Tag Archives: food fraud

Food Safety Supply Chain panel 2017

Industry Experts Weigh in on Supply Chain Issues

By Maria Fontanazza
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Food Safety Supply Chain panel 2017

The Food Safety Supply Chain conference brought together industry stakeholders from FDA, CFSAN, GFSI’s certification programs, academia and food companies to discuss strategies and challenges of the supply chain in a more complex global environment. The two-day event was held earlier this month at U.S. Pharmacopeial Convention in Rockville, Maryland. Here’s what some of the speakers had to say.

(Click images to enlarge)

Sharon Mayl, FDA You can’t build safety at the border; you have to build in safety before you get to the border… The Foreign Supplier Verification rule requires importers for first time to share responsibility of products that are coming into country. We have written this rule with a lot of flexibility. – Sharon Mayl, senior advisor for policy to the deputy commissioner for foods and veterinary medicine, FDA, on the FSMA FSVP rule
Jennifer Thomas, CFSAN Transportation of food is a piece that doesn’t get a lot of attention, but it’s a very important part in ensuring the safety of food…[FDA is] in the process of developing a small entities compliance guide. We’re also revising the guidance we did in 2010 to ensure that it’s consistent with the rule. – Jennifer Thomas, director, division of enforcement, office of compliance, CFSAN, on the FSMA Sanitary Transportation of Human Food rule

Food fraud can lead to a public health threat—and should be managed under a food safety management system. – John Spink, Ph.D., director and assistant professor, Michigan State University, on supply chain transparency and food fraud

Russell Statman, Registrar Corp. When you’re looking at the Foreign Supplier Verification Program, you also have to approve your suppliers. There are several aspects to this—you have to check their record with FDA, whether they have any warning letters or on import alert. That doesn’t mean you can’t buy from them, it just means you have to investigate what the problem is. – Russell Statman, executive director, Registrar Corp., on the FSVP rule
FDA doesn’t have jurisdiction over aquaculture farms. So we’re working with countries that do. Any country that has a significant industry has good aquaculture practice programs (GAqP)— every country now has one—so we’re working with them now to make them better. ­– Brett Koonse, consumer safety officer, FDA, on aquaculture and food safety Brett Koonse, FDA

[The Sanitary Transportation of Human Food rule is important because of] the role that transportation has played in the past regarding foodborne outbreaks. We have to be proactive. We can’t learn from our mistakes anymore. – Debby Newslow, president, DL Newslow & Associates

Food Safety Supply Chain panel 2017
(left to right) John Wadie of 3M Food Safety, Melanie Neumann, Terry Levee and Jorge Hernandez

Food safety should not be about just meeting the regulations. Suppliers must still meet the standards of your business.  – Jorge Hernandez, chief food safety officer, Wholesome International

Collaboration and partnership are the only way your going to gain the transparency you need in the supply chain and build your brand for the protection it needs. – Melanie Neumann, president and global food safety attorney, Neumann Risk Services, LLC

One of reasons retailers take [visibility] seriously is that we’re the last line of defense. If you buy something at the grocery store and you get sick, you don’t remember the manufacturer of the product, you remember where you [bought] the product. – Terry Levee, senior director of food safety, Giant Eagle

Food fraud

Mitigating Food Fraud: Top Tips

By Food Safety Tech Staff
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Food fraud

The complimentary webinar, Top Tips to Mitigate Food Fraud, takes place on June 22 at 1 pm ET. Register now.Recently, the topic of food fraud has been discussed with increasing urgency. From understanding the basics of what is food fraud to navigating the regulatory requirements, quality assurance, compliance and procurement professionals must have a general understanding of the components.

An upcoming free webinar will review the hazard analysis requirements surrounding the FSMA Preventive Control for Human Food, GFSI requirements for raw materials and risk assessments and food fraud mitigation plans. Attendees will also learn about food fraud mitigation implementation strategies. The speakers participating in this webinar are Jeff Chilton, vice president of professional services at Alchemy Systems and Peter Claise, marketing director for foods programs at USP.

Jennifer van de Ligt, Food Protection and Defense Institute, University of Minnesota
FST Soapbox

Hot Topics in Intentional Adulteration, Food Fraud and Food Crime

By Jennifer van de Ligt, Ph.D.
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Jennifer van de Ligt, Food Protection and Defense Institute, University of Minnesota

The Food Protection and Defense Institute held its annual Food Defense Conference on May 3 and 4. This unique conference focused on food fraud detection, food crime, intentional adulteration FSMA updates, advocacy for food protection and defense, and big data and how to use it. The event garnered active discussion and collaboration among speakers and attendees representing six international government agencies, 11 domestic federal, state and local government agencies, 33 private food sector partners, and many academic partners.

