encompass many types of tampering, such as adding unauthorised substances, substituting undeclared substances for genuine components of a food or diluting a food product with cheaper substances.

Food fraud is a type of food crime, with food crime including food fraud and other activities such as the use of food shipments to mask drug trafficking and money-laundering through the trading of food and food commodities.

food fraud,defense,safety,security

Food fraud and the risks it presents to the food industry is a separate subject to food safety, although fraud-affected food can be unsafe.  Food safety relates to unintentional contamination of food and the presence of naturally occurring contaminants.

Food defence (food defense) is a term that has come to be defined as the effort to prevent acts of adulteration that are intended to cause harm to a food business or to consumers, such as acts of terrorism or attempted extortion.

Food security, as defined by the World Health Organisation exists “when all people at all times have access to sufficient, safe, nutritious food to maintain a healthy and active life”.

Risk or vulnerability?  In the language of food fraud, the term risk is usually replaced with the term ‘vulnerability’, so food standards bodies are increasingly talking about vulnerability assessments rather than risk assessments.  ‘Vulnerability’ is used because food fraud ‘risks’ do not exactly fit with the accepted definition of risk as something that has occurred frequently, will occur again and for which there is enough data to make quantitative assessments.  Vulnerability is a better term for food fraud, due to the fact that the ‘risk’ of a specific fraudulent activity occurring cannot be quantitatively assessed.

Horizon scanning is another term that has been co-opted to the language of food fraud.  Horizon scanning is the act of looking for and analysing threats and opportunities that will emerge in the medium to long term.  It is used across many industries, including the financial and health care industries.  Within the food industry, horizon scanning refers to the act of collecting information about current trends in food production and predicted incidences that could increase the likelihood of food fraud for a particular food material.  For example, climate change is likely to affect coffee production which could drive up prices and increase fraudulent activity in that sector.  Click here for the complete low-down on horizon scanning.

TACCP: Threat Assessment Critical Control Point.  TACCP = prevention of malicious threats to food.

VACCP: Vulnerability Assessment Critical Control Point.  VACCP = food fraud prevention.  Learn more about TACCP and VACCP here.

Intentional Adulteration:  Although food fraud activities often involve the intentional adulteration of food with unauthorised substances, within the food safety industry, Intentional Adulteration has recently been given a more specific meaning.  And it is not related to food fraud at all.  It is related to food defense, and more specifically to activities intended to cause wide scale harm to consumers.  There is a rule within the USA’s Food Safety Modernization Act (FSMA), that addresses these activities.  It is known as the Intentional Adulteration rule.  According to the US FDA (2019), Intentional Adulteration is the deliberate contamination of food with a biological, chemical, radiological, or physical agent by an individual or group of individuals with the intent to cause wide scale public health harm.  How to protect against intentional adulteration. 

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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.