Karen Everstine, Decernis
Food Fraud Quick Bites

Lead in Spices

By Karen Everstine, Ph.D.
2 Comments
Karen Everstine, Decernis

Food fraud usually does not make people sick, but we know that it can. Fraud in spices, and particularly lead adulteration of spices, appears to be getting more attention lately. Herbs/spices is one of the top five commodity groups prone to fraud, according to the data in our Food Fraud Database. Looking at the past 10 years of data for herbs/spices, chili powder, turmeric, and saffron have the highest number of fraud records and chili powder, turmeric, and paprika have the highest number of distinct adulterants associated with them (see Figure 1).*

Adulterants, herbs and spices
Comparison of herb/spice ingredients by the number of distinct adulterants and number of records (2010-2019). Source: Decernis Food Fraud Database

Fraud in spices usually involves “bulking up” the spice with plant materials or other substances or the addition of unapproved coloring agents. A wide range of pigments have been detected in spices, from food-grade colors to industrial pigments, including lead-based pigments. Lead oxide was added to paprika in Hungary in the mid-1990s to improve the color, causing lead poisoning in many consumers. Lead chromate is another lead-based pigment that has been used to add color to spices. In 2017, ground cumin was recalled in the United States due to “lead contamination,” which was determined by the New York State Department of Agriculture and Markets to be lead chromate.

However, there is also an issue with lead contamination of agricultural products due to environmental contamination and uptake from the soil. Therefore, when recalls are posted for spices due to “elevated lead levels,” it may not immediately be apparent if the lead was due to environmental factors or intentionally added for color.

Laboratory methods for detecting the form of lead present in food are challenging. Typical tests look to detect lead, but do not necessarily identify the form in which it occurs. Testing for lead chromate, specifically, may be inferred through a test for both lead and chromium, and recent studies have looked at the development of more specific methods. There is not currently an FDA-established guideline for lead levels in spices although, the maximum allowable level for lead in candy is 0.1 ppm (0.00001%). New York State recalls spices with lead over 1 ppm and a Class 1 recall is conducted with lead over 25 ppm.

Two recent public health studies have evaluated lead poisoning cases and have linked some of those cases to consumption of contaminated spices. One study, published earlier this year, analyzed spice samples taken during lead poisoning investigations in New York over a 10-year period. The investigators tested nearly 1,500 samples of spices (purchased both domestically and abroad) and found that 31% of them had lead levels higher than 2 ppm. This study found maximum lead levels in curry of 21,000 ppm, in turmeric of 2,700 ppm, and in cumin of 1,200 ppm.

Another study conducted in North Carolina looked at environmental investigations in homes and testing of various products related to 61 cases of elevated lead levels in children over an eight-year period. The investigators found lead above 1 ppm in a wide variety of spices and condiments, with some levels as high as 170 ppm (in cinnamon) and 740 ppm (in turmeric).

A separate study, conducted in Boston, involved the purchase and analysis of 32 turmeric samples. The researchers detected lead in all of the samples (with a range of 0.03-99.50 ppm), with 16 of the samples exceeding 0.1 ppm (the FDA limit for lead in candy). The paper concluded that turmeric was being “intentionally adulterated with lead” and recommended additional measures on the part of FDA to reduce the risk of lead-contaminated spices entering the U.S. market and the establishment of a maximum allowable level of lead in spices.

Although the above studies did not report the form of lead detected, the high level of lead in many of the samples is not consistent with environmental contamination. A newspaper report in Bangladesh indicated that turmeric traders used lead chromate to improve the appearance of raw turmeric and quoted one spice company as saying that some of their suppliers admitted to using lead chromate. Lead consumption can be extremely toxic, especially to children. There is evidence that lead contamination of spices in the United States is an ongoing problem and that some of it is due to the intentional addition of lead-based pigments for color. This should be one area of focus for industry and regulatory agencies to ensure we reduce this risk to consumers.

*Given the nature of food fraud, it is fair to say that the data we collect is only the tip of the food fraud “iceberg”. Therefore, while this data indicates that these ingredients are prone to fraud in a number of ways, we cannot say that these numbers represent the true scope of fraud worldwide.

FST Soapbox

Why I’m Attending the Food Safety Consortium Conference & Expo and You Should, Too

By Jill Droge
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As someone who recently switched industries and is now an executive in a business development role for a curriculum development company that provides a 100% online PCQI course, I was trying to determine which of the many events to attend in the food industry.