The keynote address by Andy Morling, head of the UK National Food Crime Unit, led off the conference with discussion on food fraud and food crime. He profiled the tremendous work being taken to bridge the food regulatory and criminal systems to curb food crime in the UK. The UK response to food crime is guided by the 4P approach: Prevent, Protect, Prepare and Pursue. The Protect (reducing vulnerabilities) and Prepare (investing in capacity and capability building) components of the 4P approach embody key concepts of successful food defense plans.

Economically Motivated Adulteration and Food Fraud will be discussed at the Food Safety Supply Chain Conference | June 5–6, 2017 | Learn moreThe food crime discussion was followed by insight on food fraud detection in the European Union from Franz Ulberth, Ph.D., head of the Fraud Detection and Prevention Unit at the European Commission’s Joint Research Centre. This included results from Operation Opson in which Europol and INTERPOL coordinated with 61 countries. The goal of Operation Opson is to protect public health and safety through international cooperation to combat counterfeit and substandard food and drink. In Operation Opson VI, more than 9,800 tons, 26.4 million liters, and 13 million units/items of potentially hazardous food worth an estimated €230 million were seized between December 2016 and March 2017. The scope of products seized spans the range of all foods and beverages such as mineral water, alcohol, olive oil, seasonings, seafood and caviar, and includes both every day and luxury items. In addition, Dr. Ulberth outlined key characteristics of food fraud, the most common foods susceptible to fraud, and types of vulnerability and mitigation in the food fraud area.

Defense against food fraud through the use of genomics and ingredient supply chain understanding were presented by Robert Hanner of the Biodiversity Institute of Ontario at the University of Guelph and Cheryl Deem, executive director of the American Spice Trade Association, respectively. Genomics have been particularly helpful in identifying and quantifying the prevalence of seafood fraud. The most common seafood fraud is when one species of seafood is marketed and sold as a different species. The primary driver for this deception is to promote lower quality or illegal seafood species as a species of higher quality, premium location, or simply allowed in commerce. The genomics technique has been used successfully in the food fraud arena. It identified puffer fish, which produces a toxin, being deceptively marketed as monkfish. The accurate identification allowed public health officials to confirm that consumer illnesses accompanying this deception were caused by puffer fish toxin consumption. Similar to analytical techniques, supply chain understanding can help protect food manufacturers and consumers from food fraud. For example, major spice providers worked together to develop a guide to identification and prevention of adulteration because spices are often a target for adulteration. One aspect of the guide is a decision tree used to protect against supply chain vulnerabilities.

The conference also featured the authors of the FSMA Mitigation Strategies to Protect Against Intentional Adulteration Rule. They are part of the Food Defense and Emergency Coordination Staff at CFSAN. The author of the Intentional Adulteration rule discussed updated information on FDA efforts to develop both guidance for industry and training materials to support implementation of the regulation. In addition, they provided insight on the use of key activity types as an appropriate method for vulnerability assessments. For inspection and compliance, the authors indicated a two-step approach will be taken. The two-step approach will include a quick check at all registered facilities that is followed by a food defense inspection at a limited number of prioritized facilities. Inspection will occur in a tiered and staged approach after compliance dates pass. The FDA presentation at the Food Defense Conference was the launch of the new information campaign with additional detail and insight on guidance, training, inspection and vulnerability assessment approaches.

The knowledge and passion of the professionals gathered at the conference allowed appreciation of and connection between the incredible global efforts dedicated to improving defense and protection of the food system. The future of food defense to protect and create a resilient food system will be assured by continued efforts and expertise shared like those at this conference.

Food Fraud

Mitigating Food Fraud Is Complex, But Not Impossible

By Maria Fontanazza
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Food Fraud

Nearly 10% of the food supply is affected by food fraud, yet many food companies are not well equipped to deal with the problem, according to a survey cited by SSAFE at USP’s recent Food Fraud Mitigation Hands-on Workshop. Nearly 40% of companies said it is easy for fraudsters to fake their food products and about one-third named gaps in supply chain transparency as a fraud vulnerability problem. In addition, about one third of respondents were unaware of whether their suppliers have been part of a criminal offense.

