Tag Archives: Focus Article

Emily Kaufman, Emport, Allergens
Allergen Alley

Matrix Matters: Why Allergen Test Kits Are Only Half the Story

By Emily Kaufman
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Emily Kaufman, Emport, Allergens

On-site rapid tests for allergens are an important part of any manufacturing facility’s allergen control plan. Several companies offer allergen test kits for day-to-day use, and it can be hard to tell the differences between them or determine which is the best fit for a given facility. What’s a busy QA professional to do?

One of the most overlooked factors when choosing an allergen test kit actually has almost nothing to do with the test kit itself. Instead, it’s much closer to home: The matrices being tested are just as—if not more—important to consider than the test kit itself.

Before you commit to any allergen test kit, you should talk to someone extensively about the types of products you plan to test. There are a variety of surprising and counterintuitive ways that your matrices can impact the functionality of a test, and you’ll save time and money by understanding information BEFORE you start testing. Below, we’ll review some of the most common matrix challenges.

High Fat Matrices

fruit pops, allergensLet’s imagine a facility that makes ice cream and sorbet. Let’s assume they make a gourmet strawberry ice cream and a fat-free strawberry sorbet, both of which ought to be peanut-free—but since some of the ingredients come from a supplier who also works with peanuts, the QA team decides to run a rapid peanut test on the strawberry products.

Much to the team’s surprise, the sorbet tests positive for peanut but the ice cream does not. What could be happening? Of course, the simplest explanation is possible: The sorbet has peanut residue in it and the ice cream does not. However, there’s another, trickier possibility: They could have the same amount of peanut residue, but the full-fat ice cream could inhibit the test kit’s ability to detect the allergen.

In general, the higher the fat content of your matrices, the higher the detection limit on your test kit. It’s an imprecise spectrum: Using rapid tests to find traces of allergenic protein on an oil is nearly impossible, on fat-rich items like ice cream or cream-based soups it’s a challenge, on items with little or no fat it shouldn’t be an issue. That isn’t to say there couldn’t be other issues with low-fat items, as we’ll review below.

Matrices Processed with High Heat

peanuts, allergensLet’s say our ice cream facility starts making a peanut-butter-swirl flavor. Perhaps they will begin testing their rinsewater for peanut residue after running that flavor, to ensure satisfactory cleaning. The kit they use says it can detect peanut allergen to 5 ppm, and rinsewater is not a high-fat matrix, so they should be good, right?

In this exact example, it’s probably just fine. However, it’s important for the QA team to consider the temperature at which peanuts were roasted. While raw peanut might be detectable at 5 ppm, roasted peanuts could have a detection limit that is much higher. In fact, very strongly roasted peanuts could only be detectable at levels of 500 ppm or more. This doesn’t mean there is no reason to test—but it’s important to know that many antibody-based tests will respond differently to an allergen processed with high heat than one that is raw. The same detection challenge can sometimes be seen with canned or tinned items that are subjected to high heat in processing.

Fermented or Hydrolyzed Matrices

Two of the trickiest items when it comes to allergen detection are soy sauce and fish sauce. In both of these condiments—and many other common ingredients subjected to these types of processing—the allergenic material is subjected to heavy modification. As proteins get folded and broken in unpredictable ways, they become more challenging for antibody-based test kits to detect. In fact, soy sauce and fish sauce are nearly undetectable by most kits.

When validating a cleaning process after using one of these ingredients, often the safest thing to do is to test for a different allergen—formulated in a simpler way—that is also present. Sufficient cleaning after a product made with fish sauce and breadcrumbs, for example, could be proven with a gluten kit; that second allergen will be unaffected by the fermented allergens in the recipe.

Matrices without Multiple Proteins

Some kits look for a variety of proteins commonly found within one allergen. Other times, though, each test kit will be looking for one specific protein. It’s important to confirm that the allergenic protein your facility works with is in fact an allergenic protein that your test kit is trained to recognize.

Perhaps the most common FALCPA allergen where this plays a role is milk. While there are a number of proteins in milk, casein is the most common and accounts for approximately 80% of the protein in milk, making it a common target for allergen test kits (both rapid and ELISA). The remaining 20% of protein is comprised of various whey proteins, most commonly beta-lactoglobulin.