After some research, I decided to attend the 7th Annual 2019 Food Safety Consortium Conference & Expo and felt it would be helpful for anyone in a business development or sales/marketing role to have some details and tips about how I prioritize events. I also wanted to provide additional information for those in a C-level, Director, Manager, etc. position that are setting plans for the remainder of 2019 and establishing plans for 2020.

Location, Location, Location!!!

Rick Biros, president of Innovative Publishing Co., has more than 25 years of experience in the food industry and is very well known and respected. Rick saw the need for this type of event due to the variety of changes in the industry. Rick and his team did the research on the best place to have the event, which included considerations like ease of access to airports, hotel cost and percentage of food manufacturers in the area. His team found that the Schaumburg, IL area has the highest concentration of food manufacturers within a 200-mile radius. In addition, Chicago O’Hare airport is only a 30-minute ride to the beautiful Renaissance Schaumburg Convention Center where this event has been held. The Consortium team was able to negotiate a very reasonable hotel rate of around $175/night, which is a terrific deal for this area. It is also close enough to downtown Chicago that if you want to stay an extra day or two or take your team out, you have plenty of options available.

Two Great Events for One Price!

This year the Food Safety Consortium Conference & Expo is co-located with the Cannabis Quality Conference & Expo this year. Anyone in the food industry understands how fast things are expanding and changing within the cannabis industry, not to mention that the state of Illinois has approved adult use effective January 2020. Both events will share the same exhibit area, which is a tremendous plus for anyone who is trying to make contacts within both industries and has invested in a booth space. This also means that attendees from both events will be a part of the social mixer events on Tuesday and Wednesday evenings, facilitating additional networking opportunities.

Decision Makers Are Present

There are many different events within the food industry, but few have a high percentage of the actual decision makers in attendance. Often, they are made up of a variety of people from the education, government and industrial sectors of the industry that may be students, entry-level management, etc. Based on the attendance from the past, 98% of attendees to this event are within the Industrial sector of the food industry. More importantly, due to the contacts that Rick & team have made over the past years, the C-level and mid-level management make up a very large portion of those that attend this event. This enables attendees to network with those who can make the key decisions that may impact your company’s growth, as opposed to talking with someone about what your company offers only to find out they are multiple levels of approval that need to happen before even moving forward to present a proposal.

Training & Expo Discount Combinations

While there are numerous options provided within registering for this dual conference event, one option is to take advantage of the discounted rate on combining event attendance with training. One of these training options is offered by my company, ImEpik, which offers full-access to the Expo and conference sessions, and includes our 100% online PCQI course that is self-paced and available 24/7 for your convenience. The Innovative Publishing team has agreed to offer both for the low price of $895. That is lower than ImEpik’s retail cost, minus any promotions, for just the course itself –so the fact that you can get both our course and a full-conference pass to the Food Safety Consortium and the Cannabis Quality Conference is a tremendous value for any company. One other detail is the person attending doesn’t have to be the person that is given access to the training. The attendee may be senior level management who doesn’t need additional training but may need someone within his or her staff to receive PCQI training. Additional details about the training we offer are available on ImEpik’s website.

Team Building & Leadership Is a Priority

There are three breakout sessions that occur throughout the event. Each of those sessions will fall into one of the following categories:

  1. Food Safety & Testing
  2. Sanitation & Operations
  3. Food Safety Leadership

As many folks that I have personally spoken with at various events have attested, typically the leadership in the food industry is more “technical” in their leadership. One focus at the event this year is break-out sessions that focus on topics such as empowered leadership, team-building, and enabling teams that are afraid of making mistakes and therefore may not voice their opinion, which may include some positive ideas for company leaders. Come join Kathryn Birmingham, V.P. of Research & Development at ImEpik, and I as we present: Beyond meeting the FSMA regulations, the business case for PCQI, Wednesday, October 2 at 2:45 PM.

