Tag Archives: food fraud

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Keeping Food Safe, the U.S. Way

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

In the United States, the FDA is responsible for regulations and recommendations to protect public health, which includes the prevention of any type of food adulteration (unintentional contamination, intentional adulteration, and food fraud – or “economically motivated adulteration”). FSMA (the Food Safety Modernization Act) resulted in new regulations and guidance with strategies to reduce all types of risks in food facilities. It was the most comprehensive reform of FDA’s food safety regulations in more than 70 years.

Resource

  1. FSMA Rules & Guidance for Industry.

 

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Keeping Food Safe, the German Way

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

Governments are responsible for the regulatory framework and consumer food protection to keep their citizens safe. In Germany, the Federal Office of Consumer Protection and Food Safety is responsible for national food safety as well as cross-border trade and international information exchange. The German BLV is also the contact point for the EU’s Rapid Alert System for Food and Feed, RASFF. To ensure consumer safety, the Max Rubner-Institut employs some 200 scientists who research food safety, nutrition and food fraud.

Resources

  1. Bundesamt fuer Verbraucherschutz und Lebensmittelsicherheit (November 11, 2019). Retrieved from Federal Office of Consumer Protection and Food Safety, Germany, and Max Rubner-Institut, Federal Research Institute of Nutrition and Food.
Susanne Kuehne, Decernis
Food Fraud Quick Bites

The Hellcat of Pet Food

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

Pet food is a highly profitable business. Global pet food sales hit a record $90 billion in 2018, and adulterated or mislabeled feed is not uncommon. In the United States, the FDA ensures correct labeling and adherence to quality standards in pet food. Over the course of six years, a processing facility in Texas shipped low quality, mislabeled ingredients such as feathers and by-products, labeled as premium single ingredients, to pet food manufacturers and distributors. The guilty party had to pay $4.5 millions in restitution to the fraud victims, and the defendant is on a five year probation.

Resources

  1. Department of Justice, U.S. Attorney’s Office, Western District of Missouri (October 24, 2019). “Texas Manager Pleads Guilty to Pet Food Fraud, Company Pays $4.5 Million Restitution”. Retrieved from The United States Department of Justice.
Karen Everstine, Decernis
Food Fraud Quick Bites

Public Food Standards

By Karen Everstine, Ph.D., Steven M. Gendel, Ph.D.
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Karen Everstine, Decernis

In 1995, a honey processing company was indicted on charges of adulterating industrial honey labeled “USDA Grade A” with corn syrup to increase profits. Ultimately, the jury found in favor of the honey processor, in part because there “weren’t enough regulations governing honey to make the charge stick.”

Honey is defined as “the natural sweet substance produced by honey bees” from the nectar of plants. However, there is not currently an FDA standard of identity for honey in the United States, which would further define and specify the allowed methods of producing, manufacturing and labeling honey (there is, however, a nonbinding guidance document for honey). Some of the details of honey production that a standard of identity might address include allowable timing and levels of supplemental feeding of bees with sugar syrups and the appropriate use of antibiotics for disease treatment.

In circumstances where strict regulatory standards for foods are not available, they may be created by other organizations.

What Is a Food Standard?

A food standard is “a set of criteria that a food must meet if it is to be suitable for human consumption, such as source, composition, appearance, freshness, permissible additives, and maximum bacterial content.”1

To ensure quality, facilitate trade, and reduce fraud, everyone in the supply chain must have a shared expectation of what each food or ingredient should be. Public standards set those expectations and allow them to be shared. They help ensure that stakeholders have a common definition of quality and purity, as well as the test methods and specifications used to demonstrate that quality and purity. Public standards help ensure fair trade, quality and integrity in food supply chains.

How Is a Standard Different from a Method?

A method is generally an analytical technique to assess a particular property of the content or safety of a food or food ingredient. For example, methods for detection of nitrates in meat products or baby food, coliforms in nut products, or high fructose syrups in honey. Methods are an important component of food standards.

A food standard goes a step further and provides an integrated set of components to define a substance and enable verification of that substance. Standards generally include a description of the substance and its function, one or more identification tests and assays (along with acceptance criteria) to appropriately characterize the substance and ensure its quality, a description of possible impurities and limits for those impurities (if applicable), and other information as needed (see Figure 1).