How secure is your supply chain? Learn how to mitigate these risks at the Food Safety Supply Chain conference | June 5-6, 2017

Food fraud is defined as the intentional misrepresentation of the true identity or contents of a food ingredient or product for economic gain, said Janet Balson, senior food safety consultant at USP. In many cases, adulteration cannot be detected by visual inspection alone. Companies must look at the susceptibility of certain ingredients and products (common targets include olive oil, honey, milk, chicken, tea, spices and fish), potential economic gain, and vulnerabilities in the supply chain. Since only a small amount of fraud cases are detected, it is important to conduct a thorough vulnerability assessment that examines the supply chain, QA methods, testing frequency, audits, supplier history, and historical, geo-political and economic factors, and from there, a multi-disciplinary team can develop an appropriate control plan based on the level of risk.

Food companies can leverage several tools (they also work in a complementary fashion) to identify and assess potential hazards in ingredients and products, including EMAlert, USP’s Food Fraud Database 2.0 and SSAFE’s Food Fraud Vulnerability Assessment tool. Arcchana Patil, senior manager of food safety & defense, QRC at The Hershey Company and Samantha Cooper, manager of food safety & quality assurance at GMA compared several of these platforms, offering a few tips on their capabilities and how companies can make the best use of the tools.

  • USP Food Fraud Database 2.0: Contains almost 7,000 food fraud records and allows searching of records by ingredient. Helps in the process of evaluating food fraud vulnerability. Its customizable dashboard and search function update users on new records. The platform also provides automated analytics tools. The tool is best used by subject matter experts, a group or by food fraud and food defense teams.
  • EMAlert: A real-time predictive model for economically motivated adulteration that quantitatively analyzes vulnerability for a group of ingredients based on weights given by users. Commodity data for each attribute is continuously updated. It provides a good platform for commodity scanning for sourcing and procurement teams. The tool is best used by subject matter experts, a group or by food fraud and food defense teams.
  • SSAFE Food Fraud Vulnerability Assessment: Available in 10 languages, it provides a good starting point for companies to assess their vulnerability at an ingredient, product, brand, facility, country or company-wide level. It identifies vulnerabilities to enable mitigation, but it does not offer mitigation techniques. The tool can be applied throughout the supply chain, from feed and primary production to manufacturing and catering. It can be used by different segments of the supply chain, along with corporate, but it is best used by cross-functional teams in quality, lab, procurement, legal and manufacturing.
  • World Factbook of Food: With more than 130 foods and 75 country profiles, the Factbook data is curated from a variety of sources to assist in risk assessment. The repository of food and country profile contains product uses, consumption, production and trade information, along with population, economy, climate and governance.
  • Food Adulteration Incidents Registry: Containing more than 550 unique incidents of food fraud and intentional adulteration, the registry provides verified event information to support vulnerability assessments. The platform uses a repository of open data records.

The shortage of food due to climate, environmental and political changes will put further pressure on the availability of certain ingredients and is likely to cause an uptick in food fraud. However, there are more tools than ever before to help companies deal with this problem, but the key is to try to stay one step ahead. As the speakers and attendees at the USP workshop reflected on the issue, they shared their predictions on where they see food fraud headed in the near term:

  • Companies will need to use technology to push further into their supply chains (i.e., tier two or three) where there is a higher risk.
  • The implementation of blockchain technology will make it more difficult for fraudsters to fake data, especially with processed foods.
  • The food industry will be able to learn from other industries that have counterfeiting issues, such as the pharmaceutical industry.
  • Use of smarter complementary tools that fight food fraud will help companies better mitigate risks and intervene more swiftly.
Sean Crossey, arc-net
FST Soapbox

5 Problems Facing the Global Food Supply Chain

By Sean Crossey
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Sean Crossey, arc-net

The food we eat is a lot less secure than we would like to imagine. According to PricewaterhouseCoopers, food fraud is estimated to be a $40 billion a year problem, with instances of fraud becoming worryingly frequent—from wood shavings discovered in our parmesan to the 2013 horsemeat scandal in the UK.1-3 Not only do these incidents damage the faith consumers have in their food, but as seen in the 2009 salmonella peanut butter outbreak, which resulted in the death of 9 Americans and sickening of 714, they can have fatal consequences.4 Indeed, the World Health Organization estimates that nearly 1 in 10 people become ill every year from eating contaminated food.5

While it may be uncomfortable to imagine our food supply can be susceptible to such high profile attacks, what is more unsettling is that our food supply chain has grown so complex that it has become almost impossible for food producers to guarantee the provenance of their products—meaning consumers can never entirely trust in the food they eat. In this article I will identify five main issues the global food supply chain faces, and what steps can be taken to address them.