In the case of our ice cream and sorbet facility mentioned above, a kit that detects casein OR beta-lactoglobulin OR both proteins together could be suitable for confirming that the sorbet is truly milk-free. However, there are other types of product that contain only whey proteins, which are a popular way to increase protein content in a variety of foods and beverages. If a facility that works exclusively with whey proteins uses a kit that only detects casein, they will never have a true understanding of their allergen contamination risk.

Another challenging FALCPA allergen is fish, as there are many different species of fish with quite divergent protein structures. If you are testing for fish contamination, it’s important to understand which species of fish the test you are considering can detect, and which species may pose a problem. If there is a mismatch between kit and matrix, then you’ll need to find a different way to ensure safety.

How to Troubleshoot Your Matrices

If you are beginning an allergen testing program, find time to talk with the manufacturers of any allergen kits you are considering. You may also want to talk with the representatives of any labs that are doing third party testing for you. Some questions to ask include:

  • What matrices have you validated your tests for?
  • Do you anticipate any issues with my matrices?
  • How should I validate your tests for my products?
  • What factors impact the sensitivity of this kit?
  • Does the detection limit change based on the matrix?

Your kit manufacturer (or third-party testing lab) should make you feel confident that they understand the quirks of your specific matrices—and they should have ideas for how to troubleshoot any challenges that they foresee. If a supplier tells you that their kit will work equally well across all matrices and declines to offer proof that corresponds to your needs, beware (or at least be prepared to conduct rigorous validation on your own). Allergen detection is complicated, and as with so much of life: If it sounds too good to be true, it probably is.

Laura Lombard, IMEPIK
FST Soapbox

The Business Case for PCQI Training

By Laura Lombard
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Laura Lombard, IMEPIK

Beyond reducing liability or checking a regulatory box, investing in robust training can reap measurable business impact. The FSMA regulation requires that Preventive Control Qualified Individuals (PCQIs) “have successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or be otherwise qualified through job experience to develop and apply a food safety system,” as per Subpart C Section 117.180 (c) (1). Even if the person serving in the role of PCQI is qualified through job experience, FDA investigators will expect adherence to development and application of risk-based controls as contained in the standardized PCQI curriculum material or the alternative training allowed in the regulation.

Let’s face it: Our employees serving in the role of PCQI come from a spectrum of food safety plan experience. In addition, many are mentoring new members as Qualified Individuals on the food safety team. Others are building a whole new team from scratch. Team members may be specialized department heads or hold several titles and job duties within a manufacturing facility. Your PCQI is charged with overseeing the development and analysis of the food safety plan. The PCQI needs a team that has had consistent training in the language of the new rules and how to comply to support the PCQI’s charge.

Beyond meeting the regulation, companies should train at the PCQI level to safeguard a company’s product quality, brand and customer base. The fewer food safety-related claims you have, the more you save in costly recalls, loss of current or potential customers, and your brand’s reputation. A company with a robust safety culture has a competitive advantage over competitors who are more lax in their food safety and may suffer financially and reputationally from recalls and customer quality assurance complaints. In an era when customers are seeking more information about the food they consume, being a trusted food safety brand can make your company stand above the crowd.

In addition, consistent training can help with internal culture change and worker productivity. Working on hazard analysis and defining preventive controls requires that employees show critical thinking and problem-solving skills. Team members taking a curriculum with standardized material and consistent learning objectives can reflect together to identify and document gaps and corrections to practices or processes. They can quickly apply their learning for more accurate analysis of the components of the food safety plan. This is the true impact from investment in high quality instruction—motivating employees to learn updated food safety practices, change their behavior, and make more efficient and effective decisions to keep the quality and safety of your products. Well-trained food safety employees are a key factor in the protection of your customers, your company’s brand and the prevention of costly food recalls. The investment in training at the PCQI level is strategic on all fronts.

Bob Pudlock, Gulf Stream Search
FST Soapbox

Architect the Perfect Food Safety Team: Does Your Next Food Safety or Quality Team Member Even Exist?

