The Import Alert for FSVP noncompliance is applicable to any human and animal food subject to the FSVP regulation, and allows FDA to detain imported foods at the port of entry under the protocol for Detention Without Physical Examination (DWPE). DWPE is a standard enforcement tool for FDA.
July 31, 2019: FDA issued Import Alert #99-41, the first Import Alert based on noncompliance with the Foreign Supplier Verification Program (FSVP) regulation.
The FSVP Import Alert contains the following reason for the alert and the relevant charge.
Reason
“Section 805 of the FD&C Act (21 U.S.C. 384a) requires each importer of food to perform risk-based foreign supplier verification activities for the purpose of verifying that the food imported by the importer is produced in compliance with the requirements of section 418 (21 U.S.C. 350g) (regarding hazard analysis and risk-based preventive controls) or section 419 (21 U.S.C 350h)(regarding standards for produce safety) of the FD&C Act, as appropriate; and that the food is not adulterated under section 402 or misbranded under section 403(w).” – FDA
Charge
“The article is subject to refusal of admission pursuant to section 801(a)(3) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) in that it appears that the importer (as defined in section 805 of the FD&C Act) is in violation of section 805.” – FDA
Join Trish Wester for the closing plenary 2019 Food Safety Consortium panel discussion FDA Presentation on The Third-Party Certification Program | Thursday, October 3, 2019“Import alerts inform the FDA’s field staff and the public that the agency has enough evidence to allow for Detention Without Physical Examination (DWPE) of products that appear to be in violation of the FDA’s laws and regulations. These violations could be related to the product, manufacturer, shipper and/or other information,” states FDA on its webpage about import alerts.
A Trend of Increased Import Enforcement?
FDA enforcement actions in this area have recently seen a dramatic increase. Only one alert was posted in the first quarter, and less than 10 food-related alerts were posted prior to June. July 2019 saw eight food alerts, including one on radionuclides and the FSVP. FDA posted more than 30 food-related import alerts in August, and September is on a similar pace currently showing 21 food-related alerts, indicating this may be an ongoing focus for the agency.
The information in this update is provided by AFSAP, the Association for Food Safety Auditing Professionals. Please contact Patricia Wester @ trish@pawesta.com if you have any questions regarding DWPE, or to request a complete copy of the alert.
The microbiology lab will increasingly be understood as the gravitational center of big data in the food industry. Brands that understand how to leverage the data microbiology labs are producing in ever larger quantities will be in the best position to positively impact their bottom line—and even transform the lab from a cost center to a margin contributor.
The global rapid microbiology testing market continues to grow at a steady pace. The market is projected to reach $5.09 billion by 2023, up from $3.45 billion in 2018. Increased demand for food microbiology testing—and pathogen detection in particular—continues to drive the overall growth of this sector. The volume of food microbiology tests totaled 1.14 billion tests in 2016—up 15% from 2013. In 2018 that number is estimated to have risen to 1.3 billion tests, accounting for nearly half the overall volume of industrial microbiology tests performed worldwide.
The food industry is well aware that food safety testing programs are a necessary and worthwhile investment. Given the enormous human and financial costs of food recalls, a robust food safety testing system is the best insurance policy any food brand can buy.
We are going through a unique transition where food safety tests are evolving from binary tests to data engines that are capable of generating orders of magnitude of more information. This creates a unique opportunity where many applications for big data collected from routine pathogen testing can help go beyond stopping an outbreak. Paired with machine learning and other data platforms, these data have the opportunity to become valuable, actionable insights for the industry.
While some of these applications will have an impact on fundamental research, I expect that big data analytics and bioinformatics will have significant opportunity to push the utilities of these tests from being merely a diagnostic test to a vehicle for driving actions and offering recommendations. Two examples of such transformations include product development and environmental testing.
Food-Safety Testing Data and Product Development
Next-generation-sequencing (NGS) technologies demonstrate a great deal of potential for product development, particularly when it comes to better understanding shelf life and generating more accurate shelf-life estimates.