Exchange knowledge about managing your supply chain at the Best Practices in Food Safety Supply Chain conference | June 5–6, 2017 | LEARN MORE1. Consumer demand for traceability

Traceability is no longer a request from consumers, but a demand, and one that is only growing stronger. A recent transparency survey found that consumers want to see everything from a complete ingredient breakdown to sourcing information, with 94% of respondents saying they are likely to be more loyal to a brand that offers complete transparency.6 While a new study discovered that more than half of Canadians are concerned about food fraud.7

If we take seafood products as an example, almost half (46%) of respondents to an independent research survey conducted by the Marine Stewardship Council (MSC) agreed that they trust brands that use ecolabels (a form of third-party certification) more than those that do not.8 The survey also found that 66% of respondents felt that traceability of the product was the primary factor determining seafood purchasing decisions.

This kind of consumer driven, high-quality information opens up a world of possibilities for companies that recognize the significance of its demand. Brand protection, demand forecasting and consumer loyalty all becomes possible for early adapters who show themselves to be taking practical steps to guarantee the authenticity of their products.

2. Lack of communication between actors

One of the biggest challenges preventing full traceability of our food is the fragmented nature of the supply chain. For even the most seemingly simple of food items there can be a huge number of actors involved that are spread around the globe with little to no knowledge of one another’s actions.

For instance, to trace your hamburger from farm to fork may involve tracing your lettuce back to the farm in which it was grown (but not what happens to it before it reaches your supermarkets shelves), tracing the beef back to the cattle (with no guarantee, as seen with the horsemeat scandal, that the end product is 100% beef) and any number of logistical barriers.

It is vital then that stakeholders within the chain prioritize communication with their suppliers, either through the implementation of traceability solutions, or the commitment to engage only with suppliers they know they can trust. Not only is this beneficial to the end consumer, but to the food producers themselves, allowing them to ensure that their organizational reputation remains solely their responsibility and not left in the hands of unknown and uncontrollable third parties.

3. Influence of organized crime

When one thinks of the Mafia, it’s rare that olive oil is the first thing that comes to mind. Currently, however, it is the fraudulent manufacture of this and many other Italian exports (cheese, wine, etc.) that is fueling organized crime and ending up on our shelves.9

High-scale food fraud is not a naturally occurring phenomenon but rather exists as a result of highly organized criminal activity. In his 2014 UK government report, Professor Chris Elliot notes that “food fraud becomes food crime when it no longer involves random acts by “rogues” within the food industry, but becomes an organized activity by groups that knowingly set out to deceive and or injure, those purchasing food”.10

This is not just a problem for Italy; counterfeit food and drink occurs on a massive scale throughout the whole of Europe. A joint initiative by EUROPOL and INTERPOL last year led to the largest ever seizure of fake and adulterated projects. This project, known as OPSON V resulted in 11,000 tons and 1,440,000 liters of hazardous fake food and drink seized across 57 countries.11

In order to combat the growing threat organized crime has on our food supply, it is vital that governments devote resources to organizations with the sole responsibility of identifying food crime. In response to the horsemeat scandal, the UK government launched its National Food Crime Unit within the Food Standards Agency in London, while the FDA has a special focus on food defense.

The establishment of these organizations is important, as police forces traditionally have struggled to combat food fraud, either through a lack of time, resources, or simply understanding of the complexities of how fraud affects the supply chain. The creation of specialist taskforces not only legitimizes the fight against food fraud, but allows for easier intelligence share.

4. Lack of transparency throughout the supply chain

In her work on trust for the digital age, Racheal Botsman tells us that trust has evolved from an institutional based system to a distributed system. Nowhere has this more potential than with our food supply.

In such a complex system it becomes necessary to consider how the food industry can begin to move away from traditional systems of centralized trust. As Botsman points out, “institutional trust is not designed for the digital age”, the emergence of new technologies, most notably the blockchain, highlights the potential to introduce more trust in our food.12

Originally the technology underpinning Bitcoin, the blockchain has wide ranging applications beyond the world of FinTech. Blockchain is a transformative tool in the fight against food fraud, allowing an open and transparent ledger of our food products journey. This allows unalterable trust to be introduced into an untrustworthy system, ensuring every actor in the chain records and shares their interactions with our food.

This represents a huge opportunity for those companies who see the advantage of early adoption of blockchain infused traceability systems. Indeed by 2022, Gartner estimates an innovative business built on a blockchain will be worth $10 billion.13

5. Need for strong legislation

Steps have already been made in legislation to allow for earlier prevention of food safety incidents occurring, such as FSMA. While it is important that lawmakers are proactive in their response, the focus has primarily been on food safety, and there is still a difficulty in treating food fraud as its own separate entity.