By Bob Pudlock
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Bob Pudlock, Gulf Stream Search

As a food safety leader, you’re accountable for keeping the company in line with regulations and ensuring consumer trust, yet you’re constantly asked to “do more with less”.

In an environment with such a thin margin for error, it’s imperative to have a seamless, friction free, fast but effective recruitment process.

As a food safety leader, you want to move the needle towards more proactive measures to optimize systems, develop more robust risk management systems and above all else get everyone in the company singing the same song when it comes to a food safety “culture”.

Bob Pudlock will be moderating the panel discussion, “Food Safety Leadership: Earning Respect”, at the 2019 Food Safety Consortium | October 1–3 | Schaumburg, ILOur three-part series on architecting the perfect food safety team will show you the components of a hiring and recruitment methodology that you can champion to your internal recruitment team, a third-party recruiter you trust, or you yourself.

Our first of three articles will focus on the IDENTIFICATION step, where, based on your job description, your compensation plan and your skill set requirements, you’ll be able to quantify the size of your candidate pool locally, regionally and nationally fast. This is really important.

Most companies don’t do this.

Internal recruitment teams aren’t optimized to do a deep dive on each job profile, whether it’s a Food Safety Specialist or a VP of Food Safety. The gap is exacerbated in food safety and quality due to the significant uptick in expertise required to execute on all the requirements that today’s food safety climate requires. Many roles that historically required only “attention to detail” and “Microsoft Excel skills” now require a microbiology or chemistry degree as well as subject matter expertise with quality management and ERP systems.

Unfortunately, your internal talent acquisition team will find it next to impossible to tell you how many SQF-certified QA managers with experience in a manufacturing setting with a Bachelors degree that reside within 30 miles of each plant in your network, much less be in a position to effectively contact and recruit them quickly.

You have to know where your future team members are today—either through internal means (your talent acquisition team) or externally(a recruitment firm)….and you can’t wait until you’ve had an unexpected resignation.

It’s like burying a fire extinguisher in your closet and not remembering where it is–if everyone in the house doesn’t know where it is, it hasn’t been tested, and it’s not located in the optimal place, it will serve no purpose when it’s an emergency.

At a recruitment firm approaching the food safety talent ecosystem and executing a search is done in much the same manner as how you develop your company’s HACCP plan.

Your HACCP plan addresses:

  1. What threats and hazards are we trying to avoid?
  2. What are we trying to achieve with our plan?
  3. What does a fully executed plan entail? Safe food and…..

Similarly, we start a search with a role’s “intent” fully defined.

The “intent” of the role rarely exists in a job description—this is fleshed out when having a conversation with a client. It starts with a series of questions such as:

  1. What is the first area of focus this person will tackle?
  2. What problem(s) will they be tasked with solving?
  3. What will this person’s area of focus look like after a year(best case)?

It’s an oft-overlooked step because most of our hiring managers are so busy they end up using the same cut-and-paste job description that’s been used for the last 10 years.

An example our clients have used for searches we’ve completed for them include:

  1. “In 12 months, the new hire will have fulfilled our company’s initiative to attain SQF Certification Level III for Plant X.”
  2. “Within 12 months, the new hire will have participated in the installation and led internal training of plant personnel; each plant team member will have been trained and passed internal testing requirements of the new system.”
  3. “The new hire will lead improvement initiatives that dramatically improve our KPI indicators around hazardous materials and foreign objects within 6 months of hire.”

With the end result in mind, you now have a clearer picture of what you’re looking for in your new hire rather than a stale, generic job description which, oh by the way, every other company is looking for.

With a clear picture of who you’re looking for and the end results you’re looking for, the next crucial step in the IDENTIFY stage is determining to what degree that candidate exists and is available in the market.

If you create a “wish list” in a vacuum without determining how many people actually have those criteria, it’s equivalent to developing a HACCP plan without validating it.

How do you validate a HACCP plan? You test it. You challenge the thresholds. That takes time, sure, but at the end of the testing, you know where the Critical Control Points are( room for improvement), you know better what absolutely needs to be changed (Corrective Action).