Storage conditions, packaging, pH, temperature, and water activity can influence food quality and shelf life among other factors. Shelf-life estimates, however, have traditionally been based on rudimentary statistical models incapable of accounting for the complexity of factors that impact food freshness, more specifically not being able to take into consideration the composition and quantity of all microbial communities present on any food sample. These limitations have long been recognized by food scientists and have led them to look for cost-effective alternatives.
By using NGS technologies, scientists can gain a more complete picture of the microbial composition of foods and how those microbial communities are influenced by intrinsic and extrinsic factors.
It’s unlikely that analyzing the microbiome of every food product or unit of product will ever be a cost-effective strategy. However, over time, as individual manufacturers and the industry as a whole analyze more and more samples and generate more data, we should be able to develop increasingly accurate predictive models. The data generation cost and logistics could be significantly streamlined if existing food safety tests evolve to broader vehicles that can create insights on both safety and quality indications of food product simultaneously. By comparing the observed (or expected) microbiome profile of a fresh product with the models we develop, we could greatly improve our estimates of a given product’s remaining shelf life.
This will open a number of new opportunities for food producers and consumers. Better shelf-life estimates will create efficiencies up and down the food supply chain. The impact on product development can hardly be underestimated. As we better understand the precise variables that impact food freshness for particular products, we can devise food production and packaging technologies that enhance food safety and food quality.
As our predictive models improve, an entire market for these models will emerge, much as it has in other industries that rely on machine learning models to draw predictive insights from big data.
Data Visualization for Environmental Monitoring
In the past one to two years, NGS technologies have matured to the point that they can now be leveraged for high-volume pathogen and environmental testing.
Just as it has in other industries, big data coupled with data visualization approaches can play a mainstream role in food safety and quality applications.
Data visualization techniques are not new to food safety programs and have proven particularly useful when analyzing the results of environmental testing. The full potential of data visualizations has yet to be realized, however. Visualizations can be used to better understand harborage sites, identifying patterns that need attention, and visualize how specific strains of a pathogen are migrating through a facility.
Some of this is happening in food production facilities already, but it’s important to note that visualizations are only as useful as the underlying data is accurate. That’s where technologies like NGS come in. NGS provides the option for deeper characterization of pathogenic microorganisms when needed (down to the strain). The depth of information from NGS platforms enables more reliable and detailed characterization of pathogenic strains compared to existing methods.
Beyond basic identification, there are other potential use cases for environmental mapping, including tracking pathogens as they move through the supply chain. It’s my prediction that as the food industry more broadly adopts NGS technologies that unify testing and bioinformatics in a single platform, data visualization techniques will rapidly advance, so long as we keep asking ourselves: What can the data teach us?
The Food Data Revolution and Market Consolidation
Unlike most PCR and immunoassay-based testing techniques, which in most cases can only generate binary answers, NGS platforms generate millions of data points for each sample for up to tens to hundreds of samples. As NGS technologies are adopted and the data we collect increases exponentially, the food safety system will become the data engine upon which new products and technologies are built.
Just as we have seen in any number of industries, companies with access to data and the means to make sense of it will be in the best position to capitalize on new revenue opportunities and economies of scale.
Companies that have adopted NGS technologies for food safety testing will have an obvious advantage in this emerging market. And they won’t have had to radically alter their business model to get there. They’ll be running the same robust programs they have long had in place, but collecting a much larger volume of data in doing so. Companies with a vision of how to best leverage this data will have the greatest edge.
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne.
A large recall was initiated by the Brazilian Ministry of Agriculture, Livestock and Food Supply for Brazilian olive oil unfit for human consumption, and retailers and traders are requested to report and pull faulty products off the shelves. Large fines will be issued for non-compliance. The fake olive oils are sold very cheaply, but may be a health hazard. An infrared analysis was made to check the composition of fatty acids, which uncovered the fraud.
