Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne
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.
On Friday FDA released another update to its investigation of the Salmonella Infantis outbreak linked to Del Monte vegetable trays. The agency has been unable to find a single source or contamination point for the outbreak, but it also states that it’s not likely that these trays are either on store shelves or in consumers’ homes. The illness cases have been isolated to five people in Minnesota and Wisconsin, with the last illness onset reported on May 15. No hospitalizations or deaths have been reported.
The 2019 Food Safety Consortium Conference & Expo kicks off on Tuesday, October 1 and is packed with two-and-a-half days of informative sessions on a variety of topics that are critical to the food safety industry. We invite you to check out the full agenda on the event website, but below are several event highlights that you should plan on attending.
Opening Keynote: Frank Yiannas, Deputy Commissioner for Food Policy and Response, FDA
Recalls Panel Discussion: Led by Rob Mommsen, Director of Global Quality & Food Safety, Sabra Dipping Company
Food Defense Panel: Led by Steven Sklare, REHS, CP-FS, LEHP. Invited Panelists include Jason P. Bashura, MPH, RS, Sr. Mgr., Global Food Defense, PepsiCo and Jill Hoffman, Director, Global Quality Systems and Food Safety at McCormick & Company and Clint Fairow, M.S. Global Food Defense Manager, Archer Daniels Midland Company
“Validation Considerations and Regulations for Processing Technologies”: General Session presented by Glenn Black, Ph.D., Associate Director for Research, Division of Food Processing Science and Technology (DFPST), Office of Food Safety (OFS), CFSAN, FDA
“Food Safety Leadership: Earning respect – real-life examples of earning and maintaining influence as a Food Safety leader”: Panel Discussion moderated by Bob Pudlock, President, Gulf Stream Search
Supply Chain Transparency Panel Discussion: Led by Jeanne Duckett of Avery Dennison
Taking an Aggressive Approach to Sanitation: Planning for a Contamination Event: Presented by Elise Forward, President, Forward Food Safety
Three Breakout Tracks: Food Safety Leadership; Food Testing & Analysis and Sanitation and Operations
Register by September 13, 2019 for a special discount!
Watch this video from when Frank Yiannas was the vice president of food safety at Walmart. He presented at the 2015 Food Safety Consortium.
Watch this video of Steven Sklare speaking with Aaron Biros of Cannabis Industry Journal at the 2017 Food Safety Consortium.
In a recent exclusive column on Food Safety Tech, Laura Lombard, CEO of ImEPIK, discusses why food companies should be investing in PCQI training beyond basic FSMA requirements. During the following Q&A, she expands on these insights further to shed light on some of the misunderstandings companies have when it comes to the PCQI requirements under FSMA as well as tips for how to approach PCQI training itself.
Food Safety Tech: What are some of the misconceptions with the FSMA PCQI requirements?
Laura Lombard: The FSMA rule allows for alternate PCQI training in addition to the original FSPCA training. PCQI trainings are accepted as long as they meet the standardized curriculum recognized by the FDA. The FDA never intended that one organization have a monopoly over PCQI training but equally wants to ensure that core competencies in preventive controls are met.
The FSMA regulation does not require you to have a different PCQI per facility. However, it does require a PCQI to be in charge of an individual food safety plan per location. Depending on how many facilities your particular company has, you may want to consider more than one PCQI to oversee these different food safety plans to ensure that food safety plans are regularly updated and properly implemented.
FST: How should food companies be investing in PCQI training beyond the basic FSMA requirements?
Lombard: It’s very important to have at least one back up PCQI in place to ensure you are always covered if your head PCQI is out sick, on family leave, departs from the company, etc. This isn’t only to meet the FDA requirement of having a PCQI on your team, but also to ensure you are keeping your brand, product, and customers safe. The more you can protect yourself from having to do a recall of your product, the better. Recalls cost an average of $10 million, and this does not including damage to your brand and customer retention.
