Supporting small and very small plants via trying to take the cost burden off these establishments. The agency lowered overtime and holiday inspection fees for small establishments by 30% and by 75% for very small establishments.
Proposed rulemaking related to the labeling of meat and poultry products that are comprised of or contain cultured cells from animals.
Review of “Product of USA” labeling.
Collaboration with public health partners that include the FDA and CDC. The agencies signed a Memorandum of Understanding to enable more efficient use of resources.
It is fair to say that 2020 was a challenging year with wide-ranging effects, including significant effects on our ongoing efforts to ensure food integrity and prevent fraud in the food system. COVID-19 caused major supply chain disruptions for foods and many other consumer products. It also highlighted challenges in effective tracking and standardization of food fraud-related data.
Let’s take a look at some of the notable food fraud occurrences in 2020:
Organic Products. The Spanish Guardia Civil investigated an organized crime group that sold pistachios with pesticide residues that were fraudulently labeled as organic, reportedly yielding €6 million in profit. USDA reported fraudulent organic certificates for products including winter squash, leafy greens, collagen peptides powder, blackberries, and avocados. Counterfeit wines with fraudulent DOG, PGI, and organic labels were discovered in Italy.
Herbs and Spices. Quite a few reports came out of India and Pakistan about adulteration and fraud in the local spice market. One of the most egregious involved the use of animal dung along with various other substances in the production of fraudulent chili powder, coriander powder, turmeric powder, and garam masala spice mix. Greece issued a notification for a turmeric recall following the detection of lead, chromium, and mercury in a sample of the product. Belgium recalled chili pepper for containing an “unauthorized coloring agent.” Reports of research conducted at Queen’s University Belfast also indicated that 25% of sage samples purchased from e-commerce or independent channels in the U.K. were adulterated with other leafy material.
Dairy Products. India and Pakistan have also reported quite a few incidents of fraud in local markets involving dairy products. These have included reports of counterfeit ghee and fraudulent ghee manufactured with animal fats as well as milk adulterated with a variety of fraudulent substances. The Czech Republic issued a report about Edam cheese that contained vegetable fat instead of milk fat.
Meat and Fish. This European report concluded that the vulnerability to fraud in animal production networks was particularly high during to the COVID-19 pandemic due to the “most widely spread effects in terms of production, logistics, and demand.” Thousands of pounds of seafood were destroyed in Cambodia because they contained a gelatin-like substance. Fraudulent USDA marks of inspection were discovered on chicken imported to the United States from China. Soy protein far exceeding levels that could be expected from cross contamination were identified in sausage in the Czech Republic. In Colombia, a supplier of food for school children was accused of selling donkey and horse meat as beef. Decades of fraud involving halal beef was recently reported in in Malaysia.
Alcoholic Beverages. To date, our system has captured more than 30 separate incidents of fraud involving wine or other alcoholic beverages in 2020. Many of these involved illegally produced products, some of which contained toxic substances such as methanol. There were also multiple reports of counterfeit wines and whisky. Wines were also adulterated with sugar, flavors, colors and water.
We have currently captured about 70% of the number of incidents for 2020 as compared to 2019, although there are always lags in reporting and data capture, so we expect that number to rise over the coming weeks. These numbers do not appear to bear out predictions about the higher risk of food fraud cited by many groups resulting from the effects of COVID-19. This is likely due in part to reduced surveillance and reporting due to the effects of COVID lockdowns on regulatory and auditing programs. However, as noted in a recent article, we should take seriously food fraud reports that occur against this “backdrop of reduced regulatory oversight during the COVID-19 pandemic.” If public reports are just the tip of the iceburg, 2020 numbers that are close to those reported in 2019 may indeed indicate that the iceburg is actually larger.
Unfortunately, tracking food fraud reports and inferring trends is a difficult task. There is currently no globally standardized system for collection and reporting information on food fraud occurrences, or even standardized definitions for food fraud and the ways in which it happens. Media reports of fraud are challenging to verify and there can be many media reports related to one individual incident, which complicates tracking (especially by automated systems). Reports from official sources are not without their own challenges. Government agencies have varying priorities for their surveillance and testing programs, and these priorities have a direct effect on the data that is reported. Therefore, increases in reports for a particular commodity do not necessarily indicate a trend, they may just reflect an ongoing regulatory priority a particular country. Official sources are also not standardized with respect to how they report food safety or fraud incidents. Two RASFF notifications in 2008 following the discovery of melamine adulteration in milk illustrate this point (see Figure 1). In the first notification for a “milk drink” product, the hazard category was listed as “adulteration/fraud.” However, in the second notification for “chocolate and strawberry flavor body pen sets,” the hazard category was listed as “industrial contaminants,” even though the analytical result was higher.1
What does all of this mean for ensuring food authenticity into 2021? We need to continue efforts to align terminology, track food fraud risk data, and ensure transparency and evaluation of the data that is reported. Alignment and standardization of food fraud reporting would go a long way to improving our understanding of how much food fraud occurs and where. Renewed efforts by global authorities to strengthen food authenticity protections are important. Finally, consumers and industry must continue to demand and ensure authenticity in our food supply. While most food fraud may not have immediate health consequences for consumers, reduced controls can lead to systemic problems and have devastating effects.