Retired NFL player Rob Gronkowski, formerly of the New England Patriots, recently signed a deal with Abacus Health Products in Woonsocket, Rhode Island that includes buying a stake in the company and agreeing to promote its products. His decision reflects his belief that cannabidiol or “CBD” products made by the company under the brand CBDMEDIC can help others manage pain the way it has helped him.
Former world champion boxer Mike Tyson is developing a cannabis farm called “Cannabis Resort” for smokers and growers on his 40-acre land in California City. His company Tyson Holistic Holdings also owns Tyson Ranch, his own cannabis strain company and recently launched his CBD brand named CopperGel, which includes roll-on relief items.
Lifestyle maven Martha Stewart has entered into a deal with cannabis and CBD company Canopy Growth to be an adviser to the company. Her role will be to help it develop a new line of CBD-based products for both humans and animals.
Learn more about the direction of the cannabis industry at the 2019 Cannabis Quality Conference & Expo, which is co-located with the Food Safety Consortium Conference & Expo | October 1–3, 2019 | Schaumburg, IL The involvement of these and other celebrities in the emerging CBD industry signals an escalation in the evolution of cannabis as a legal consumer product. CBD products are sold today not only through licensed dispensaries and pharmacies, but also in specialty cafes, smoke shops, grocery stores and general retailers. This reflects the degree to which cannabis has become increasingly integrated into mainstream society.
Thirty-three states and the District of Columbia have legalized medical cannabis products, and 11 states plus D.C. have legalized cannabis for recreational use by adults. Affecting industries as diverse as cosmetics, food and beverage and pharmaceuticals, the exponentially expanding CBD market has generated analyses forecasting that the collective market for CBD sales in the United States will surpass $15–20 billion by 2025, according to the firms BDS Analytics, Arcview Market Research and Cowen & Co.
Legal Recreational Use of Cannabis: Alaska, California, Colorado, Illinois, Maine, Massachusetts, Michigan, Nevada, Oregon, Vermont and Washington, plus the District of Columbia
Illinois became the second most-populous state (after California) to legalize recreational marijuana in June
Vermont was the first state to legalize marijuana for recreational use through the legislative process. The state law allows for adults age 21 and over to grow and possess small amounts of cannabis. The sale of nonmedical cannabis is not allowed.
Yet, many government officials at the state and local levels, as well as industry members and consumers, justifiably question whether CBD products are legal. For example, in January 2019, New York City’s health department started prohibiting restaurants from adding any CBD supplement to food or drink, saying CBD was not approved by the federal government as a safe ingredient for human consumption. “The Health Department takes seriously its responsibility to protect New Yorkers’ health,” a spokeswoman said in a February 2019 email to media outlet CNBC. “Until cannabidiol (CBD) is deemed safe as a food additive, the Department is ordering restaurants not to offer products containing CBD.”
Is CBD legal in America? The answer is: “It’s complicated.”
The Details Behind CBD, Legalization and Marketing
CBD is the acronym for cannabidiol, a chemical compound found in cannabis plants—both hemp and marijuana. Unlike the chemical compound tetrahydrocannabinol (THC), which also is found in those plants, CBD does not induce a “high.”
The main difference between marijuana and hemp is the amount of THC in the plants. If the cannabis plant contains more than 0.3% of THC, federal law defines the plant as “marijuana.” Hemp is a cannabis plant with less than 0.3% of THC. While CBD produced from hemp often is sold as an oil, it actually is a chemical compound.
The Agricultural Improvement Act of 2018 (commonly known as the “2018 Farm Bill”) removed industrial hemp and hemp-derived CBD from Schedule 1 of the Controlled Substances Act. Thus, by legalizing the production of hemp, the 2018 Farm Bill removed hemp and hemp seeds from the schedule of Controlled Substances maintained by the federal Drug Enforcement Administration (DEA). That change effectively legalized hemp-derived CBD, which contains only trace amounts of THC, subject to federal agency health and safety regulations that govern all foods, beverages, supplements and other consumer products marketed in the United States. The new law also allows for increased research and product development of CBD extracted from hemp.