ImEpik and Food Safety Tech have partnered to offer PCQI online training, with special pricing options for attendees of the 2019 Food Safety Consortium Conference & Expo | Learn moreFST: What are your top tips for companies regarding PCQI training?
Lombard: Be proactive in ensuring your employees are trained. The regulation is the minimum required, but for a small investment, you can ensure more of your food safety staff is current on best practices to ensure your products’ quality and safety.
Look for training that fits your individual or company needs and learning styles. Look for training that is interactive and going to test knowledge rather than just death by PowerPoint. Again, the goal shouldn’t be to check a regulatory box but to ensure that your staff has the knowledge needed to maintain your brands quality, reputation and customer base.
FST: What are some of the differences between the various PCQI trainings on the market?
Lombard: There are three types of trainings that all require 20-hours of content: 1) An in-person version where an instructor leads a 2 or 2.5 day training, 2) a blended-online version that has some content that is self-paced but also requires a set time and date for a webinar portion, and 3) a 100% self-paced online course that does not require a webinar. Some of the blended versions claim to be 100% online. It is true in the sense that both the self-paced content and webinar are computer-based, but it is not as convenient as being able to do the entire training on your schedule. All versions have their pros and cons, but doing the course online can save your company significant time and money by not requiring travel or set timeframes. We have learned that online versions allow learners more opportunity for mastering the material through regular assessments and remediation as needed. It is also an opportunity to practice knowledge through scenarios in a low-risk environment. Lastly, done correctly, online training can be more interactive through the use of games, videos and audio tools to keep learners engaged.
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne
An organized crime group produced and traded rotten and adulterated apple products labeled as organic. The food and beverage items, which were not suitable for human consumption, were worth several million Euros. A transnational investigation, coordinated by Eurojust, led to several arrests in Italy and Serbia and the confiscation of millions worth of illegal assets.
Resource
Ton van Lierop. (July 1, 2019). “Eurojust helps reveal fake organic food fraud”. Eurojust, the European Union’s Judicial Cooperation Unit. Retrieved from http://www.eurojust.europa.eu/press/PressReleases/Pages/2019/2019-07-01.aspx
I recently attended two webinars that highlighted distinct perspectives on two challenging aspects of food fraud prevention. First, Chris Elliott from Queen’s University Belfast discussed the current situation with meat fraud. He cited his “top three” fraud-prone foods as meat, olive oil and honey. While we cannot determine the true scope of food fraud globally, looking at the data we have collected from the past 10 years, meat is also in our “top three.”
Top 10 Commodity Groups. Source: Decernis Food Fraud Database
Meat is prone to fraud in many ways, including misrepresenting the animal species, fraudulent labeling of production practices (organic, kosher, halal, etc.), the use of unapproved additives, the addition of non-meat-based protein ingredients, and misrepresentation of geographic origin (among others).
Elliott discussed some of the reasons that meat is prone to fraud, which included the fact that the industry is highly competitive, relies on low profit margins, and the supply network can be complex. Discussing specifically the horsemeat scandal in Europe a few years ago, he cited the “mess of subcontracts” involved in the adulterated meat, which were based primarily on price. He finished his presentation by noting that certain aspects of meat authentication are still challenging from an analytical perspective, such as ensuring country of origin and verifying the claims about animal feed consumption.
The final in a series of food fraud webinars sponsored by the IAFP Food Fraud Professional Development Group (PDG) focused on another aspect of food fraud: E-commerce. One of the big challenges with food fraud is the intentional nature of the crime, which can make anticipation of adulterants and fraud methods difficult.
GFSI has stated “any plans and activities to mitigate, prevent or even understand the risks associated with food fraud should consider an entire company’s activities, including some that may not be within the traditional food safety or even HACCP scope, applying methods closer to criminal investigation.” This is particularly true for fraud involving intellectual property (IP) infringement, which adds another layer of complexity to detection and prevention strategies. We have more than 200 records documenting fraud involving “counterfeit” products. Counterfeit products are a problem both because of the IP infringement and because, often, the actual contents of the product cannot be verified. Many of the records we have documented involve counterfeit vodka, whiskey, and wine, as well as non-alcoholic soft drinks.