Legislation regarding food labelling could also be more stringent, especially in Europe. At present only olive oil, fish (unless it’s canned or prepared), beef (fresh, chilled, frozen or minced), fresh or frozen poultry of non-EU origin, wine, most fresh fruit and vegetables, honey and eggs are required to be labelled. This means that origin information is largely missing on foods such as meat products (e.g., ham and sausages), yogurts and cheese, kitchen staples (e.g., oil, flour, sugar and pasta), biscuits and confectionery, or ready-meals.

Tighter legislation, leading to significant punitive measures taken against actors found to be committing fraud, would be a vital catalyst in ensuring that food in our supply chain is as secure as possible.

Conclusion

The growth of the global food supply chain may bring with it complexity and challenges, but also great opportunities. If actors can interject their processes with the kind of joined up thinking outlined above, with the help of technological tools that are becoming more and more accessible, the benefits will be significant, not just for them, but for all of us.

Resources

  1. PWC. (2016). Fighting $40bn food fraud to protect food supply [Press Release]. Retrieved from http://press.pwc.com/News-releases/fighting–40bn-food-fraud-to-protect-food-supply/s/44fd6210-10f7-46c7-8431-e55983286e22
  2. Mulvany, L. (February 16, 2016). The Parmesan Cheese You Sprinkle on Your Penne Could Be Wood. Retrieved from https://www.bloomberg.com/news/articles/2016-02-16/the-parmesan-cheese-you-sprinkle-on-your-penne-could-be-wood
  3. Grierson, J. (August 26, 2016). Three men charged over UK horsemeat scandal. Retrieved from https://www.theguardian.com/uk-news/2016/aug/26/three-men-charged-over-uk-horsemeat-scandal
  4. Andrews, J. (April 16, 2016). 2009 Peanut Butter Outbreak: Three Years On, Still No Resolution for Some. Retrieved from http://www.foodsafetynews.com/2012/04/2009-peanut-butter-outbreak-three-years-on-still-no-resolution-for-some/#.WD7tE6KLTpJ
  5. World Health Organization. (2015). WHO’s first ever global estimates of foodborne diseases find children under 5 account for almost one third of deaths [Press Release] Retrieved from http://www.who.int/mediacentre/news/releases/2015/foodborne-disease-estimates/en/
  6. Label Insight (2016). The 2016 Label Insight Transparency ROI Study. Retrieved from https://www.labelinsight.com/hubf /2016_Transparency_ROI_Study_Label_Insight.pdf?t=1486676060862
  7. Sagan, A. (February 21, 2017). Study finds 63 per cent of Canadians are concerned about food fraud. Retrieved from http://www.theglobeandmail.com/news/national/study-finds-63-per-cent-of-canadians-are-concerned-about-food-fraud/article34094664/
  8. MSC (2014). MSC Consumer Survey 2014. Retrieved from https://www.msc.org/newsroom/news/new-research-shows-increasing-appetite-for-sustainable-seafood
    Bacchi, U. (February 21, 2017). Italian police break mafia ring exporting fake olive oil to U.S. Retrieved from http://www.reuters.com/article/us-italy-crime-food-idUSKBN1602BD
  9. HM Government (2015) Elliot Review into Integrity and Assurance of Food Supply Networks. Retrieved from https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/350726/elliot-review-final-report-july2014.pdf
    EUROPOL (2016) largest ever seizures of fake food and drink in INTERPOL-EUROPOL operation [Press Release]. Retrieved from https://www.europol.europa.eu/newsroom/news/largest-ever-seizures-of-fake-food-and-drink-in-interpol-europol-operation
  10. Botsman, R. (October 20, 2015). The Changing Rules of Trust in the Digital Age. Retrieved from https://hbr.org/2015/10/the-changing-rules-of-trust-in-the-digital-age
  11. Panetta, K. (October 18, 2016) Gartner’s Top 10 Strategic Technology Trends for 2017. Retrieved from http://linkis.com/www.econotimes.com/Zk8mh
Food Fraud

Using Data to Prevent Food Fraud

By Maria Fontanazza
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Food Fraud

The FDA Food Safety Modernization Act (FSMA) Preventive Controls for Human Food rule is now final, and compliance dates for some businesses began in September 2016.  Economically Motivated Adulteration (EMA) or food fraud is a component in the Preventive Controls Rule.  As the global supply chain becomes more complex, preventing EMA and compliance to Preventive Controls for Human Food rule can be a challenging task.

A food company’s supply chain can be the weakest link in their food safety program. Learn strategies and how to mitigate risks at the Food Safety Supply Chain Conference | June 4–5, 2017 | Rockville, MD, LEARN MORELast year GMA and Battelle released EMAlert, a tool that enables quantitative evaluation of a company’s supply chain to economically motivated adulteration. USP also provides a platform to help companies with food fraud mitigation strategies. In a Q&A with Food Safety Tech, experts from the USP Food Program, Jeff Moore, Ph.D., science director and Karen Everstine, Ph.D., scientific liaison explain how the Food Fraud Database 2.0 works and how it can help companies with FSMA compliance.