Not waiting for the regulators or scientists, enthusiastic entrepreneurs have produced extraordinary growth in the creation of markets for hemp CBD oil tinctures, topical creams, edibles, pet oil tinctures, vaping-liquids and a host of other consumer products purportedly containing CBD. The increase in CBD-related medical research, as well as the decreasing stigma surrounding CBD, has led to an industry boom, enticing celebrities and generating mass market growth for CBD products and sales.
According to predictive analysis and market research company Brightfield Group, $620 million worth of CBD products were sold last year in the United States. The same research team is projecting year-over-year CBD product sales growth in the United States of 706% in 2019 to reach approximately $5 billion, and sales of $23.7 billion by 2023.
Similarly, cannabis industry research firm BDS Analytics is predicting a compound annual growth rate of 49% by 2024 for all cannabis products across all distribution channels. The industry researchers also project that the CBD market, combined with other cannabis products, will create a total U.S. market of $45 billion for cannabinoids by 2024.
Another data group, New York-based Nielsen, estimates total sales of all legalized cannabis, which includes CBD products, reached $8 billion in the United States in 2018. According to Nielsen, U.S. cannabis sales should reach $41 billion by 2025, with marijuana products accounting for $35 billion, presuming 75% of the U.S. adult population has consistent access to legal marijuana by 2025.
In this context, there was only limited surprise in the marketplace when U.S. cannabis retailer Curaleaf Holdings Inc. disclosed in March 2019 that big-box retailer CVS Health Corp. will carry its line of CBD products. CVS, which is the largest drugstore chain by total sales in the United States, already has started to sell CBD products in eight states, including creams, sprays, roll-ons, lotions and salves.
Follow the link below to access page 2 of the article, which covers Regulatory Oversight and Emerging Enforcement.
Today FDA released the results of its yearly report on pesticide residues, and the good news is that of the 6504 samples taken, most of them were below EPA tolerance levels. As part of the Pesticide Residue Monitoring Program for FY 2017, FDA tested for 761 pesticides and industrial chemicals in domestic and imported foods for animals and humans. The following are some highlights of the FDA’s findings:
Percentage of foods compliant with federal standards
96.2% of domestic human foods
89.6% of imported human foods
98.8% domestic animal foods
94.4% imported animal foods
Percentage of food samples without pesticide residues
Milk and game meat: 100%
Shell egg: 87.5%
Honey: 77.3%
Percentage of food samples without glyphosate or glufosinate residues
Milk and eggs: 100%
Corn: 82.1%
Soybeans: 60%
“Ensuring the safety of the American food supply is a critical part of the work of the U.S. Food and Drug Administration. Our annual efforts to test both human and animal foods for pesticide residues in foods is important as we work to limit exposure to any pesticide residues that may be unsafe,” said Susan Mayne, Ph.D., director of FDA’s CFSAN, in an agency release. “We will continue to do this important monitoring work, taking action when appropriate, to help ensure our food supply remains among the safest in the world.”
“Gina and her teams have built two strong companies with outstanding reputations that come from providing a unique level of service to their customers,” said Robert Wiebe, CEO of Matrix Sciences, in a company press release. “This strategic investment adds to the scope and depth of our Advisory business and has real linkage to our other services. ” Gina (Nicholson) Kramer is the executive director of Savour Food Safety International and also a member of Food Safety Tech’s Editorial Advisory Board. She will continue to serve in the same role and said the acquisition will not change how Savour Food Safety does business. However, the deal will give the firm access to new services, including laboratory testing, process validation, environmental monitoring program assessments, and R&D and sensory testing. “Matrix Sciences is creating an unparalleled team of expert services to provide customers with resources of a large company while maintaining a very focused, personalized approach to service for every client,” said Kramer.