As part of the IAFP webinar, Axel Hein from ApiraSol discussed their work using global customs data to detect counterfeit products, so-called “fantasy trademarks,” and geographical indication infringements.
Many countries provide public access to customs data which, when aggregated and combined with other sources (such as Alibaba transactions), allows mapping of supply chains and detection of unusual patterns that may indicate fraud. In school, I spent many months digging through U.S. customs data trying to uncover patterns that might indicate fraud, so I was very interested to see this being done on a larger scale.
Although each webinar was distinct in its focus, each highlighted the importance of supply chain control and monitoring in mitigating food fraud risk. To paraphrase a point made by Elliott, each arrow in a supply network is a potential vulnerability. The continued globalization of the food supply requires new and innovative ways to reduce these supply chain vulnerabilities.
Despite manufacturers’ best intentions to provide safe products for consumers, notifications about recalled products appear in news headlines with increasing regularity. The CDC reports that each year, 48 million Americans experience foodborne illnesses, resulting in a reported 128,000 hospitalizations and 3,000 deaths. Behind these statistics are recall trends that can lead to operational and financial instability, and a loss of reputation for companies in the marketplace. Proactive measures and tools adopted by experienced food and beverage manufacturers can help mitigate the potentially harmful effects of these product recalls by establishing preparedness initiatives.
Recall Essential Facts
A recall is defined as a request for the return of a product from the market due to a defect or safety concern resulting from a variety of issues including improper labeling or contamination, which places the manufacturer at risk of legal action. Product recalls can be issued by either the manufacturer or a governmental agency, but it is the sole responsibility of the company to properly recall and notify consumers of unsafe products. Recalls are categorized as either voluntary or mandatory, with the majority falling under the voluntary classification. In the case of a voluntary recall, a manufacturer has greater control over the process with less stringent procedures, review and paperwork. While both have the same potential for negative effects and significant legal costs, a voluntary recall is preferred by manufacturers. Implementing an industry-specific ERP solution with a documented recall preparedness plan and mock recall capabilities provide the necessary tools for either scenario, as recalls are inevitable in today’s manufacturing environment.
Recall Trends
In the USDA- and FDA-regulated markets, comparatively, there have been a slightly higher number of recall incidents in the beginning months of 2019 versus 2018. Mispackaging is identified as one of the primary recall issues, involving packaging a finished good into the wrong container. Another trending recall cause involves not properly identifying an ingredient on the packaging label. Both of these manufacturing errors resulted in the labels not providing an accurate reflection of the product, which could be potentially harmful to consumers if the undeclared ingredient(s) include one of the common allergens. Well-documented and properly executed internal manufacturing processes, in addition to an automated ERP solution, create checks and balances and assist in generating accurate, compliant packaging and nutrition fact panels to meet the requirements of consumers and regulatory bodies.
A third recall trend of 2019 is being driven by consumer complaints in regards to foreign materials such as metal fragments, plastics or rubber pieces in finished goods. This is caused by incomplete testing, lack of or faulty material detection equipment, including metal detectors, x-rays and other devices used during manufacturing. Due to an increasing number of these types of incidents, the USDA has issued a guidance document requiring manufacturers to maintain updated documentation of their internal procedures in their hazard analysis and critical control point (HACCP) plan. This guidance necessitates follow up with federal inspectors regarding any adjustments made to the plan. HACCP information recorded within an ERP solution helps to identify and control potential hazards before food safety is compromised—providing quality, consistent and safe consumables for the public.