FCC Standard, USP
Figure 1. The Anatomy of an FCC Standard (Source: Food Science Program, Food Chemicals Codex, USP)

Figure 1. The Anatomy of an FCC Standard (Source: Food Science Program, Food Chemicals Codex, USP)

A standard defines both what a food or food ingredient should be and documents how to demonstrate compliance with that definition.

Public Standards and Food Fraud Prevention

Many of the foods prone to fraud are those that are not simple food ingredients, but agricultural products that can be more complex to characterize and identify (such as honey, extra virgin olive oil, spices, etc.). Milk products are an example of a commodity that is prone to fraud with a wide range of adulterants (for example, fluid cow’s milk is associated with 155 adulterants in the Food Fraud Database). Ensuring the quality and purity of a product link milk requires implementation of multiple analytical techniques or the development of non-targeted methods.

The creation of effective public standards with input by a range of stakeholders will be particularly important for ensuring the quality, safety and accurate labeling of these high value commodities in the future.

Reference

  1. A Dictionary of Food and Nutrition 2005, Oxford University Press.

Resources

  1. The Food Chemicals Codex is a source of public standards for foods and food ingredients. It was created by the U.S. FDA and the National Institute of Medicine in 1966 and is currently published by the nonprofit organization USP. The FCC contains 1250 standards for food ingredients, which are developed by expert volunteers and posted for public comment before publication.
  2. The Decernis Food Fraud Database is a continuously updated collection of food fraud records curated specifically to support vulnerability assessments. Information is gathered from global sources and is searchable by ingredient, adulterant, country, and hazard classification. Decernis also partners with standards bodies to provide information about fraudulent adulterants to support standards development.
Susanne Kuehne, Decernis
Food Fraud Quick Bites

Comparing Ceylon and Cassia

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

Cinnamon is in high demand worldwide, with Ceylon cinnamon or true cinnamon (Cinnamon verum) the most sought-after and higher priced variety. It is therefore tempting to “cut” Ceylon cinnamon with cheaper cassia cinnamon. Previous detection methods for such adulterations included HPLC testing or DNA barcoding, which was time consuming and could only be applied by experts. New FT-NIR (Fourier transform near-infrared) and FTIR (Fourier transform infrared) spectroscopic methods in combination with multivariate analysis enable quick detection of cinnamon adulteration.

Resources

  1. J. Yasmin, M.R. Ahmed, S. Lohumi, C. Wakholi, H. Lee, C. Mo, B.-K. Cho, Corresponding author: chobk@cnu.ac.kr, Quality Assurance and Safety of Crops & Foods: 11 (3)- Pages: 257 – 267 (25 April, 2019). “Rapid authentication measurement of cinnamon powder using FT-NIR and FT-IR spectroscopic techniques”. Retrieved from Wageningen Academic Publishers, wageningenacademic.com

Lessons Learned from Intentional Adulteration Vulnerability Assessments (Part I)

By Frank Pisciotta, Spence Lane
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Food defense is the effort to protect food from intentional acts of adulteration where there is an intent to cause harm. Like counterterrorism laws for many industries, the IA rule, which established a compliance framework for regulated facilities, requires that these facilities prepare a security plan—in this case, a food defense plan—and conduct a vulnerability assessment (VA) to identify significant vulnerabilities that, if exploited, might cause widescale harm to public health, as defined by the FDA. Lessons learned during the conduct of food defense vulnerability and risk assessments and the preparation of the required food defense plan are detailed throughout this three-part series of articles. Part I of this series is intended to assist facilities that have not yet conducted vulnerability assessments or wish to review those already conducted, by leveraging lessons learned from assessments conducted for the largest and most complex global food and beverage facilities.

Lesson 1: VA outcomes are greatly enhanced if a physical security professional is consulted. In support of this contention, there are several physical security mitigation strategies, which can be employed to support a food defense program, that are frequently under-utilized and are not optimally managed by non-security staff. Also, the FDA seems to promote the use of cameras even though this equipment is unlikely to prevent an incident of intentional adulteration. For organizations that choose to use video surveillance, a competent security professional can help organizations engineer and operate video surveillance for maximum benefits and to meet challenging record-keeping requirements when this mitigation strategy is included in a food defense plan.