Food Safety Tech:  How does the Food Fraud Database 2.0 assist food companies in identifying hazards and vulnerabilities?

Jeff Moore, Ph.D.: We reengineered the database [previously Food Fraud Database 1.0] from the ground up, including the structure of the data. Users wanted not just a source of high quality data to inform of risks and vulnerabilities that were related to food fraud but also some ability to analyze the information and get alerts and real-time information to figure out what to do in real time.

Karen Everstine, USP Food Program
Karen Everstine, Ph.D., USP Food Program

Karen Everstine, Ph.D.: Since it was reengineered, we’ve been able to include a lot of fields that allow food companies to tailor their results to information that is most applicable to them (i.e., geographic location). Automated analytics give a visual of what’s happening to see trends more quickly.

Moore: We have a team of dedicated analysts that are constantly scouting the public domain and looking for information globally to add to the database to make sure it’s the most comprehensive, up-to-date global database of food fraud information.

FST: What tools within FFD 2.0 can help companies with FSMA compliance?

Everstine: One of the things in the FSMA PC rule is the fact that food companies now have to identify potential hazards, whether they are intentional or unintentional, which includes food fraud-related hazards. One of the tools we built into the database is an EMA (Economically-Motivated Adulteration) hazard identification report. It allows users to input a list of their ingredients (those sourced and brought into the facility to create a finished food product), and then the report output identifies which ingredients are associated with potential hazards (i.e., adulterants that might pose a health threat to consumers). That’s the main tool we’ve built to target FSMA compliance.

Moore: One of the key parts of the PC rule as related to EMA is a question of whether the ingredient has a history of association with potentially hazardous adulterants. We put together an expert panel at USP and Karen [Everstine] was responsible for working with the panel to develop a classification system to identify adulterants that are potentially hazardous.

FSC 2016

FSMA, Listeria, Fraud and Food Safety Culture Among Top Topics at Food Safety Consortium

By Maria Fontanazza
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FSC 2016

The 2016 Food Safety Consortium was a big success, from the preconference events that included the STOP Foodborne Illness fundraiser honoring heroes in food safety and the education workshops (SQF Information Day and preventive controls courses) to the record-breaking attendance we saw during the main program (with keynotes from FDA Deputy Commissioner for Foods and Veterinary Medicine Stephen Ostroff, M.D., Walmart’s Vice President of Food Safety Frank Yiannas, and FBI’s Special Agent Scott Mahloch).

As the event winded down, the leaders of each session track shared their insights on lessons learned during the Consortium.

Understanding biofilm and how it forms.  If you’re seeing peaks and valleys in the positives and negatives in your environmental swabbing program, you may have resident Listeria that has formed a biofilm, which requires a deep clean. Focus on biofilm, not just mitigation of the Listeria bacteria itself. – Gina Kramer, Savour Food Safety International. Read Gina’s column, Food Safety Think Tank, where she talks about the latest technology and innovations.

This is the first conference I’ve been to you where food fraud is being more widely acknowledged as a serious, important concern that is distinctly separate from food safety. One of the more significant takeaways is the number of tools that are now available for people to mitigate their risk to food fraud in the supply chain. – Steve Sklare, USP

Warren Hojnacki, SGS
Warren Hojnacki, SGS

A while back food safety was a nice-to-have but not a need-to-have. It’s certainly an absolute need-to-have now. There are three groups of individuals out there: The third that has picked up the baton and is proactive, the other third that are in the middle of it right now, and the other third have their heads in the sand. I come across a sizable portion that is in the bottom third, and it’s slightly scary… It’s the documentation that a lot of companies are having the biggest challenge in dealing with—the death by paper. The resources out there are immense. It’s a necessity to have right now in order to be effective and compliant.  – Warren Hojnacki, SGS

FSMA regulations require us to be risk based, scientifically based and systematic in our approach to our concerns and issues. – Barb Hunt, Savour Food Safety International

There’s potential for greater data and actions: i.e., the microbiome study or particulate contamination analysis, PLM, IR spectroscopy, SEM EDS, [and] raman spectroscopy…Lab customers may need to depend more greatly on contract labs as FSMA develops and in return, labs need to work more closely with the customers to get dependable, defensive data results. – Eric Putnam, Wixon, Inc.