Progress towards fewer FDA food and beverage recalls continues due to an increase in FDA inspections as well as manufacturers’ success in proactive measures to stay abreast of FDA requirements. However, bacterial pathogenic concerns including Listeria, Salmonella and E. coli continue to be prevalent recall culprits. This has resulted in the FDA utilizing the Whole Genome Sequencing (WGS) Program in an attempt to protect consumers from foodborne illness. By swabbing manufacturing environments and sending samples to WGS, the DNA strains are documented in a centralized public database—holding manufacturer’s accountable for processing and sanitation control. When an outbreak occurs, the database is able to locate possible matches that help health officials identify the source of contamination, and stop outbreaks more quickly, thereby avoiding additional widespread illnesses. As the database grows in size, so will the speed of investigations to determine the root causes of illnesses. This program has the potential to not only stop outbreaks from spreading but also includes proactive applications for increasing the safety of the food and beverage industry as a whole.
ERP’s Role in Recall Preparedness
An industry-specific ERP’s real-time forward and backward lot traceability, detailed record keeping, allergen/attribute tracking and efficient, documented processes support end-to-end recall management functionality to maintain compliance. With preventative measures such as establishing supplier relationships, conducting quality control testing and documenting quarantine procedures, an ERP solution works to identify gaps and prevent future recalls. Accurate product labeling is one of the key factors of recall prevention and food and beverage ERP software handles the intricacies of packaging and label creation, such as ingredient and allergen statements, nutrient analysis, expiration dates and lot and batch numbers—creating an audit trail that allows items to be located promptly in the event of a recall. As part of a sound food safety plan, mock recalls conducted regularly encourages familiarity with internal recall processes, as well as allows for adjustments to be made as needed. With a comprehensive ERP to generate lot tracking reports, manufacturers are able to identify and locate contaminated products in order to notify clients, vendors, consumers and government agencies quickly in the event of a recall—helping to minimize harmful effects in the marketplace as well as legal action.
The trends identified in recent recalls issued by the FDA and the USDA, thus far in 2019, demonstrate that manufacturers need to be proactive in how they respond in order to mitigate the detrimental effects that recalls can have on companies and to public health. With the increasing scrutiny from the FDA and USDA, along with an aware consumer base, it’s important for forward-thinking businesses to address the eventuality of a product recall with sound food safety and HACCP plans and an industry-focused ERP software solution that promotes, supports and helps manage preparedness and responsive action, if needed.
Register for the complimentary webinar: Pest Management, Accountability and Food Safety: How to Get the Best from Your Service Provider | September 10, 2019 | 12 pm ETRodents are intelligent creatures. Luckily, no matter how smart they get, their goals remain the same. Like any animal, rodents are primarily after three things: Food, water and harborage. When going about your day-to-day activities, it is important to assess your facility with these three things in mind. Consider how conducive your facility is to rodents in each of the following related areas.
Easily accessible raw food waste: If food is available and unprotected, rodents can feed off of the raw food waste and populations can grow. Ensure any stored food sources are sealed and inaccessible, minimize exposed food as much as possible and attend to spills and standing water immediately.
Clutter and inaccessible areas: Rodents look for undisturbed areas where their populations can grow. In a rodent-infested grocery store in Chicago, rodents were found in the wall voids, gaps inside shelves and in quarter-sized (or larger) cracks in concrete floor underneath pallets of food. Recessed areas, traps and pits under heavy-duty industrial equipment are also places where rodents like to nest.
Easy access: Gaps underneath door sweeps, exterior facing doors that close slowly, propped open doors, gaps in walls, cracks, utility access ports that enter the building are all attractive to a rodent seeking shelter.
Foliage that touches the building: Tree branches that extend over the roof of a building can act as perfect pathway for mice to run across and jump into the top of the building (ants can trail from branches that touch buildings too, so this isn’t limited to mice).
Building proximity to rodent habitats: If your facility is close to open fields, dense foliage, brush or other places with lots of insects, chances are high you have some rodent neighbors. It’s important to be particularly vigilant, especially during fall and winter because as the temperature drops, rodents look for shelter.