How you validate your HACCP plan is similar to how we provide our clients with data that reflects the feasibility their expectations – from there, we chip around the edges of the requirements until we have a large enough candidate pool from which we can effectively execute a recruitment strategy.

For example, we’re often asked to help clients with a search that has the following particulars:

  1. Plant QA Manager with three years of management experience
  2. QA Manager with management experience in a food, beverage, ingredient or flavor manufacturing/processing environment
  3. Bachelor degree in Chemistry and/or Biology
  4. Local candidates only

Each of the four-above criteria is a “limiter” of some sort—as you work through the list and add a requirement or a “must have”, the candidate pool decreases.

In the example above, the limiter that impacts the candidate pool the most will be the last one: “Local candidates only.”

That limiter might be forced on food safety or the quality department because of budget restrictions or it may be your choice altogether. Regardless, you’ve set the parameter and now it needs to be tested. Weeks and months can be lost if the search is executed without first knowing how many candidates actually have these skills locally.

You know how it feels when Marketing calls you in to test a new innovation for a product launch, three months into the gig? How within minutes of showing up at the trial you realize that production and quality will be compromised? How you wish they would have involved you from the start so you could have saved them, the company and your team all the headaches, time and money by offering an alternative? If only they would have asked you sooner?!?!

It’s the same with a search for a candidate with a particular set of skills and/or experience that doesn’t actually exist.

So, what’s the answer?

Well, the optimal strategy is to know every single food safety / quality candidate in the local market and/or nationally (especially if your category has more stringent needs like Dairy, Brewing, etc.) and to nurture them on an ongoing basis. You’ve done the work up front to assess and determine the caliber of the local candidate pool – since you’re already in rapport with the target candidate base, the turn-around time when you’re in a pinch is significantly shorter.

When a client asks us for the requirement we outlined above, we deliver an audit of that expectation within 48 hours, letting them know if that person actually exists and how many of them.

No time is lost. We have countless examples in the last year of alerting our client that two, yes two QA director candidates have the “must have” skills locally they are requesting, and neither is interested. We get clients to that point of discovery within hours, with tangible real-live data(not opinions), where they can then reassess their requirements and expand their candidate pool.

It’s a healthy conversation when it’s done early and up front— it results in less spinning of wheels and more productive dialogue around working within capabilities and restraints.

So do that—get your talent acquisition partner and talk to them specifically about your wish list, and have them come back to you with tangible numbers that validate whether or not what you’re asking for is reasonable.

Once you’ve done that and have a large enough pool of candidates to whom you can market the opportunity, you’ll be operating from a position of strength when it comes time to ASSESS the candidates who are brought forward. We’ll dive into more about the ASSESS step in Part two of our three-part series.

Megan Nichols
Retail Food Safety Forum

How Can We Make Food Labeling More Consistent?

By Megan Ray Nichols
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Megan Nichols

Consistent Inconsistencies

Current food labels may seem to possess a wealth of information, but they’re often challenging to read even if you know what you’re looking for. Additionally, studies have shown that even accurate food labels don’t work —they lead to no significant dietary changes. Even posting the calorie counts on fast food menus did little to change people’s eating habits.

It might sound as simple as telling consumers to read the ingredients labels on the items that they’re purchasing. The problem with this—aside from the fact that ingredients are often printed in a painfully small font—is that you almost need a degree in chemistry to understand the components. This confusion is a big issue with processed foods that contain a variety of chemicals to protect the flavor of the food and preserve it during storage.

When it comes down to it, choosing healthy foods isn’t the problem—or at least, not the only problem. Picking a healthy option isn’t as complicated as doing your taxes or choosing a mortgage when you purchase a home. We as consumers have plenty of information available to us when it comes to eating healthy. The problem is the fact that it’s easier and usually cheaper to choose the unhealthy option. You can buy a can of soda for $0.50, while a bottle of water often costs more than $1 at a soda machine or convenience store.

No One Reads Them Anymore

Another big issue with nutrition labels is that no one bothers to read them anymore. One survey found that two-thirds of young adults in the Minneapolis-St. Paul area don’t bother reading nutrition labels or worry about the nutrition content of what they’re eating.

