Tea adulteration is a very common and recurring issue. Indian Officials, such as the Food Safety and Standards Authority of India (FSSAI), keep seizing teas adulterated with artificial colorants and dyes. Tea dust and low-quality teas are adulterated by adding coal tar dyes, sunset yellow, tartrazine and other artificial colorants, some of them rendering the teas unfit for human consumption and endangering consumer health.
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).*
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.
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.
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
Organized crime in Europe has found a new money making machine by engaging in food fraud, which often goes undetected and is relatively low risk compared to other criminal activities. Opson, an Europol-Interpol joint operation, confiscated 16,000 tons of fake food items and 33 million liters of fraudulent beverages in 2018, a new record, but also probably just the tip of the iceberg. Government agencies do not have the resources to detect all fraudulent activities, and suspected food fraud cases moving through the federal and local government hierarchies is a long and cumbersome process.
Food safety and food labeling are strictly regulated in Canada and therefore, honey adulterated with sugars labeled as genuine is considered fraudulent. The Canadian Food Inspection Agency (CFIA) investigated Canadian honey samples from various sources within the supply chain, such as importers, blenders, retailers and more. Almost 22% of imported samples were adulterated with added sugars, the domestic (Canadian) samples showed no adulterations. The CFIA will continue monitoring honey imports and take measures to avoid fraudulent products entering the Canadian market.
Pentobarbital-adulterated products were distributed to pet food manufacturers by a company in spite of receiving a formal notification letter from the FDA. Even a trace amount of this drug makes pet food “adulterated” according to the FDA; in this case the levels of the drug found were quite high. The affected company undertook some corrective measures but was unable to avoid the contamination. However, the company is now supposed to notify the FDA about specific steps regarding sufficient corrective actions within 15 days of receiving the warning letter.
Fresh beef adulterated with sulphur dioxide was found in a Hong Kong market by the Centre of Food Safety. The adulteration of fresh or chilled meat with sulphur dioxide carries hefty penalties of fines and even prison time. Sulphur dioxide is a widely used preservative and antioxidant for foods and beverages that include dried fruits, processed meat products such as sausages, soft drinks and alcoholic beverages. The substance is harmless to healthy persons, however, in subjects with a sulphur dioxide allergy, breathing difficulties and asthma can be induced.
Centre for Food Safety (April 10, 2019). “Fresh beef sample found to contain sulphur dioxide” Centre for Food Safety, The Government of the Hong Kong Special Administrative Region. Accessed April 10, 2019. Retrieved from https://www.cfs.gov.hk/english/press/20190410_7408.html
I attended the Safe Food California Conference last week in Monterey, California. Food fraud was not the main focus of the conference, but there was some good food fraud-related content. Craig Wilson gave a plenary session about the past, present and future of food safety at Costco. As part of that presentation, he discussed their supplier ingredient program. This program was implemented in response to the 2008 Salmonella Typhimurium outbreak in peanut paste but has direct applicability to food fraud prevention.
Food Fraud: Problem Solved? Learn more at the 2019 Food Safety Supply Chain Conference | May 29–30, 2019 | Attend in Rockville, MD or virtually Jeanette Litschewski from SQFI gave a breakout presentation on the most common SQF non-conformities in 2018. She presented data from 7,710 closed audits that cited 44,439 non-conformities. Of those, 756 were related to food fraud requirements. While this presentation was not focused on the specifics of the food fraud non-conformities, Jeanette did mention that many of them were related to broad issues such as not having completed a food fraud vulnerability assessment or appropriately documenting that each of the required factors was addressed in an assessment.
I was invited to give a breakout presentation with an overview of food fraud issues globally and a brief outline of some of the tools currently available to assist with conducting vulnerability assessments. Although many of the attendees had already began implementation of food fraud measures, there was a lot of interest in this list of tools and resources. Therefore, I am recreating the list in Table I. The focus is on resources that are either complimentary or affordable for small- and medium-sized businesses, with recognition that “full-service” and tailored consulting services are always an option.
Of course, there are quite a few companies that offer tailored tools, training and consulting services. Companies that offer courses in food fraud mitigation and assistance in creating a vulnerability assessment (or FDA-required food safety plan) include NSF, Eurofins, AIB International, SGS, and The Acheson Group.
Also available are services that compile food safety recalls and alerts (including those resulting from food fraud) from multiple official sources, such as FoodAKAI and HorizonScan. EMAlert is a proprietary tool that merges public information with user judgment to inform food fraud vulnerability. Horizon Scanning is a system that can monitor emerging issues, including food fraud, globally.
In short, there are many resources available to help support your food fraud vulnerability assessments and mitigation plans. If I have unintentionally missed mentioning any resources you have found to be helpful, please let us know in the comments.
