Tag Archives: regulatory

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FDA Warns Industry on Food Safety Risks of Transferring Genes for Proteins that are Food Allergens

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The FDA has issued a letter to developers and manufacturers of new plant varieties who intend to transfer genes for proteins that are food allergens (including allergens from foods identified as major food allergens) into new plant varieties used for food. The purpose of the letter is to remind them of the relevant legal requirements for these products, which may include adding a gene for an allergenic animal protein to a new plant variety to provide a non-animal source of the protein for use as an ingredient in another food.

While the agency noted that it is not aware of any foods currently in the U.S. market derived from these types of new plant varieties, it is aware of research and development in this area.

The FDA is asking developers to consider the food safety risks posed by such allergens and plan early in development to manage those risks, including the potential for recalls due to undeclared allergens.

“We are specifically reminding those developers who are now exploring development of these types of plant varieties of their responsibility for food safety. In particular, we are reminding them to consider the allergenicity issues related to their products, and how they would be stewarded from production to manufacturing to consumption so that they do not inadvertently or unexpectedly enter the food supply,” the FDA stated. “We are also reminding them that they need to be properly labeled when intentionally part of the food supply.”

To reduce risk to consumers as well as the risk of recalls, the FDA is encouraging developers of new plant varieties to consult with the agency through its voluntary premarket consultation program for foods from new plant varieties prior to marketing.

 

 

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FDA Calls for Enhanced Powdered Infant Formula Safety Measures in Letter to Industry

By Food Safety Tech Staff
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On March 8, the FDA sent a letter to manufacturers, packers, distributors, exporters, importers, and retailers involved in the manufacturing and distribution of powdered infant formula to share current safety information and call on the industry to take prompt action to improve processes and programs for the protection of our infants.

The agency notes that since the 2022 infant formula recalls and resulting shortages, it has been working to improve the resiliency of the infant formula supply by issuing multiple guidance documents intended to help facilitate the availability of safe and nutritionally adequate products in the U.S. marketplace through the exercise of enforcement discretion. The FDA has also taken steps to enhance the safety of powdered infant formula through the development of a Cronobacter prevention strategy, enhanced inspectional activities, increased engagement with the infant formula industry, and by pursuing regulatory action when appropriate.

In addition, over the past two months, food safety staff have been meeting regularly with manufacturers to further develop the prevention strategy to help prevent Cronobacter illness associated with consumption of powdered infant formula. The letter sent to manufacturers reflects the information the agency gained through interactions with industry as well as the latest available science on improving the microbiological safety of powdered infant formula.

The FDA called on members of the infant formula industry to use the information in the letter to take prompt action to improve processes and programs for the protection of infants. In addition to this call to action, Congress recently added new requirements for manufacturers aimed at mitigating supply chain disruptions through mandatory shortage notifications and risk management plans.

 

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From the Editor’s Desk

FDA Proposes Redesign of Human Foods Program

By Food Safety Tech Staff
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On January 31, Robert M. Califf, M.D., MACC, FDA Commissioner of Food and Drugs shared a proposal for a unified Human Foods Program that would combine the Center for Food Safety and Applied Nutrition (CFSAN), Office of Food Policy and Response (OFPR) and certain functions of the Office of Regulatory Affairs (ORA) under one leader.

The new model was proposed in response to the findings of an external evaluation of the FDA Foods program conducted by an expert panel of the Reagan-Udall Foundation and a separate internal review of the agency’s infant formula supply chain response completed last year.

The Reagan Udall evaluation identified several concerns, including lack of communication, lack of a clear vision and mission, lack of a clear, overarching leader, and siloed workers within the FDA’s Human Foods program. The panel also found that the FDA Human Foods program was ill defined with multiple agencies, including CFSAN, OFPR and OVA, working independently of each other, often with separate leadership and little sharing of information. It recommended creating a new Federal Food Administration under HHS that would operate parallel to, rather than under the auspices of, the FDA.

In his statement announcing the proposal for a more unified Human Foods program, Califf highlighted the issues identified by these independent reviews, including problems with the current culture, structure, resources, and authorities in the FDA Human Foods program.

“Today I am announcing a new, transformative vision for the FDA Human Foods Program. I am also announcing a transformative vision for the Office of Regulatory Affairs (ORA, the FDA’s field-based operations) to support the FDA organization as a whole. The proposed structures for both groups will have clear priorities that are focused on protecting and promoting a safe, nutritious U.S. food supply that more quickly adapts to an ever-changing and evolving environment,” said Califf.