In summary, I hope this article is helpful in your 2019/2020 event planning. The networking opportunity as well as the chance to take advantage of combined training packages, multiple Expos (Food Safety and Cannabis) and access to decision makers make this event a “must” to attend. For more details on the agenda, hotel, etc. please visit the Food Safety Consortium website. Hope to see you there, and please visit Imepik at booth 105 on the Expo floor.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Palm Oil to Dye For

By Susanne Kuehne
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Susanne Kuehne, Decernis
Decernis, Food Fraud, Palm Oil
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne

Sudan IV, a diazo dye widely used to stain fuel and industrial grease, is a carcinogen and therefore unsuitable for human consumption. In a recent case in Ghana, it was added to palm oil to achieve the typical reddish-brown color. Adulteration of palm oil is a recurring issue that has been taking place across Asian and African brands, including products sold in Europe, and authorities keep warning of the consumption of the tarnished palm oil.

Resource

  1. Times of Malta (June 28, 2019). “Palm oil contains dangerous dye, authorities warn”.

Additional Resources

  1. FDA food alert, April 2018, Palm oil recall due to the presence of Sudan IV
  2. Swiss government warns of cancerous palm oil, January 2018. Palm Oil adulteration with Sudan IV. Origin of the oil is unknown but most likely an African producer
  3. CFA Alert, August 2017, Food recall: Palm oil adulterated with Sudan IV
Melody Ge
FST Soapbox

Compliance with the Intentional Adulteration Rule: Using FMEA for Your Vulnerability Assessment

By Melody Ge
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Melody Ge

What is FMEA? What is a vulnerability assessment (VA)? How can these two be linked? Despite what you may think, there are similarities between these two methods. FMEA (Failure Modes and Effects Analysis) methods can be utilized to help objectively assess the vulnerable steps within your process.

After July 26, 2019, businesses other than small and very small businesses (defined by FDA) must comply with the FSMA Intentional Adulteration (IA) Rule. The rule is intended to enforce industry regulation to conduct vulnerability assessments and address proper mitigation plans to prevent any potential fraud risks within the food defense plan. For small businesses, the compliance date is July 27, 2020; for very small businesses, the compliance date is July 26, 2021.

Although the IA rule does not specify a particular method that you must use to conduct your VA and address proper mitigation plans, the following elements must be considered during your evaluation and mitigation strategy and must be implemented at each actionable step afterwards:

  • The potential public health impact (e.g., severity and scale) if a contaminant were added (21 CFR 121.130(a)(1))
  • The degree of physical access to the product (21 CFR 121.130(a)(2))
  • The ability of an attacker to successfully contaminate the product (21 CFR 121.130(a)(3))

During the 2019 Food Safety Consortium, Melody Ge will present: How to prepare ourselves in this data-driven transitioning time for the smart food safety era? | October 2 @ 10 am FMEA is a Six Sigma method widely used in operations when implementing a new process. It is a structured approach to discover potential failures that may exist within the design of a product or process. Within FMEA, the RPN (Risk Priority Number) score is used to prioritize risks and is calculated by Severity × Occurrence × Detection. RPN is a quantified number that helps you prioritize risks when determining actions. If we employ the same mentality, FMEA is a useful method in helping to identify vulnerable steps based on the risk within your process. Take a close look at how the RPN is generated; the following three components are also important during the vulnerability assessment.

Severity or the potential public health impact (e.g., severity and scale) if a contaminant were added.
Severity is identified when considering the consequence of when a processing step goes out of control; or thinking about the severity of the health impact. We can consider those impacts or consequences using four common categories:

  • Biological contaminants
  • Chemical contaminants
  • Physical contaminants
  • Intentional adulteration for economic gain contaminants

Occurrence or the degree of physical access to the product.

Occurrence is identified when considering how frequently a process step is expected to go out of defined controls. Is it once a week or once a month? Depending on how often the step goes out of defined controls, this will trigger different action steps as well as mitigation plans.

Detection or the ability of an attacker to successfully contaminate the product.

Detection is considered by how easy it can be detected when the failure occurs. For example, within the food production operation, mixing steps is relatively easier than a CIP step to be detected. More references could be found in FDA’s definition of KAT (Key Activity Types, as discussed in the draft guidance, “Mitigation Strategies to Protect Food Against Intentional Adulteration”), such as:

  • Bulk and liquid receiving and storage
  • Liquid storage and handling
  • Secondary ingredient handling
  • Mixing and similar activities

Once the RPN is identified, then the vulnerable steps can be sorted based on the RPN. To utilize this approach, Table 1 provides a template to be considered using FMEA for the vulnerability assessment.