Trish Wester, PA Wester Consulting
Trish Wester, PA Wester Consulting

We need to do a better job of messaging upstream to our corporate senior officials so we get the money and resources we need—there’s still a gap there. We need to find ways to communicate to them.  – Trish Wester, PA Wester Consulting

USP

The U.S. Pharmacopeial Convention (USP)

USP

USP improves global health through public standards and related programs to help ensure the quality and safety of medicines and foods. USP’s Food Safety and Integrity Solutions, which include the Food Chemicals Codex with more than 1,200 standards (methods and specifications), food ingredient reference materials, the Food Fraud Database v2.0, and food fraud mitigation training and advising services help ensure the quality, safety, and integrity of the food supply and help companies meet regulatory requirements and mitigate supply chain risk.

EMAlert, Economically motivated adulteration

Food Fraud: Perps Two Steps Ahead, Innovation Needed to Keep Up

By Maria Fontanazza
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EMAlert, Economically motivated adulteration

Economically motivated adulteration (EMA) has considerable economic ramifications, impacting businesses from a financial and liability perspective, posing dangers to consumers, and eroding product confidence. One of the biggest issues with monitoring the volume and type of adulterated products is the fact that the landscape of food fraud is ever changing. “The perpetrators are always two steps ahead, so innovation is needed to keep up,” said Jeff Moore, Ph.D., director of science, food program at U.S. Pharmacopeial Convention (USP), at the GMA Science Forum last week.

GMA and Battelle have teamed up to launch EMAlert, a tool that companies can use to quantitatively assess the vulnerability of their supply chains to EMA. The secure, cloud-based platform comes with 50 commodities off the shelf (including spices, grains, dairy, seafood, meat, oils, fruits, veggies, and food ingredients). It was developed fairly rapidly (Battelle, which serves as the technology provider, started development at the beginning of this year) and still needs to be validated; full validation will be presented at the IAFP meeting this summer. And if EMAlert lives up to its potential, it could help companies be more nimble in monitoring and acting on threats in their supply chain.

The purpose of the tool is to generate quantitative vulnerability results that allow people to make actionable decisions based on numeric values. As such, it has been designed to be dynamic and customizable, since every company has its own risk tolerance. In addition, it looks at real-time environmental changes, because you can’t have a static tool to monitor vulnerability when it’s always changing, said Joseph A. Scimeca, Ph.D., vice president, global regulatory & scientific affairs at Cargill, Inc.

EMAlert, Economically motivated adulteration
A screenshot of EMAlert

“The EMA threat is changing,” said Ashley Kubatko, principal research scientist at the Battelle Memorial Institute. “A static assessment is only a snapshot in time.” EMAlert pulls live, automated data that takes into account economic drivers (value, volume, and scarcity of product), historical drivers (how often has product adulteration occurred in the past, geopolitical stability), and ease drivers (how frequently the commodity is tested; whether there are government regulations around the commodity group; how often the product changes hands or is repackaged). Data is pulled from several databases, including FDA, UN Comtrade, USP, Quandi, and Transparency International.

When creating the tool Battelle borrowed from its approach in working with the U.S. Department of Homeland Security to develop models that predict terrorist decision making and used the same mathematical methodology, providing a predictive model of fraudster behavior. Keeping in mind that perpetrators are also constantly monitoring how law enforcement and industry is keeping track of their strategies, EMAlert not only requires a subscription, but Kubatko says that Battelle will also be monitoring its users to ensure there is no suspicious activity within EMAlert.

John Ryan, Ryan Systems, Inc.
FST Soapbox

Substituted Ingredients Are Only the Tip of the Iceberg

By John M. Ryan, Ph.D.
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John Ryan, Ryan Systems, Inc.

While the United States has no legal definition of food fraud, current thinking tends to be focused primarily on companies and products involved in the illegal substitution of one ingredient for another in a product. Such substitution generally involves substituting a cheap filler in the place of the labeled ingredient. In recent news, Parmesan and Romano cheeses have captured news headlines because of illegal “misbranding” of foods meaning that the label on shredded cheeses from companies like the Castle Cheese, Inc. company in Slippery Rock, PA include ingredients found through FDA testing that are included in percentages beyond allowable levels. In the case of shredded cheeses, so called “imitation” cheese better is known as wood pulp. The labels stated that the ingredients were 100% cheese.

Perhaps Slippery Rock is an apt name for the Castle Cheese operation where the inclusion of wood pulp was cheaper than the inclusion of real parmesan cheese. Such activities are becoming increasingly known as “economically motivated” and the practice is one of economically motivated adulteration. The FSMA final rule, Focused Mitigation Strategies to Protect Food Against Intentional Adulteration, will make these practices illegal.