The “Vision for a Reimagined Human Foods Program” includes the recommendation to create a Human Foods Program under a single leader who reports directly to the Commissioner. Under this plan, the functions of the Center for Food Safety and Applied Nutrition (CFSAN), Office of Food Policy and Response (OFPR), as well as certain functions of ORA will be unified into a new organization called the Human Foods Program.

“The FDA will conduct a competitive national search for a Deputy Commissioner for Human Foods, who will oversee the Program. The person in this position will report directly to me and will be charged with leading a unified Human Foods Program that keeps the foods we regulate safe and nutritious, while ensuring the agency remains on the cutting edge of the latest advancements in science, technology, and nutrition,” said Califf. “The Deputy Commissioner will have decision-making authority over policy, strategy, and regulatory program activities within the Human Foods Program, as well as resource allocation and risk-prioritization.”

Other key elements of the proposed new Human Foods Program include:

  • Creation of a Center for Excellence in Nutrition that prioritizes the agency’s ongoing efforts to help American consumers make more informed food choices, including by working with industry to offer healthier, more nutritious food products.
  • Establishment of an Office of Integrated Food Safety System Partnerships that will focus on elevating, coordinating and integrating the FDA’s food safety and response activities with state and local regulatory partners to more effectively meet the vision of an Integrated Food Safety System in the FDA Food Safety Modernization Act of 2011.

The proposed program would also include the establishment of a Human Foods Advisory Committee made up of external experts who will advise the agency on challenging and emerging issues in food safety, nutrition and innovative food technologies.

“Finally, there will be an emphasis on strengthening our enterprise information technology and analytical capabilities to fulfill the promise described in the New Era of Smarter Food Safety and support the improvement in workflow that will accompany these changes,” said Califf. “This area of focus will support the work of the Human Foods Program by enabling more facile communication, more efficient operations and enhanced empirical risk algorithms to guide the priorities of the program and the work in the field.”

To execute this new plan, the FDA has formed an Implementation and Change Management Group that will be charged with developing a detailed plan for implementation of the newly organized agency. “While details of this proposal continue to be developed, CFSAN, ORA, and OFPR will continue to operate under their current structures, with my direct oversight. I look forward to providing additional public updates by the end of February on our progress, organizational design and timeline,” said Califf.

 

Susanne Kuehne, Decernis
Food Fraud Quick Bites

It’s Official: FDA Designates New Webpage to Food Fraud

By Susanne Kuehne
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Susanne Kuehne, Decernis
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Find records of fraud such as those discussed in this column and more in the Food Fraud Database, owned and operated by Decernis, a Food Safety Tech advertiser. Image Credit: Susanne Kuehne

Food fraud has become such an important issue that many governments are monitoring it much more closely. To keep producers and consumers informed on the latest developments, the FDA has generated a new web page on economically motivated adulteration (EMA). The page includes links on how to report food fraud (including a list of consumer complaint coordinators), important examples of adulteration (i.e., honey, olive oil and seafood), how food fraud is detected and monitored, enforcement and legal consequences such as recalls, seizures and import refusals, guidance documents to assist manufacturers and importers, and a list of import alerts.

Resource

  1. FDA. (November 4, 2021). “Economically Motivated Adulteration (Food Fraud)”.
Roberto Bellavia, Kestrel
FST Soapbox

How Integrated Compliance Management Systems Maximize Efficiency

By Roberto Bellavia
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Roberto Bellavia, Kestrel

Managing the complexities of a management system is challenging for any food and beverage company, particularly for the team tasked with implementing the system throughout the organization. That is because every regulatory agency (e.g., FDA, USDA, OSHA, EPA) and voluntary certification (e.g., GFSI-benchmarked standards, gluten-free, organic, ISO) calls for companies to fulfill compliance requirements—many of which overlap. Supply chain and internal requirements can create further complications and confusion.

In today’s “New Era of Smarter Food Safety,” having a common system to organize, manage and track compliance offers an ideal solution. Dynamic tools are becoming available—systems that can manage employee training, pest control, laboratory testing, supply chain management tools, regulatory compliance and certification requirements, etc.