Lesson 2: Given the focus by the FDA on the insider, a formal insider threat detection program is highly recommended. Trying to promote the common, “See Something, Say Something” strategy may not be enough. For example, if employees are not clearly told what to look for in terms of uniform requirements, how to identify persons who do not belong or changes to a coworker’s baseline behavior, which may indicate moving toward a path to violence or sabotage, then “See Something, Say Something” may end up being no more than a catchy slogan.

A key element of an insider threat detection program is the completion of effective background checks for all persons who will be allowed in the facility unescorted. This includes temporary employees and contractors. A common theme in many of the recent, serious intentional adulteration incidents was that the person responsible was involved in some sort of grievance observable to coworkers and supervisors. In all insider threat detection programs, the grievance becomes an important trip wire. The Carnegie Mellon University Software Engineering Institute has published a document titled, “Common Sense Guide to Mitigating Insider Threats, Sixth Edition”. In this document is some particularly helpful guidance that can be used to stand up an insider threat detection program, but this is an effort that can take some time to fully implement.

Lesson 3: The FDA has made it abundantly clear that they believe the focus for the food and beverage industry should be the radicalized insider. A closer look at all the recently publicized contamination events suggests that there are other profiles that need to be considered. A good foundational model for building profiles of potential offenders can be found in the OSHA definitions for workplace violence offenders, which has been expanded to address ideologically based attacks. Table I applies those descriptions to the food and beverage industry, with an asterisk placed by those offender profiles that exist in recent incidents and discussed later in the text.

Class OSHA Workplace Violence Offender Description Motivation Translated to the Food and Beverage Industry
1 The offender has no legitimate relationship to the business or its employee(s). Rather, the violence is incidental to another crime, such as robbery, shoplifting, trespassing or seeking social media fame. Behavioral Health Patient *
Social Media Fame Seeker *
Copycat *
Extortion *
Economic motivation *
2 The violent person has a legitimate relationship with the business—for example, the person is a customer, client, patient, student, or inmate—and becomes violent while being served by the business, violence falls into this category. My load isn’t ready, you are costing me money
3 The offender of this type of violence could be a current employee or past employee of the organization who attacks or threatens other employee(s) in the workplace. I am upset with a coworker and adulterate to create problems for that person *
I am upset with the company and adulterate as retribution and to harm the brand *
Youthful stupidity
I am not paid enough *
4 The offender may or may not have a relationship with the business but has a personal (or perceived personal) relationship with the victim. I am upset with an intimate partner/ coworker and adulterate to create problems for that person
5 Ideological workplace violence is directed at an organization, its people, and/or property for ideological, religious or political reasons. The violence is perpetrated by extremists and value-driven groups justified by their beliefs. Radicalized Insider
Table I. A description of OSHA workplace violence offenders and how it can be applied to the F&B industry.

A supermarket in Michigan recalled 1,700 lbs. of ground beef after 111 people fell ill with nicotine poisoning. The offender, an employee, mixed insecticide into the meat to get his supervisor in trouble. In Australia, the entire strawberry industry was brought to its knees after a disgruntled supervisor “spiked” strawberries with needles. There were more than 230 copycat incidents impacting many companies. A contract employee in Japan, apparently disgruntled over his low pay, sprayed pesticide on a frozen food processing line resulting in illnesses to more than 2,000 people. A contract worker upset with a union dispute with the company at a food manufacturing plant videoed himself urinating on the production line, then uploaded the video to the Internet. Be cognizant of any grievances in the workplace and increase monitoring or take other proactive steps to reduce the risk of intentional adulteration.

Lesson 4: The IA Rule requires that every point, step and procedure be analyzed to determine if it is an actionable process step (APS). The Hazard Analysis Critical Control Point flow charts are a good starting point to comply with this element of the law but cannot be counted on completely to achieve the standard of analyzing every point, step or procedure. Critical thinking and persons familiar with the production process need to be involved to ensure that no steps are missed. Oftentimes companies modify the HACCP flow diagrams after a VA.