Matrix Sciences has operations nationwide to address the needs of food and beverage industries and has grown through acquisitions of Richter International and Neumann Risk Services as well.
A new report released by the University of Minnesota’s Food Protection and Defense Institute warns that the food industry is vulnerable to cyberattacks, suggesting that food companies need to beef up their security and IT systems. According to the report, “Adulterating More Than Food: The Cyber Risk to Food Processing and Manufacturing”, the systems that food companies use for processing and manufacturing could be the most vulnerable and as such, serve as an attractive target for an attack—especially as industries that are currently common targets improve their cybersecurity.
“The food industry has not been a target of costly cyberattacks like financial, energy, and health care companies have,” said Stephen Streng, lead author of the FPDI report, in a news release. “However, as companies in those sectors learn to harden their defenses, the attackers will begin looking for easier victims. This report can help food companies learn about what could be coming their way and how to begin protecting themselves.”
The report calls out that in 2011, researchers and manufacturers found more than 200 vulnerabilities in industrial control systems. In addition to the fact that these vulnerabilities are in many components from different vendors, many of these systems have obsolete operating systems and passwords that are easy to hack. Compounding this issue, “Companies often lack knowledge about how their industrial control systems and IT systems interact and lack awareness about cyber risks and threats,” the FPDI release notes.
And if you’re a small company, don’t think you’re immune, the report cautions. It cites that 74% of U.S. food manufacturers have fewer than 20 employees—yet software company Symantec Corp. points out that small companies have been targeted as often, or sometimes even more, than large companies.
How can food companies address this risk? The report recommends the following “critical” steps all companies should take:
Bridge the gap and facilitate more communication between OT (operational technology) and IT (information technology) personnel
Conduct risk assessments of inventory control systems and IT systems
Ensure that staff with the cybersecurity knowledge is involved in procuring and deploying inventory control system devices
Incorporate cybersecurity into your food safety and food defense culture.
According to the Food and Agriculture Organization of the United Nations, it is estimated that nearly one third of the food produced (about 1.3 billion tons) globally is not consumed. To help tackle this billion-dollar problem, an innovative solution is being deployed to detect one of the key factors driving food waste: Spoilage due to fluctuations in temperature.
To get to the dinner table, food must travel great lengths to preserve that farm fresh quality. Refrigerated shipping units and storage facilities are essential to reducing bacteria growth and by using an automated smart-refrigeration solution, a food-safe environment can be maintained throughout the journey with little supervision. Traditional food temperature monitoring is reliant on staff to periodically check temperature levels and make adjustments as necessary. This process is not scalable, meaning that with a larger facility or an increased number of food displays, it becomes increasingly labor intensive and inefficient. If employees are preoccupied, periodic check-ins may be delayed or missed entirely, leading to gaps where temperature fluctuations are not addressed, opening the door for increased bacteria growth and food waste.
LoRa devices and LoRaWAN protocol are being integrated into smart refrigeration solutions to fight food waste. Image courtesy of Semtech.
To solve this issue, Internet of Things (IoT) sensors can be deployed in shipping vehicles, displays, refrigerators, and storerooms to provide accurate and consistent monitoring of temperature data. When a temperature fluctuation occurs, the sensors will send a signal to a low power, wide area network (LPWAN) gateway application. The information is then relayed to a network server, where it is routed to application servers or Cloud IoT services. The data is then processed and sent to the end user through a desktop or smartphone application. What’s more, in the event of a power outage, these long range, low power wireless enabled IoT devices are battery powered and consume minimal energy, allowing for consistent off-grid temperature tracking.
These connected devices can be found globally in a variety of use cases ranging from quick service restaurants to full service grocery stores, with an end goal of ensuring appropriate temperature levels for food. To support connectivity for these devices, an open network protocol is used to ensure the devices can be scalable and globally deployed. Two recent use cases where the long range, low power wireless devices and LoRaWAN protocol were used to actively monitor temperature fluctuations are Axino Solutions (Axino) and ComplianceMate.