While the survey didn’t explore why adults were no longer utilizing nutrition labeling, it’s likely due to a combination of consumer distrust and confusion. People either don’t trust that the labels contain accurate information, or they’re merely confused by the information presented in that format.

The Healthwashing Dilemma

How many times have you walked into the grocery store and chosen a brand based on whether or not it had “All-Natural” or “Organic” labels? Even if these phrases are written on the label, that doesn’t necessarily mean that the food contained within falls under either of those categories. That’s where the problem of healthwashing occurs.

Food packages will slap these labels on their product even if it doesn’t apply—a company can claim that their product is “all natural” and still use pesticides on it. Some businesses use products like pyrethrins, which are potentially dangerous pesticides derived from natural sources—specifically, the chrysanthemum flower.

Food companies don’t typically like to advertise this information because it might discourage potential consumers from choosing their brand, especially if the user is concerned about their health and is trying to remove all chemicals and pesticides from their food chain.

Fixing the Labeling Problem

What can we do to encourage consumers to pay attention to nutrition labels? The biggest challenge lies in making these labels more consistent and transparent. That task is more complicated than it sounds since there is no regulation or standardization in nutrition labeling. Clean labeling could be the solution.

Five key facets define clean labels — Simple ingredients lists, transparency in ingredients and packaging, no flowery language, accurate images and fresh food—are top priorities for consumers, with transparency being in the highest demand. However, these labels face the same problems as current nutrition labels—a lack of standardization. When asking more than 27,000 people in 31 countries what they thought clean labeling meant, more than a third had no idea, according to a report from Packaged Facts.

Many companies have started to transition to clean labels, but no law currently requires businesses to do so.

The Need for Change in Food Labeling Consistency

Food labeling could potentially help consumers make healthier choices if they were more accurate and easier to understand. Eliminating the flowery language that currently defines food labeling is one step in the right direction. The federal government— or, more specifically, the FDA— may need to step in as well to create standards that each company can be held to so that consumers know what exactly is in their food, no matter the brand.

Food labels are on nearly everything that we buy, except for fresh meat and produce. It’s time to create a standard and transparent label that everyone can understand.

Hand

Food Safety Tech, Food Safety Consortium Conference & Expo Announce Partnership with Alliance for Advanced Sanitation

By Food Safety Tech Staff
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Hand

EDGARTOWN, MA, Jan. 18, 2019 – Innovative Publishing Co., the publisher of Food Safety Tech and organizer of the Food Safety Consortium Conference & Expo, has announced a partnership with the Alliance for Advanced Sanitation. Angela Anandappa, Ph.D., director of the organization, will also be joining the Food Safety Tech and Food Safety Consortium Advisory Board. As part of this role, Anandappa will be a key resource on topics related to sanitation and will serve as chairperson for the Sanitation track at the Food Safety Consortium Conference & Expo, ensuring the presentations are relevant, accurate and balanced.

Angela Anandappa, Alliance for Advanced Sanitation
Angela Anandappa, director, Alliance for Advanced Sanitation

“The collaboration with Angela Anandappa and the Alliance for Advanced Sanitation is a significant enhancement to the Food Safety Consortium Conference & Expo,” said Rick Biros, president of Innovative Publishing Co., Inc. and director of the Food Safety Consortium Conference and Expo. “Angela brings a wealth of experience in food safety and molecular diagnostics, especially in her role developing programs that tackle hygienic design and sanitation issues.”

As a partner organization, members of the Alliance for Advanced Sanitation will also receive a discount to attend the Food Safety Consortium Conference & Expo in October.

“I look forward to working with Rick and his team at Food Safety Tech and the Consortium event to help industry further understand the issues we face in sanitation, the advances necessary for success and how we can share best practices,” said Anandappa, who is also a research assistant professor with the Department of Food Science and Technology at the University of Nebraska-Lincoln.

About Food Safety Tech

Food Safety Tech publishes news, technology, trends, regulations, and expert opinions on food safety, food quality, food business and food sustainability. We also offer educational, career advancement and networking opportunities to the global food industry. This information exchange is facilitated through ePublishing, digital and live events.