Lesson 5: The FDA states in the second installment of guidance (here’s the full copy) to the industry that, “There are many possible approaches to conducting a VA. You may choose an approach based on considerations such as the time and resources available and the level of specificity desired. You have the flexibility to choose any VA approach, as long as your VA contains each required component (21 CFR 121.130).”

The FDA further states that the Key Activity Type, or KAT method, is an appropriate method for conducting a VA because it reflects consideration of the three required elements and the inside attacker. Using this methodology alone, however, can result in substantially more APS’s, which might otherwise be ruled out for practical purposes such as a lack of accessibility or a lack of feasibility to contaminate the product at a point, step or procedure. We have experienced up to a 90% decline in APS’s by utilizing another FDA recommended assessment approach, the hybrid approach, which assesses each point, step or procedure as first whether it is a KAT. Then to qualify as an APS, it must also trigger positively for public health impact, accessibility and feasibility to contaminate the product.

Organizations who have yet to execute vulnerability assessments (due July 26, 2020) or who may wish to reflect back on their existing VA’s in an effort to eliminate unnecessary APS’s should find these strategies helpful to focus limited resources to the areas where they can have the greatest effect. The next two articles in this series will cover more information on electronic access, the value of site tours, comparisons to drinking water security strategies, dealing with multi-site assessments and more.

Susanne Kuehne, Decernis
Food Fraud Quick Bites

Fraudsters Who Deserve Prison Time, Too

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

Uninspected and adulterated beef with a value of more than $1 million was sold to prison institutions in 18 states across the United States, a crime that carries a potential five-year prison sentence. The meat processor illegally used whole cow hearts and went a long ways to hide illegal ingredients from USDA inspectors.

Resources

  1. Erin Dooley, Public Affairs Officer, Office of the Inspector General USAO – Texas, Northern (September 24, 2019). “Meat Packing Plant Execs Plead Guilty to Selling $1 Million in Adulterated Ground Beef to Federal Bureau of Prisons”.
Susanne Kuehne, Decernis
Food Fraud Quick Bites

Not in Good Spirits

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

Fake brandy based on corn distillate was purchased by a Spanish company based in Georgia and was exported to other EU countries with falsified documentation. Fortunately, this alcohol fraud did not pose a health hazard like many other alcohol fraud cases. However, the economic gain for the fraudulent brandy was going to be huge, since a volume of 4 million liters of “brandy” was exported. EU regulations state that brandy is supposed to be based on wine distillate only, which costs up to four times more than distillate made from corn.

Resources

  1. Herraiz, P. El Mundo (September 16, 2019). “La trama del brandy español falsificado exportó cuatro millones de litros ilegalmente”.
Susanne Kuehne, Decernis
Food Fraud Quick Bites

A Broken Record

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

Over the course of almost a full year, laboratory documents were falsified by the owner and the quality control officer of a Connecticut meat processing company. None of the reported beef samples were actually taken and tested for E. coli. The letterhead of a formerly utilized inspection laboratory was fraudulently used to falsify the test documents, an act that carries a maximum term of five years in prison. Fortunately, no illness was reported from consumers who purchased the meat products.

Resources

  1. The United States Attorney’s Office (September 23, 2019). “Quality Control Officer of Connecticut Meat Supplier Admits Fabricating E. Coli Test Results”. Department of Justice, U.S. Attorney’s Office, District of Connecticut.
Susanne Kuehne, Decernis
Food Fraud Quick Bites

I Have a Beef with You

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

Over the course of three years, wholesale meat fraudsters in Brooklyn, NY, removed the USDA stamp on “Choice” beef and applied a counterfeit USDA “Prime” stamp to sell the fraudulently labeled meat at a premium price. A conviction can get the defendants a prison sentence of up to 20 years, even public health was not endangered, however, the USDA is taking integrity and quality of food very seriously.

Resources

  1. John Marzulli, U.S. Attorney’s Office (September 24, 2019). “Two Defendants Charged in Scheme to Sell Fraudulently Misbranded Beef Products”. Department of Justice, U.S. Attorney’s Office, Eastern District of New York