Global food supply chains offer consumers more choice than ever before. Thanks to international networks of producers, wholesalers, manufacturers and suppliers, many ingredients can be sourced all year round, meaning diets are no longer limited by what’s in season. However, the increasing complexity of these supply chains means many food and beverage products are potentially more exposed to biological and chemical contamination as well as food fraud issues, putting brand reputation and human health at risk.
With consumer trust and public safety of paramount importance, global food regulators have introduced strict rules to protect the quality and authenticity of products. Regulations such as the FDA’s Food Protection Plan, for example, seek to incorporate safety measures throughout food supply chains in order to better prevent and respond to potential issues.1 These regulations are complemented by standards such as the ISO’s recently updated ISO 22000:2018 guidelines that recommend the implementation of hazard analysis and critical control points (HACCP) to achieve the highest levels of quality control (QC).2 For businesses working within this regulatory framework, it is essential to take a coordinated approach to deliver the standards of food quality and safety that customers and regulators expect.
Every food supply chain will have its own set of product specifications and QC parameters. However, all these requirements demand that decisions on the release of goods are made using accurate and timely information. Given the growing attention from regulators on the safety and provenance of food, as well as the need for operations to run as efficiently as possible, supply chain stakeholders are reevaluating the digital platforms they use to manage, store and recall their data. Here, we consider how laboratory information management systems (LIMS) can help businesses integrate efficient data collection workflows across multiple locations to support robust QC testing and build regulatory compliance into their operations.
Meeting the Challenges Facing Modern Food Supply Chains
Assuring consistent product quality and safety is a constant challenge for food supply chain businesses, given the broad range of issues that can compromise these standards. Although most businesses adopt strict storage and handling protocols to minimize the risk of foodborne illnesses caused by bacterial contamination, high-profile public health stories regularly hit the headlines. The widespread use of pesticides and veterinary drugs in farming also means that ingredients are potentially exposed to a wide range of known and unknown chemical contaminants. Contamination can also occur during the handling, processing and packaging stages. Robust QC measures are therefore essential to identify issues as early as possible.
Equally, food adulteration and counterfeiting continue to be key challenges, with high-value products regularly targeted by food fraudsters. The Grocery Manufacturers Association estimates that up to 10% of all commercially sold food products are affected by these practices, costing the industry between $10 and $15 billion each year and putting public health at risk.3 Comprehensive QC testing, supported by robust chain of custody data, is required to demonstrate quality and authenticity of goods, protect brands and safeguard consumers.
However, the extended nature of modern food supply chains can make delivering against these goals more difficult, especially if poorly integrated information management approaches are employed. As food supply chains have gone global, it has become increasingly common for businesses to operate storage, production and processing facilities across sites in multiple regions, countries and even continents. To deliver goods that meet well-defined safety and quality specifications, QC workflows must be built upon standardized protocols that are implemented correctly across the supply chain, regardless of the individual following them or the location in which they operate. These workflows must be supported by robust information exchange mechanisms that make sure the right decisions around product manufacturing and batch release can be made using accurate, complete and up-to-date information.
Improving QC Data Quality Using Integrated Data Management Solutions
With fragmented information management approaches often getting in the way of this ideal, many food businesses are looking to transform their poorly connected systems into informatics platforms that streamline operations, improve visibility and reduce errors. The latest LIMS allow businesses to bring all their QC data into a single integrated system, helping to harmonize processes and make information sharing more efficient to enhance product quality and safety.
Take the execution of standard operating procedures (SOPs) for pesticide residue testing, for example. By centrally connecting instruments and storing SOPs digitally on a LIMS, processes and parameters can be downloaded directly, eliminating the need for human error-prone manual set-up and supporting the consistent collection of data. Furthermore, because these SOPs are located in a centralized system, securely accessible to authorized users across all sites and facilities, the risk of SOPs becoming out of date or out of sync is greatly reduced. With guidance on residue levels regularly updated to reflect the evolving knowledge of these threats, ensuring the latest testing protocols are applied is particularly important.