Unfortunately, these systems are often not set up to “talk” to each other, leaving company representatives to navigate many systems, databases, folders, and documents housed in many different locations.

The Solution: Compliance Management Systems

An integrated compliance management system (CMS) is intended to bring all these tools together to create one system that effectively manages compliance requirements, enables staff to carry out daily tasks and manage operations, and supports operational decision making by tracking and trending data that is collected daily by the team charged with implementation.

A CMS is used to coordinate, organize, control, analyze and visualize information to help organizations remain in compliance and operate efficiently. A successful CMS thinks beyond just access to documents; it manages the processes, knowledge and work that is critical to helping identify and control business risks. That may include the following:

  • Ensuring only authorized employees can access the right information.
  • Consolidating documents and records in a centralized location to provide easy access
  • Setting up formal business practices, processes and procedures
  • Implementing compliance and certification programs
  • Monitoring and measuring performance
  • Supporting continuous improvements
  • Documenting decisions and how they are made
  • Capturing institutional knowledge and transferring that into a sustainable system
  • Using task management and tracking tools to understand how people are doing their work
  • Enabling data trending and predictive analytics

CMS Case Study: Boston Sword and Tuna

In early 2019, Boston Sword and Tuna (BST) began the process of achieving SQF food safety certification. We initially started working with BST on the development, training and implementation of the program requirements to the SQF code for certification—including developing guidance documents for a new site under construction.

The process of attaining SQF certification included the development of a register of SQF requirements in Microsoft SharePoint, which has since evolved into a more comprehensive approach to overall data and compliance management. “We didn’t plan to build a paperless food safety management system,” explains BST President Larry Dore, “until we implemented our SQF food safety management program and realized that we needed a better way to manage data.”

We worked with BST to structure the company’s SharePoint CMS according to existing BST food safety management processes to support its certification requirements and overall food safety management program. This has included developing a number of modules/tools to support ongoing compliance efforts and providing online/remote training in the management of the site and a paperless data collection module.

The BST CMS has been designed to support daily task activities with reminders and specific workflows that ensure proper records verifications are carried out as required. The system houses tools and forms, standards/regulatory registers, and calendars for tracking action items, including the following:

  • Ambient Temperature
  • Corrective and Preventive Action (CAPA)
  • Chemical Inventory/Safety Data Sheets (SDS)
  • Compliance Management
  • Customer Complaints
  • Document Control
  • Employee Health Check
  • Food Safety Meetings Management Program
  • Forklift Inspections
  • Good Manufacturing Practices (GMP) Audit
  • SQF Register
  • Maintenance (requests/work orders/assets/repairs)
  • Nightly Cleaning Inspections
  • Operational/Pre-Operational Inspections
  • Sanitation Pre-Op Inspections
  • Scale Calibration
  • Sharp/Knife Inspections
  • Shipping/Receiving Logs
  • Thawing Temperature Log
  • Thermometer Calibration

Key Considerations for Designing a Successful CMS

An effective CMS requires an understanding of technology, operational needs, regulatory compliance obligations and certification requirements, as well as the bigger picture of the company’s overall strategy. There are several key considerations that can help ensure companies end up with the right CMS and efficiency tools to provide an integrated system that supports the organization for the long term.

Before design can even begin, it is important to first determine where you are starting by conducting an inventory of existing systems. This includes not only identifying how you are currently managing your compliance and certification requirements, but also assessing how well those current systems (or parts of them) are working for the organization.

As with many projects, design should begin with the end in mind. What are the business drivers that are guiding your system? What are the outcomes you want to achieve through your system (e.g., create efficiencies, provide remote access, reduce duplication of effort, produce real-time reports, respond to regulatory requirements, foster teamwork and communication)? Assuming that managing compliance and certification requirements is a fundamental objective of the CMS, having a solid understanding of those requirements is key to building the system. These requirements should be documented so they can be built into the CMS for efficient tracking and management.

While you may not build everything from the start, defining the ultimate desired end state will allow for development to proceed so every module is aligned under the CMS. Understand that building a CMS is a process, and different organizations will be comfortable with different paces and budgets. Establish priorities (i.e., the most important items on your list), schedule and budget. Doing so will allow you to determine whether to tackle the full system at once or develop one module at a time. For many, it makes sense to start with existing processes that work well and transition those first. Priorities should be set based on ease of implementation, compliance risk, business improvement and value to the company.