Process Step Description Is it KAT? (Y/N) RPN Action Process Step Mitigation Strategy Explanation
Sev Occ Det RPN
Table 1: Determine the vulnerable steps (for reference)

As IA rules regulate, a mitigation plan must be generated once a vulnerable step is identified. The intention of the plan shall ensure those risks identified are mitigated and controlled so that the final finished products are not impacted or contaminated. One tip to begin this process is to start with reviewing your current control plan for potential food safety risks. As FSMA Preventive Controls are fully implemented, all food plants shall have a food safety plan in place with validated control plans that are intended to reduce risks for potential physical, chemical, biological and adulteration for economic gain. Sometimes, these risks are highly associated with potential vulnerable steps for intentional adulteration, especially those processing steps associated with potential economic gain hazards. If those controls are not working properly, then we can seek out other mitigation plans. Nevertheless, regardless of what steps are taken, they have to be validated to show that the IA risks are effectively mitigated. Monitoring and verification shall be conducted as well once the mitigation plan is implemented.

Of course, like all food safety management systems, every food plant should have its own designated plans based on the products being produced, operations implemented and the nature of the production. Ultimately, it will be your choice to find an effective method that fits your production culture. However, the intention should always be in compliance with the IA rules: Identify the vulnerable steps within the process, and conduct mitigation plans to control the risks of intentional adulteration.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Food (or Beverage) Fraud That Kills

By Susanne Kuehne
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Susanne Kuehne, Decernis
Food fraud, methanol, alcohol, Costa Rica
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne

Methanol is highly toxic for humans, and increased amounts can show up in fraudulent or illegal alcoholic beverages. Dozens of methanol poisoning cases still happen every year around the world, some of them being deadly, according to the World Health Organization (WHO). The FBI is assisting the Costa Rican Police in the investigation of 20 recent deaths that are possibly methanol-related. Costa Rican authorities have searched a production facility, seized liquor and issued a nationwide alert.

Resource

Knowles, H. (July 24, 2019). “Tainted alcohol has led to 20 deaths in Costa Rica, authorities say”. The Washington Post.

Alec Senese, Bayer Crop Science, Digital Pest Management
Bug Bytes

Back to the Future…of Pest Management

By Alec Senese
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Alec Senese, Bayer Crop Science, Digital Pest Management

Some of you may not remember the days when pest control companies were few and far between and the majority of pest management programs were run by in-house experts. But in-house pest management programs used to be the rule, not the exception. Over time, most companies have adopted third-party pest management services as a way to manage costs. In-house programs are certainly more costly than third-party services, but they have significant advantages over today’s outsourced approach. Because of a shared accountability and responsibility for the outcome, well-managed in-house programs incorporate greater expertise and responsiveness.

While outsourcing pest control services will continue to be the standard, manufacturers do not enjoy the same level of transparency as they did in the past. Manufacturers trust that the job is being done well, but with limited in-house pest management expertise, it can be hard to know if gaps or “blind spots” exist in the program that can put them at risk.

With this in mind, it is important to remember that you rely on the expertise of your service provider. However, consider whether cost containment efforts have put your brand reputation in the hands of the lowest cost service provider, not necessarily the best provider. Your provider may be responsible for your pest management program, but they are not accountable for the consequences—you are. There are, however, ways to mirror the results of an in-house program by collaborating with service providers and aligning expectations. It may require building in-house knowledge and understanding of new technologies available today in order to partner with your service provider and get their very best service.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Need to Focus on Crocus

By Susanne Kuehne
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Susanne Kuehne, Decernis
Food fraud, crocus, saffron
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne

Many food adulteration cases revolve around spices, since the profits can be significant. Genuine saffron is the world’s most costly spice by weight. Often, fraudsters blend real saffron threads, which are derived from saffron crocus flowers, with cheaper fibers from other plants. Saffron costs up to $9 per gram and is therefore a spice that is very tempting for fraudsters to adulterate. Product sold in the UK led to the seizure of 90 kg of fake saffron in Spain and subsequent arrest of two fraudsters.