Additionally, because LIMS capture and store QC measurements directly, as it is generated, they eliminate the need for labor-intensive transcription and data transfer processes. Not only does this improve measurement accuracy by taking human error out of the equation, it also boosts efficiency and reduces the administrative burden on those responsible for collecting QC data. As a result, experienced staff can spend less time on paperwork and data entry, and more time actively optimizing processes and finding solutions to other key challenges. With access to the most accurate and up-to-date information, businesses are better placed to maintain the integrity of the food supply chain and can act to resolve potential issues before they turn into more significant problems.
Supporting Well-Defined QC Processes and Regulatory Compliance
With international food regulators turning their attention to the methods used to assure the quality and authenticity of foodstuffs, supply chain stakeholders are now expected to have well-defined QC workflows that not only provide complete traceability of products from farm to fork, but also transparency around processes such as instrument calibration and data handling.
Modern LIMS allow food businesses to visualize their workflow data using dashboards, process diagrams or facility maps. Image courtesy of Thermo Fisher Scientific.
LIMS allow food businesses to build regulatory compliance into their processes by providing a comprehensive overview of all supply chain data, including information associated with QC steps. As all data required to support proof of compliance is organized in a single system, it can be quickly and conveniently recalled for sharing or review purposes. Some of the latest systems allow users to visualize this data holistically on process diagrams or dashboards, helping to fulfill HACCP requirements and make keeping track of active workflows as easy as possible.
Furthermore, because LIMS can be used to capture and store data automatically, they also facilitate the real-time monitoring of supply chain processes, meaning out-of-specification QC parameters can be flagged and reported earlier. The sophisticated algorithms present in some of the latest LIMS can even be used to warn businesses of small but significant trends such as the decline in performance of an aging instrument, which could cause unexpected downtime or cause product quality standards to fall over time. These alerting capabilities mean potential issues can be remedied faster, helping stakeholders more proactively protect consumer safety.
Defensible data is central to protecting brand integrity, especially when it comes to issues around food adulteration and counterfeiting. As such, food businesses need robust data management tools that support complete traceability of actions. By automatically recording every interaction with the system to generate a comprehensive audit trail and facilitating the use of e-signatures to document review procedures, LIMS can safeguard the highest levels of accountability, from data collection all the way through to results reporting. Some of the most advanced LIMS also feature powerful audit trail search functionality, allowing authorized users to recall specific actions such as unusual QC activity or potentially non-compliant behavior. With a secure record of events and a single, integrated platform for supply chain data, food businesses can focus on what’s important—optimizing processes and delivering high-quality goods.
Optimizing and Safeguarding the Food Supply Chain Using LIMS
Modern LIMS allow food supply chain stakeholders to build regulatory compliance into their workflows by standardizing QC processes and giving authorized individuals full visibility over their data. By facilitating faster and more informed decision-making using accurate and up-to-the-minute data, LIMS are helping businesses meet current industry challenges head on to maintain the safety and integrity of the food supply chain.
References
FDA. (November 2007). Food Protection Plan. Access April 7, 2019. Retrieved from , https://www.fda.gov/downloads/aboutfda/centeroffices/oc/officeofoperations/ucm121761.pdf .
International Organization for Standardization. (June 2018). ISO 22000:2018(en) Food safety management systems — Requirements for any organization in the food chain..
The Grocery Manufacturers Association and A.T. Kearney. (2010). Consumer Product Fraud: Deterrence and Detection.
Find records of fraud such as those discussed in this column and more in the Food Fraud Database. Image credit: Susanne Kuehne
Use of sulphites in food is tightly regulated in the Netherlands. “Vleesfraude” or meat fraud was committed by Dutch meat processors and butchers by adding large amounts of sulphites to ground beef, sausages and other processed meats in order to achieve the perfect “meaty” red color. Sulphites are classified as an allergen with mandatory labeling requirements, however, their use in meat is illegal in the first place. The affected products were pulled from the market and the companies were fined for fraud.
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