Finally, the CMS will not work well without getting the right people involved—and that can include many different people at various points in the process (e.g., end user entering data in the plant, management reviewing reports and metrics, system administrator, office staff). The system should be designed to reflect the daily routines of those employees who will be using it. Modules should build off existing routines, tasks, and activities to create familiarity and encourage adoption. A truly user-friendly system will be something that meets the needs of all parties.

Driving Value and Compliance Efficiency

When thoughtfully designed, a CMS can provide significant value by creating compliance efficiencies that improve the company’s ability to create consistent and reliable compliance performance. “Our system is allowing us to actually use data analytics for decision making and continuous opportunity,” said Dore. “Plus, it is making remote activities much more practical and efficient”.

For BST, the CMS also:

  • Provides central management of inspection schedules, forms, and other requirements.
  • Increases productivity through reductions in prep time and redundant/manual data entry.
  • Improves data access/availability for reporting and planning purposes.
  • Effectively monitors operational activities to ensure compliance and certifications standards are met.
  • Allows data to be submitted directly and immediately into SharePoint so it can be reviewed, analyzed, etc. in real time.
  • Creates workflow and process automation, including automated notifications to allow for real-time improvements.
  • Allows follow-up actions to be assigned and sent to those who need them.

All these things work together to help the company reduce compliance risk, create efficiencies, provide operational flexibility, and generate business improvement and value.

Stephen Dombroski, QAD
FST Soapbox

Regulatory Issues and Transportation: Critical Factors in the Quest for Sustainability in Food Manufacturing

By Stephen Dombroski
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Stephen Dombroski, QAD

Over the last several months, we have been exploring the details of several critical factors that are impacting the food and beverage manufacturing sector in terms of sustainability, including:

Two additional factors that food manufacturers now have to manage regarding sustainable practices are transportation and regulatory restrictions. Each can be discussed as a separate topic, but they are intertwined, as there have always been regulations regarding food transportation, and obviously food has always needed to be transported. Now that sustainability is an important topic in all areas of food manufacturing, it makes sense to discuss these two subjects both individually and collectively.

Transportation and Regulatory Joint Concerns

Ensuring that all areas of food transportation incorporate sustainable practices is a critical component of achieving sustainability in food manufacturing. To this point, however, these types of practices have not fully been implemented or even designed. This area is still evolving. From a straight transportation point of view, governments globally have been imposing restrictions for decades. These restrictions vary from country to country, province to province, region to region, and so on, and this causes confusion when inter- or intra-region transportation of food is required. There are also several regulatory differences based on mode of transportation. Land, air and sea transportation can and should have different regulations.

Another ingredient that should be added to this product mix of sustainability, transportation and regulations is food safety and the integrity of the food materials being transported whether it is ingredients, work-in-process foods or finished products. Various modes of transportation can affect the chemical composition, physical appearance, nutritional value and quality and safety of food. It could be straightforward to start implementing restrictions, regulations and new methods of how to package, manufacture and transport food to satisfy the growing trend of sustainable food behaviors. However, what cannot get lost in this is the issue of food safety and integrity.

Sustainability More than Recycling and Litter

When discussing regulations around transportation and food, many people immediately think of littering, of some uncaring individual throwing a soda pop can out of a car window. Littering regulations, laws, fines, penalties and public service campaigns have been in place globally for more than 50 years. The next time you go outside, take a look around at how effective those have been. Sustainability goes far beyond the issue of litter. One area that works hand in hand with transportation of food is climate change. Governments have been evaluating the current practices and have begun implementing changes designed to positively affect climate change. Some examples include:

  • 23 American states and Washington, D.C. limit idling by some or all vehicles.
  • The California Air Resources Board adopted the TRU Airborne Toxic Control Measure in 2004 to reduce diesel particulate matter pollutant emissions.
  • In 2020, the International Maritime Organization will implement a new regulation for a 0.50% global sulfur cap for marine fuels.

The food and beverage industry is actively embracing other changes that affect sustainability. Electric trucks fit well with the F&B distribution hub model, with clean, quiet, short-run deliveries. Fuel usage during transportation is being considered from every angle. Local and regional food systems, where farmers and processors sell and distribute their food to consumers within a given area, use less fossil fuel for transportation because the distance from farm to consumer is shorter. This shorter distance also can help to reduce CO2 emissions.