Such intentional cheating has a long record in the history of food. No one really knows the extent of such food fraud activities, when they started (perhaps at the beginning of time?), or who could claim to be the first person to win an international award for creativity.

There are so many ways to commit food fraud that it boggles the mind and creates an almost complete inability on the part of governments, testing laboratories, food processors, retailers and the public to identify, let alone fully prevent and capture the guilty every single time.

Think about a few things. Is it fraudulent to leave the identification of GMO ingredients off of labels? If a packer knowingly packs a product in dirty packaging, is that practice fraudulent? If the food safety part of the government knows how high the levels of fecal coliform are on most of the produce we eat but does not acknowledge the problems or inform the public, is this practice fraudulent? How about the idea that a retail outlet replaces an “expired” label on hamburger with a new unexpired label? Or how about the time Sysco was shipping perishable foods in refrigerated trucks and storing eggs, milk, meat, chicken and other products in the same storage sheds where you might keep leftover junk from your garage? Do “Good Things Come From Sysco”?

But none of those examples have anything to do with intentionally substituting a cheaper ingredient for an ingredient on the label. Honey, olive oil, coffee, juices, fish, alcohol, milk and dairy products, fish, vitamins, meat, spices, organic foods, maple syrup, peanut product, flavorings, preserves, cereals, colorings, wines, vinegar, purees, sweeteners ,and other ingredients are involved. And food fraud occurs in manufacturing, processing, packing and food holding operations. Such large opportunities for all foods in all operations means the entire food chain is—at one time or another, in one place or another—suspect.

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The Grocery Manufacturers Association (GMA) estimates that food fraud may cost the global food industry between $10 billion and $15 billion annually with lost sales between 2% and 15%. They estimate that approximately 10% of all commercial food products are impacted.

Considering the fact that the food industry claims their profit margins are only a few percent, it would seem that if they wanted to reduce food costs, food fraud would surely be a prime business improvement target. And GMA, unfortunately, is also focused on economically motivated adulteration such as unapproved additives, mislabeling, counterfeit ingredients, transshipment (shipping from one country to another to repackage and relabel in order to avoid taxes), and dilution.

When a consumer enters a supermarket in search of fresh meat, poultry or fish to cook for dinner, he or she knows little about how those products were packaged. Adding water to the pad that is often inserted under the meat to soak up blood, adds weight to the scale and money to the price. Packing the meat using carbon monoxide is common in order to “preserve” the product color. Red meat should look red, right? While the FDA considers this practice generally recognized as safe (GRAS), studies regarding how carbon monoxide interacts with the foam packaging and the clear plastic wrap covering the package are nonexistent. What makes the practice deceptive is the lack of information on the label that tells consumers carbon monoxide is used to preserve color. Of equal importance are recent studies that clearly show that many of the plastics used in today’s food packaging operations contain toxic chemicals shown to be dangerous to humans.

Interestingly enough, the European Union has a definition of food fraud:

‘Food fraud is a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain’.

After the monster European horsemeat scandal (remember that one?) in which horse meat was substituted for beef to the embarrassment of many companies, such as Burger King and Ikea, the United Kingdom promised proactive solutions from food laboratories and improving supply chain audits in an effort to slow and diminish the number of incidents reported annually.

In the United States, we frequently point to the melamine (milk substitution) in baby formula or the pet food problems that came out of China as evidence that foreign companies are primarily to blame for food fraud. Coupled with governmental trade agreements and the attitude that other countries are dumping substandard product on American consumers, it seems easy to blame others for food fraud –except for the fact that we in America are dealing with so many incidents.

The problem with our inability to tackle food fraud in part comes from the gap between our ability to identify and develop appropriate and targeted food ingredient testing capabilities. So many types of food, so many types of tests, so many types of ingredients, and so many types of ways to intentionally or accidentally cheat the system all combine to confuse and confound our efforts to quickly and economically establish detection systems.

In most food distribution arenas, food traceability systems are slowly being agreed upon and implemented. However, the FDA does not seem to be able to help with establishing data and other standards that would help establish traceability requirements designed to quickly and accurately get to the source suppliers in food fraud events. Other industries under FDA medical device and drug laws have worked to establish solid chain of custody systems. Chain of custody implies that the suppliers and handlers are legally responsible and clearly identified. Leadership in this area is clearly needed.

While there are many good resources evolving both within and outside of the United States, those resources are scarce and relatively immature. It seems that without some basics, such as legal definitions, standardized testing practices, and an agreement that food fraud is much more than substitution of one ingredient for another, we have a very long way to go if we expect to get the food fraud system under control.