Laboratory reports recently acquired by the Freedom of Information Law from the New York State Department of Agriculture and Markets show the Sol Andino brand ground cumin to contain 1090 ppm lead as well as 259 ppm chromium. The spice was also analyzed by IS:2446, 1980 method, “Detection of Lead Chromate in Chillies, Curry Powder and Turmeric by diphenyl carbizide.” A positive result was given, indicating the presence of hexavalent chromium, which is a component of lead chromate. Lead chromate is a yellow pigment, not allowed in food anywhere in the world as it is toxic, containing both lead and hexavalent chromium. The New York State Department of Agriculture and Markets posted a Class I recall of the Sol Andino ground cumin on July 10, 2017, without mention of the extremely high concentration of lead in the product.
The author could find no record of an FDA recall for the Sol Andino brand cumin powder containing excessive lead.
Some of us remember the four FDA Class I recalls of Pran brand turmeric for excessive lead in October 2013. These recalls were initiated by the New York State Health Department due to an illness complaint—most likely a child with high blood lead levels. The recalled Pran brand turmeric contained 28–53 ppm lead.
“There have been two cases of high blood levels of lead associated with this product to date. Both cases have been reported through the Illinois Department of Public Health, Environmental Health Protection.”
According to the recall, the “Thyme” was found to contain 422 ppm lead.
Wondering if the 422 ppm lead was caused by adulteration of the “Thyme” with lead chromate or another lead pigment, a food chemist at the New York State Food Laboratory (a Division of NYS Dept. of Agriculture and Markets) requested from Illinois a sub-sample of the “Thyme” for analysis. Lab analysis of the spice found 323 ppm lead, 109 ppm chromium and a positive result for the chromate test. Thus, this recalled “Thyme” contains lead chromate.
In both cases, Pran turmeric and Nabelsi Thyme, illness complaints led to the recall of lead adulterated spices.
The New York State Department of Agriculture and Markets has a proactive program. Random samples of spices are sampled from retail markets and subsequently analyzed for unallowed colorants, undeclared allergens and heavy metals. In 2016 this resulted in the Oriental Packing Class I recall of 377,000 lb. of turmeric containing spices for excessive lead. (A typo in the FDA recall attributes the recall to the New York State Health Department, instead of the New York State Dept. of Agriculture and Markets.)
Still, it’s even better to analyze spices being imported into the country at receiving warehouses before the product reaches retail markets. Lead concentrations above 10 ppm can be determined instantaneously with a handheld XRF analyzer.
Food fraud is a recognized threat to the quality of food ingredients and finished food products. There are also instances where food fraud presents a safety risk to consumers, such as when perpetrators add hazardous substances to foods (e.g., melamine in milk, industrial dyes in spices, known allergens, etc.).
The tables in Appendix 1 include 17 food categories and are presented in three series:
Information that you should consider for potential food-related biological hazards
Information that you should consider for potential food-related chemical hazards
Information that you should consider for potential process-related hazards
According to the FDA draft guidance, chemical hazards can include undeclared allergens, drug residues, heavy metals, industrial chemicals, mycotoxins/natural toxins, pesticides, unapproved colors and additives, and radiological hazards.
USP develops tools and resources that help ensure the quality and authenticity of food ingredients and, by extension, manufactured food products. More importantly, however, these same resources can help ensure the safety of food products by reducing the risk of fraudulent adulteration with hazardous substances.
Data from food fraud records from sources such as USP’s Food Fraud Database (USP FFD) contain important information related to potential chemical hazards and should be incorporated into manufacturers’ hazard analyses. USP FFD currently has data directly related to the identification of six of the chemical hazards identified by FDA: Undeclared allergens, drug residues, heavy metals, industrial chemicals, pesticides, and unapproved colors and additives. The following are some examples of information found in food fraud records for these chemical hazards.
Undeclared allergens: In addition to the widely publicized incident of peanuts in cumin, peanut products can be fraudulently added to a variety of food ingredients, including ground hazelnuts, olive oils, ground almonds, and milk powder. There have also been reports of the presence of cow’s milk protein in coconut-based beverages.
Drug residues:Seafood and honey have repeatedly been fraudulently adulterated with antibiotics that are not permitted for use in foods. Recently, beef pet food adulterated with pentobarbital was recalled in the United States.
Heavy metals:Lead, often in the form of lead chromate or lead oxide which add color to spices, is a persistent problem in the industry, particularly with turmeric.
Industrial Chemicals: Industrial dyes have been associated with a variety of food products, including palm oil, chili powder, curry sauce, and soft drinks. Melamine was added to both milk and wheat gluten to fraudulently increase the apparent protein content and industrial grade soybean oil sold as food-grade oil caused the deaths of thousands of turkeys.
Pesticides: Fraud in organic labeling has been in the news recently. Also concerning is the detection of illegal pesticides in foods such as oregano due to fraudulent substitution with myrtle or olive leaves.
Unapproved colors/additives: Examples include undeclared sulfites in unrefined cane sugar and ginger, food dyes in wine, and tartrazine (Yellow No. 5) in tea powder.
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