Resource

  1. Spirit FM News Team (August 6, 2019). “Fake saffron found in West Sussex sparks international investigation”. Spirit FM News.
Susanne Kuehne, Decernis
Food Fraud Quick Bites

Oodles of Not-so-Sweet Potato Noodles

By Susanne Kuehne
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Susanne Kuehne, Decernis
Food fraud, noodles
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne

One of China’s and other Asian countries food staples are sweet potato noodles. However, almost 60% of investigated samples tested positive for cassava, a common adulterant in sweet potato noodles (and also the basis for tapioca). The DNA of 52 samples was extracted and analyzed by the real-time loop-mediated isothermal amplification (Real-time LAMP) method, which showed accurate detection down to a 1% limit.

Resource

  1. Wang, D., et al. (May 29, 2019). “Detection of Cassava Component in Sweet Potato Noodles by Real-Time Loop-mediated Isothermal Amplification (Real-time LAMP) Method”. Molecules 2019, 24(11), 2043. Retrieved from: doi:10.3390/molecules24112043

 

Alec Senese, Bayer Crop Science, Digital Pest Management
Bug Bytes

Meet the Three Biggest Rodent Offenders

By Alec Senese
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Alec Senese, Bayer Crop Science, Digital Pest Management

Rodents are wary and cautious animals. Because of their discreet and mainly nocturnal nature, hundreds can be present in a facility without anyone knowing, all the while spreading dangerous bacterial diseases.

In order to outsmart them and protect your facility, you need to know what you’re dealing with. I’d like to introduce you to the three biggest rodent offenders and share some helpful hints to help you identify them. Without further ado…

Norway Rat

Norway rats are large, stocky, strong and sometimes aggressive. Common characteristics include coarse, reddish to greyish brown fur, blunt noses, small, close-set ears and short, scaly, semi-naked tails. They dig burrows and often nest in their burrows or in basements, walls, floor voids, woodpiles and sewers.

REGISTER NOW! Complimentary Webinar: Pest Management, Accountability and Food Safety: How to get more from your service provider | September 10, 2019 | 12 pmPossible signs of Norway rats: Urine and droppings with blunt ends, grease marks, fighting noises, scurrying and climbing sounds, footprints (about 2 cm-long and may show 4-5 toes), visual signs of gnawing that are around 0.3 cm and damaged goods (favorite foods include meat, fish, cereal and dry dog food).

Roof Rat

Roof rats are smaller and sleeker in appearance than Norway rats. Common characteristics include grayish black to solid black fur, pointed snouts, large ears and long tails. They are climbers and often nest in stored material, walls, appliances, false ceilings, wood piles, floor voids, garages, storm drains, attics and in vegetation like ivy and climbing vines, in trees like yucca, palm and cypress trees.

Possible signs of Roof Rats: Grease marks, fighting noises, scurrying and climbing noises, footprints (about 2 cm-long and may show 4-5 toes), visual signs of gnawing that are around 0.3 cm and damaged goods (favorite foods include fruit, vegetables and cereal). FYI: Roof rats do not often leave signs of urine or droppings on building floors.

House Mouse

House mice have small, slender bodies. Common characteristics include dark grey fur, large ears and long, semi-naked tails. They nest in walls, attics, trees, storm drains, woodpiles garages, basements, closets and storage places. They are especially drawn to insulation and voids of the walls with fibrous and shredded materials like paper, cloth, burlap, insulation or cotton.

Possible signs of house mice: Small droppings similar to those of large cockroaches, footprints (more numerous than a rat’s and do not exceed 1 cm-long), characteristic musky odor, scurrying and climbing sounds, visual signs of gnawing that are around 0.15 cm and damaged goods (favorite foods include seeds, cereals and insects trapped on glue boards).

Susanne Kuehne, Decernis
Food Fraud Quick Bites

In France, Appellation Matters, Not Just for Wine

By Susanne Kuehne
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Susanne Kuehne, Decernis
Food fraud, Decernis, Strawberries
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne

The 2013 horse meat and lasagna scandal, and the 2018 kiwi fraud issue are just some of the product traceability cases that are under public scrutiny in France. For the second time in France’s Lot-et-Garonne region, strawberries labeled French turned out to originate in Spain. Part of the harvesting labor was outsourced and was therefore more difficult to track. This makes it easier for mislabeling and food fraud to enter smaller-scale agricultural and agricultural cooperative businesses.

Resource

  1. Annick Berger (June 22, 2019). “Apres les faux kiwis, voici les fausses fraises francaises”. Capital.fr Retrieved from https://www.capital.fr/entreprises-marches/apres-les-faux-kiwis-voici-les-fausses-fraises-francaises-1342718