Everstine, K., Popping, B., and Gendel, S.M. (2021). Food fraud mitigation: strategic approaches and tools. In R.S. Hellberg, K. Everstine, & S. Sklare (Eds.) Food Fraud – A Global Threat With Public Health and Economic Consequences (pp. 23-44). Elsevier. doi: 10.1016/B978-0-12-817242-1.00015-4
It is being speculated that the short-term decline in the number of food and beverage recalls this year is due to less regulatory oversight as a result of the COVID-19 pandemic. During Q3, FDA food recall activity was up 34% compared to last quarter, but this increase is actually a sign of things returning to normal on the side of regulatory oversight activities, according to the latest Q3 Recall Index from Stericycle.
FDA Food Recalls: Notable Numbers (Q3 2020)
Undeclared allergens: 56 recalls, accounting for nearly 53% of all recalls; the top cause of an FDA food recalls for the 13th consecutive quarter
Bacterial contamination: Accounting for 62% of recalled units, this was the top cause of recalled units with Salmonella being the most common contaminant (the pathogen was responsible for 17 out of 24 recalls)
Foreign materials, quality and mislabeling were the other reasons for recalls
USDA Recalls: Notable Numbers (Q3 2020)
Undeclared allergens: Top cause of recalls; 6 recalls accounted of nearly 70% of all recalled pounds
A single meat and poultry recall affected more than 242,000 pounds (63%) of all recalled pounds
The average recall affected 38,000 pounds
Over the last three quarters, recalls have been at record low levels
Quarterly recall activity is averaging 8.3 recalls a quarter versus an average quarterly volume of more than 30 recalls over the last five years
The COVID-19 crisis has led to supply chain management challenges for food manufacturers and processors, ingredient suppliers and vendors, and regulators. In its Q1 2020 Recall Index, experts from Stericycle advise that companies use this time to take a closer look at their supply chain processes and reevaluate their recall plan.
Seafood is a never-ending target for defrauding restaurant and store customers. At an Italian restaurant chain in the UK, a lobster and king prawn dish contained more than one-third white fish in addition to other filler ingredients to lower cost. The dish was shaped to represent lobster meat. No health or safety issues were reported, however, this is yet another example where significantly cheaper ingredients were used to defraud customers. The company made almost $4 million in revenue over the course of several years from this dish alone.
The following infographic is a snapshot of the hazard trends in meat and meat products from Q3 2019. The information has been pulled from the HorizonScan quarterly report, which summarizes recent global adulteration trends using data gathered from more than 120 reliable sources worldwide. Over the next several weeks, Food Safety Tech will provide readers with hazard trends from various food categories included in this report.
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.
Use of sulphites in food is tightly regulated in the Netherlands. “Vleesfraude” or meat fraud was committed by Dutch meat processors and butchers by adding large amounts of sulphites to ground beef, sausages and other processed meats in order to achieve the perfect “meaty” red color. Sulphites are classified as an allergen with mandatory labeling requirements, however, their use in meat is illegal in the first place. The affected products were pulled from the market and the companies were fined for fraud.
Fresh beef adulterated with sulphur dioxide was found in a Hong Kong market by the Centre of Food Safety. The adulteration of fresh or chilled meat with sulphur dioxide carries hefty penalties of fines and even prison time. Sulphur dioxide is a widely used preservative and antioxidant for foods and beverages that include dried fruits, processed meat products such as sausages, soft drinks and alcoholic beverages. The substance is harmless to healthy persons, however, in subjects with a sulphur dioxide allergy, breathing difficulties and asthma can be induced.
Centre for Food Safety (April 10, 2019). “Fresh beef sample found to contain sulphur dioxide” Centre for Food Safety, The Government of the Hong Kong Special Administrative Region. Accessed April 10, 2019. Retrieved from https://www.cfs.gov.hk/english/press/20190410_7408.html
People like to ask “what is the next melamine?” Of course, this is an impossible question to answer. However, methods of perpetrating food fraud are rarely novel. Even melamine had a history of use in feed products for nitrogen enhancement.
Examples of recurring food fraud in recent history include:
Herbs and spices: High-value commodities, especially when sold in dried, flaked or ground form, have been targets of fraud for ages. Although recent work looking specifically at oregano shed new light on the problems in that particular herb, the group as a whole is long known to be prone to substitution with other plant material and addition of dyes to improve color. Lead chromate and lead oxide have both been used in spices to add color. A recent study in the United States conducted testing on spices recovered from the homes of children diagnosed with lead poisoning and determined that some lead poisoning cases can be attributed to high levels of lead in spices consumed by children.
Milk: Milk has been repeatedly prone to the addition of protein-mimicking compounds such as urea, the addition of other fats such as vegetable oil, and the addition of preservatives such as formaldehyde. Melamine addition to milk discovered in 2008 was not entirely novel. The addition of melamine to artificially enhance the apparent protein content of a product was documented in scientific papers in the 1980s.1
Liquor: Alcoholic beverages are also a high-value target, especially if they are a popular brand. Counterfeit alcohol is a common form of food fraud cited in the Food Fraud Database. Unfortunately, the use of methanol in unregulated liquor production repeatedly results in illnesses and deaths in consumers.
What forms of food fraud will be common in the coming years? Millennials reportedly place value on sustainability, convenience, high protein, and production practices such as organic and “local.” Verifying claims around production practices through long food supply chains is notoriously challenging. Increasing interest by consumers in these types of label claims may increase this type of fraud in the future.
Bisaz, R., and A. Kummer. “Determination of 2, 4, 6-triamino-1, 3, 5-triazine (melamine) in potatoe proteins.” Mitt. Gebiete Lebensm. Hyg 74 (1983): 74-79.
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