About the Food Safety Consortium Conference and Expo

The Food Safety Consortium Conference and Expo is a premier educational and networking event for food safety solutions. Attracting the most influential minds in food safety, the Consortium enables attendees to engage conversations that are critical for advancing careers and organizations alike. Visit with exhibitors to learn about cutting edge solutions, explore diverse educational tracks for learning valuable industry trends, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in an ever-changing, global food safety market. This year’s event takes place October 1–3 in Schaumburg, IL.

About the Alliance for Advanced Sanitation

The Alliance for Advance Sanitation’s research, extension and teaching activities engage university of Nebraska–Lincoln faculty and address the needs and interests of the private sector partners. The overall goal of these activities is to develop improved sanitation practices that can be implemented by the food processing and affiliated industries. The Alliance’s mission is to create a safer food supply through advanced sanitation approaches and practices.

Erika Miller
FST Soapbox

Does the Sanitary Transportation Regulation Require Seals for LTL Shipments?

By Erika Miller
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Erika Miller

This question has come up frequently in our FSMA Sanitary Transportation workshop. Just as with all the parts of FSMA, the focus of the Sanitary Transportation of Human and Animal Food regulation is on addressing hazards that may be present throughout the food chain and assigning responsibility (liability) for preventing those hazards. There are very few specific requirements—most of it is couched in very general language, for flexibility on both sides (FDA’s and industry’s).

While the regulation does not specifically address locks or seals on trailers, the FDA has stated publicly that they intend to enforce the adherence of industry to generally accepted best practices. Sometimes, as in the case of certain animal food applications, the FDA has stated they will accept mild steel transports instead of stainless (as would typically be required for hauling food) because it’s all about the risk, and mild steel is not a risk in those applications. What is the risk of an unlocked load to the food being hauled, and to the business being conducted? Maybe a seal or lock on an LTL can protect a significant investment from an identified hazard.

Generally, in most food hauling operations, seals or locks are required on trailers by businesses in order to protect their investments. They are also expected under GFSI-approved food safety management systems, used by most food manufacturers (which are private, voluntary standards, not regulatory). They are definitely required if you want to haul 100% juice under Juice HACCP and the JPA guidelines.

There are so few straightforward answers with FSMA. You must always look at your operation, your risks, and decide if controls are necessary. Document the basis for your decision, ensuring it is based on facts. If the FDA inquires, you must make your case for your decision. Do you feel comfortable defending it, all the way to a court of law if need be? If so, then stand by it.

If there are potential risks to food that is being hauled (don’t forget about defense-type risks as well, like the truck being stolen or misrepresented) then you must take reasonable, industry-standard precautions to prevent those hazards from occurring.

Of course, you want to do this anyway because it is smart business.

Karen Everstine, Decernis
Food Fraud Quick Bites

Media Sources for Food Fraud Intelligence

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

A recently published paper advocates the inclusion of media reports as a source of information for assessing food fraud vulnerability.1 Those of us who maintain the Food Fraud Database could not agree more. We have been monitoring media reports for years and they are an important source of information in the database (accounting for 45% of all primary source references).

As I mentioned in last month’s post, there are challenges with using media reports to inform food fraud vulnerability. Many media reports are general discussions of the issue of food fraud and are not necessarily reporting new information. It may be difficult to filter out these types of reports without manual review. There may also be concerns about the validity of media reports on food fraud. This is the reason we implemented a classification for “weight of evidence” for incident records in the database. Overall, approximately 30% of the incident records in our database are classified as a “low” weight of evidence due to unverifiable data or a lack of corroborating reports. Some of our users choose to filter these out of their searches.

We have received requests for information about how the data in the Food Fraud Database compares with numbers reported in the paper. Table 11 in the paper described the top product categories, countries and type of fraud as reported in four food safety tracking systems.1 We have adapted that table below to data from the Food Fraud Database.