Axino recently integrated LoRa devices and LoRaWAN protocol into its line of smart refrigeration solutions with the goal of combatting food waste. The solution combines sensor technology with automated data communication providing a substantial increase in measurement quantity and quality. Additionally, stores found a significant reduction in metering and operating costs after sensor deployment. This smart refrigeration solution has been globally deployed and is currently used by Switzerland’s largest supermarket chain, Migos. Axino’s sensors can be quickly installed, utilizing a magnet to attach to a refrigerator’s infrastructure. The sensors monitor temperature in real time, are accurate to one degree Celsius and can be pre-programmed to adjust refrigerator temperatures to ensure that food is stored in a safe environment. By having access to real time data and automatic temperature adjustment, supermarkets were able to eliminate human error, prolong shelf life and pass energy savings off to the customers.
The challenge for any wirelessly connected device is the presence of physical barriers that will block signals. Steel doors, concrete and insulation are some of the key considerations when developing a smart solution, especially in restaurants using large freezers. ComplianceMate partnered with Laird Connectivity and found that devices on a LoRaWAN-based network produces a more reliable signal than its Bluetooth counterpart. This IoT solution has been deployed in some of your favorite restaurant chains such as Shake Shack, Five Guys, Hard Rock Café, City Barbeque, and Hattie B’s and has already proved to be a huge asset. For instance, a sensor deployment saved $35,000 to $50,000 worth of inventory in a Hattie B’s location when downtown Nashville experienced a sudden power outage in 2018. The LoRa-based alert system immediately notified store management, allowing them to act quickly and prevent food spoilage.
Reducing global food spoilage is a monumental task. From farms to grocery stores and restaurants, technology must play a critical role, ensuring food remains at a safe temperature, preventing unnecessary spoilage. In the era of connectivity, businesses will turn to LoRa-based IoT deployments for its flexibility, durability and ability to provide real-time information to employees and decision makers to not only maintain strict industry standards in food safety, but to also pass savings on to their valued customers.
Food is no longer a commodity. With an increase in special interest consumer groups, it’s taking on a more nuanced character. Consumers are increasingly seeking out specific attributes for their food. Whether the focus is on organic and natural, foods with superior eating quality, or simply a better price—consumers are more discerning than ever.
Their expectations around transparency and authenticity are growing as well.
According to Food Marketing Institute research, nearly 93% of consumers are more likely to be loyal to a brand when it commits to full transparency. Transparency and traceability go hand in hand. In a study conducted by SMS Research, traceability was at least somewhat important to 75% of participants and very important to 45%.* Animal welfare emerged as a contributing factor with 75% of consumers claiming they would be at least somewhat more likely to buy beef if they knew about the animal’s living conditions.
These are useful insights but challenging to make fully actionable in our commodity-focused infrastructure that’s simply not built for the nuance of our new reality. Successful companies will design a supply chain within the existing infrastructure and industry capabilities that meets customers’ unique needs and desired attributes.
Two major retailers are developing their own supply chains to control quality. Last year, Costco announced it is bringing chicken production in-house, largely driven by its rotisserie program, to ensure size specifications are met. In April, Walmart announced it is developing an end-to-end supply chain for Angus beef. Companies like Tyson are upgrading some of their supply chains with improved traceability systems using DNA technology. The use of this technology was pioneered in North America a decade ago in partnership with IdentiGEN, a global expert identifying and tracing food products with greater precision and accuracy.
Leveraging DNA Technology
DNA traceability was first developed nearly 20 years ago in Ireland by IdentiGEN to protect market access for Irish beef. The technology can serve as the backbone for a comprehensive set of origin, handling and processing practices that work together to guarantee quality. Beyond genetics, a company’s quality improvement program should consider standards for feeding, animal health, humane treatment, environmental impact and the processing of the animal. DNA technology can help uphold these standards throughout the supply chain, providing a cost-effective way of tracking product and establishing meaningful accountability.