Product Category % Country of Origin % Type %
Meat/Poultry 18 India 26 Dilution/substitution (misrepresentation of animal origin) 26
Seafood 16 China 9 Dilution/substitution (“other”) 19
Dairy Products 14 United States 9 Dilution/substitution with a non-food substance 14
Alcoholic Beverages 6 Columbia 6 Dilution/substitution (misrepresentation of botanical origin) 12
The most common food fraud records (“cases”) in the Food Fraud Database (2014-2015)

As shown in Table 11 in the paper, the top four products by number of articles in the media monitoring system (in 2014-2015) were meat, seafood, milk and alcohol. As shown above, when looking at data in the Food Fraud Database from 2014 and 2015, the top ingredient categories are very similar: Meat/Poultry, Seafood, Dairy Products, and Alcoholic Beverages. However, there was little agreement in the country of origin of the reported cases among any of the systems. For the Food Fraud Database (shown above), the top countries of origin in 2014–2015 were India, China, the United States and Colombia. According to the paper, the top countries of origin reported by the food fraud media monitoring system were Egypt, the United States, the U.K. and Saudi Arabia. The top country of origin reported by RASFF was China and by HorizonScan was the Czech Republic.

Table 4 reported the “types” of food fraud (which correspond to what we call “reasons for adulteration”) and the corresponding number of articles collected, which we have also adapted to the data in the Food Fraud Database below.

Types of Food Fraud in Records in the Food Fraud Database (2014–2015)
Type of Food Fraud Number of Records %
Dilution/substitution – misrepresentation of animal origin 212 26
Dilution/substitution (other) 159 19
Dilution/substitution with a substance not approved for use in foods 118 14
Dilution/substitution – misrepresentation of botanical origin 101 12
Unknown 87 11
Fraudulent labeling 64 8
Artificial enhancement of apparent protein content 58 7
Artificial enhancement with color additives 57 7
Other 41 5
Dilution/substitution – misrepresentation of geographic origin 40 5
Dilution/substitution – misrepresentation of varietal origin 28 3
Use of unapproved biocides (antibiotics, anti-fungal agents, preservatives, etc.) 21 3
Artificial enhancement (other) 7 1
Formulation of an entirely fraudulent product using multiple techniques and adulterants 2 0
TOTAL 828 *
* Greater than 100% because one record can have multiple types of associated fraud

It is not possible to make meaningful comparisons among the reported fraud “types” without harmonized definitions and standardization of data collection processes, as noted in the paper. A glance at Table 1 from the paper illustrates the variety of food fraud categorizations in use among the various systems.1 Generally, it is a challenge to directly compare any of the information coming from various sources such as RASFF, HorizonScan, the Food Fraud Database and others, due to the differences in the way data is collected, standardized and reported.

In contrast with foodborne illnesses, which are generally required to be reported to public health agencies, food fraud typically does not result in acute illness and is difficult to track. The nature of food fraud combined with differences in data tracking systems make it almost impossible to reconcile the data among the various systems. Regardless of which system is reporting, the reports are likely just a fraction of the true occurrence of food fraud; however, each can provide valuable perspective on risks to food safety (including those from food fraud). A holistic assessment of food fraud vulnerability should take into account a wide variety of information sources, including media reports.

Reference

  1. Bouzembrak, Y., et al. (November 2018). Development of food fraud media monitoring system based on text mining. Food Control. Vol. 93. Retrieved from https://doi.org/10.1016/j.foodcont.2018.06.003
Food Safety Tech

Call for Abstracts for the 2019 Food Safety Consortium & Expo

By Food Safety Tech Staff
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Food Safety Tech

It’s that time of year again! As we prepare to put together another informative and insightful Food Safety Consortium, we are requesting abstracts for presentation content. This year’s event takes place October 1–3 in Schaumburg, IL.

Before submitting an abstract, here are some things to keep in mind:

  • This year’s breakouts will feature
    • 1) Cleaning & Sanitation
    • 2) Food Safety Testing
    • 3) Food Safety Management
  • The abstract should be about 300 words
  • Presentations will be judged on educational value
  • Don’t submit a sales pitch!
  • Presentation time is about 45 minutes—this includes a 10-15 Q&A session

The abstract submission deadline is May 15. For more information on submitting an abstract to the 2019 Food Safety Consortium click here.

Good luck!