Here’s how the technology works. At the slaughterhouse, a DNA sample is taken from the animal, and the ear tag is then scanned to create a digital link. With this information, the origin and handling of product throughout the supply chain is verifiable, even after disassembly and packing. From a safety standpoint, the technology can support recall mitigation efforts, allowing for swift and specific identification of the animals involved, helping protect consumers and limiting financial damages.
To create the most effective supply chain, companies should still supplement DNA testing with time-tested initiatives for quality improvement, such as customer feedback mechanisms and facility audits conducted both by internal groups as well as external partners and USDA-approved auditing companies. The data collected should not be siloed but rather correlated in some capacity to create a holistic view of all supply sources and the quality they deliver.
Building a Foundation for Success
There are many elements beyond technology that come together to make traceability and quality initiatives successful. One is a company’s big-picture, strategic view. It helps to look at these programs and systems as supporting an evolving process. Continuous improvement means creating and refining the right mix of methodologies, partners and technology—it’s about evaluating and eliminating anything that no longer adds value. Some companies have banned electric cattle prods, for example, because they cause stress on the animal that negatively impacts quality. As standards continue to strengthen and the supply chain is better organized, everything works together more cohesively, and it becomes easier to continue updating and adding new elements.
The foundation for any initiative of this type must be built on a shared vision, strategy and end goals, starting at the organizational level, and then with external partners. A supply chain should be organized for better production, but it also should be organized for mutual benefit, recognizing that everyone has different goals and interests. Structure your economic models so that every link in the supply chain is pulling in the same direction. Participating in the supply chain should mean doing at least a little bit better, however each partner defines it—enhanced financial performance, higher quality, lower shrinkage or improved safety and compliance. Farmers and packers will be willing to participate in the systems—and use tools like DNA technology—if they gain insights that help them achieve their goals, sell more product and improve their bottom line. It’s all about building a system that works for everyone involved.
Consumer demand for foods that offer greater choice and a wider variety of attributes will only continue to grow. Companies can successfully mature brands through a customized supply chain grounded in increased accountability and traceability. The potential to re-engineer supply chains and meet customer needs more effectively exists across many different product categories and attributes. It’s a valuable opportunity many companies may find well worth exploring.
* The survey was conducted by SMS Research on behalf of PFG among a sample of 2,001 general consumers in the U.S., weighted to census. This survey was live on March 28 – April 1st, 2019. All statistical tests were performed at a 5% risk level. PFG had no role in survey design, data collection, data analysis or data interpretation.
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).*
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.
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In other cases, our advertisers request to use third-party tracking to verify our ad delivery, or to remarket their products and/or services to you on other websites. You may opt-out of these tracking pixels by adjusting the Do Not Track settings in your browser, or by visiting the Network Advertising Initiative Opt Out page.
You have control over whether, how, and when cookies and other tracking technologies are installed on your devices. Although each browser is different, most browsers enable their users to access and edit their cookie preferences in their browser settings. The rejection or disabling of some cookies may impact certain features of the site or to cause some of the website’s services not to function properly.
Individuals may opt-out of 3rd Party Cookies used on IPC websites by adjusting your cookie preferences through this Cookie Preferences tool, or by setting web browser settings to refuse cookies and similar tracking mechanisms. Please note that web browsers operate using different identifiers. As such, you must adjust your settings in each web browser and for each computer or device on which you would like to opt-out on. Further, if you simply delete your cookies, you will need to remove cookies from your device after every visit to the websites. You may download a browser plugin that will help you maintain your opt-out choices by visiting www.aboutads.info/pmc. You may block cookies entirely by disabling cookie use in your browser or by setting your browser to ask for your permission before setting a cookie. Blocking cookies entirely may cause some websites to work incorrectly or less effectively.
The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block all cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here.