Steve Ardagh, Eagle Protect
FST Soapbox

Glove Polymers: The Unregulated Food Safety Threat

By Steve Ardagh
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Steve Ardagh, Eagle Protect

Various polymers are used in food contact applications that include food packaging and disposable gloves. More than 30 different types are used in packaging and up to six in disposables gloves. In terms of safeguards for the U.S. food supply as well as user safety, it is worth noting that 87% of the production of packaging polymers is based in the United States and subject to FDA regulation and monitoring. On the other hand, all (100%) of the 100 or more glove factories supplying the United States are based in Southeast Asia, according to a report by the British Medical Association and are not subjected to the same FDA monitoring or scrutiny.1

Packaging production is carefully overseen by the FDA, is included in FSMA, and covered in the HACCP process. Toxicology of food packaging is carefully prescribed and subject to strict enforcement action from production to storage.

Glove factories, however, are generally self-regulated, with FDA compliance required for a rough outline of the ingredients of the gloves rather than the final product. Few controls are required for glove manufacturing relating to the reliability of raw materials, manufacturing processes and factory compliance. A clear opportunity exists for accidental contamination within the glove-making process. More significantly, because of the geographic and economic implications in workforce and workplace conditions, intentional contamination potential is greatly increased. Polymer gloves utilized in food processing and service have been implicated in 15–18% of foodborne illness outbreaks in the United States.2

There is a striking difference in the requirements for these two different types of food contact polymers. Food packaging is extensively regulated, gets tested within the context of completed food product and has production primarily in the United States under close supervision. Disposable gloves, on the other hand, rely on self certification, often with testing results only on glove constituents, and little or no oversight of factory process and conditions. It seems as though this is a glaringly obvious but little accounted for risk to the U.S. food sector.

As a result, based on the root cause analysis of food cross contamination, a selection of tests and certifications, some of which are unique to the glove industry, are being implemented by one particular glove supplier. These tests ensure that their gloves coming into the United States are made in clean, well-run factories, free of any type of contamination and are consistent in material makeup to original food safe specifications. This glove fingerprint testing program consists of a number of proprietary risk reduction steps and targeted third-party testing methods, includes gas chromatography combined with mass spectroscopy (GC/MS, surface free energy determination, in vitro cytotoxicity analysis, and microbial viability-linked metagenomic analysis.

With a great deal of faith placed on a glove supplier’s ability to deliver disposable gloves sight unseen, I believe these tests are essential to further reduce the food safety risks associated with them. Objective…Zero surprises!

References

  1. Bhutta, M. and Santhakumar, A. (March 2016). In Good Hands. Tackling labor rights concerns in the manufacture of medical gloves. British Medical Association. Retrieved from https://www.bma.org.uk/collective-voice/influence/international/global-justice/fair-medical-trade/medical-gloves-report.
  2. Michaels, B. (2018). Determination of the % of Foodborne Illness Outbreaks Attributed to Glove-Related Cross-Contamination. Unpublished report

The author would like to acknowledge Barry Michaels, an international scientific consultant on food safety, infectious disease transmission and glove use, who has assisted in the fingerprint testing program discussed in this column.

Lettuce

CDC Reports Romaine Lettuce Outbreak Over

By Food Safety Tech Staff
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Lettuce

Although FDA is continuing its investigation into the source of the E.coli outbreak involving romaine lettuce grown in California, the CDC has declared the outbreak over. Contaminated romaine that caused illnesses should no longer be available, FDA stated in an outbreak update. Consumers will not need to avoid romaine lettuce, and retailers and restaurants do not need to avoid selling or serving the product, according to the agency. Suppliers and distributors need not avoid shipping or selling any romaine that is on the market either.

FDA has recommended that romaine lettuce is labeled with the harvest location and date, as well as whether it has been grown hydroponically or in a greenhouse. “ In case of future product withdrawals or recalls of romaine lettuce, this will help to limit the amount of product to be removed from the market and it will help consumers, restaurants and retailers determine that the romaine lettuce they are buying is from an unaffected growing region,” stated FDA. In addition, the detailed labeling should be available in stores, the agency states.