Change Starts with Money

During many conversations I have had with my wife about a variety of subjects, especially those that can be considered controversial, one of us always raises the same question which is: “When in doubt, what is it all about?” And most of the time, the answer is money. Regulations around sustainability in food manufacturing are being driven by demands made by the consumer. The purchasers of the finished food product dictate almost every aspect of that product to the manufacturer because, let’s face it, if the consumer doesn’t like it, they won’t buy it. And if they don’t buy it, what will eventually happen to the manufacturer? That’s right—it goes out of business.

Now there is a good definition of sustainability or at least of what is not sustainable. From the transportation side of things, manufacturers in almost all cases pay the freight of shipping their food products to the members of the value chain. This obviously affects the costs of goods sold, which is a direct component of the bottom line and the profitability of the business. And with margins typically low in food and beverage manufacturing, transportation costs are always on the minds of the executives. So as the drive for sustainable transportation practices rolls into food manufacturing, you can bet that in addition to meeting sustainable practices, they will fit into the financial plans of the organization as well.

Sustainability: Just Another Component in a Long Line of Disruptors in Food Manufacturing

Years ago, when the topic of disruption in food manufacturing came up, many would mention things like a customer changing an order, an ingredient not arriving on time, or a packaging line going down for an hour. Today, these occurrences are just part of the day-to-day process and reality of food manufacturing. They are going to happen, and disruptions are the things that will make a food manufacturer have to change their business model and force them to change their philosophy and begin to evaluate their business practices and systems to adjust to the world in which they operate.

Sustainability is another one of those disruptions that will impact the process of food transportation long term. Sustainability will be an area that eventually forces manufacturers to operate within new regulatory parameters imposed on how they produce and ship their food. Through these changes, manufacturers will have to ensure that food meets the current and future safety regulations while maintaining profitability. That is where real sustainability will be measured. Changes to business, movements like sustainability are adding to the disruption of the food industry at unprecedented rates of speed. In order to survive and thrive, and to meet these disruptions head on and be sustainable themselves, global food manufacturers must be able to innovate and adapt their business models.

FDA

FDA Issues Letter to Industry Addressing Efforts to Reduce Chemical Hazards in Foods for Babies and Young Children

By Food Safety Tech Staff
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A report released last month by the Subcommittee on Economic and Consumer Policy revealed dangerous levels of toxic heavy metals in baby food. It stirred up quite a bit of controversy and concern, and raised questions over whether baby food manufacturers were hiding dangerous levels of toxic heavy metals in food, and whether FDA was doing enough to ensure the safety of food.

In an effort to assure the public that FDA is taking the issue seriously, the agency published a constituent update about its actions to further prevent or reduce toxic elements in foods for babies and young children. It also issued a letter to manufacturers and processors of baby and toddler foods as a reminder of the “responsibility under the rulemaking to consider chemical hazards that may be present in foods when conducting your hazard analysis,” which is part of the preventive control provisions of the Current Good Manufacturing Practice, Hazard Analysis, and Risk-based Preventive Controls for Human Food FSMA rule.

“FDA takes exposure to toxic elements in the food supply extremely seriously, especially when it comes to protecting the health and safety of the youngest and most vulnerable in the population. Toxic elements, such as arsenic and lead, are present in the environment and may enter the food supply through soil, water, or air,” stated CFSAN Director Susan Mayne in the letter. “Our goal is to reduce exposure to toxic elements in foods to the greatest extent feasible and to further advance progress in this area through more research and enhanced collaboration among stakeholders.”

The agency also stated that it is finalizing a plan to reduce levels of toxic elements in baby foods, including:

  • “Reviewing current action levels, as well as developing additional action levels, to help make food safer, including finalizing the arsenic in apple juice draft guidance and publishing a draft guidance with action levels for lead in juices.

  • Focused compliance and enforcement activities, including inspections.

  • Providing guidance to industry on how to meet their obligations under current regulations.”

The agency will also continue its surveillance sampling assignment that focuses on these products.

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FDA Begins Phase Two of Artificial Intelligence Imported Seafood Pilot Program

By Food Safety Tech Staff
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FDA is beginning phase two of its Artificial Intelligence Imported Seafood Pilot Program. The program, which is expected to run from February 1 through July 31, intends to improve FDA’s response in quickly and efficiently identifying potentially harmful imported seafood products.

Phase one of the pilot looked at using machine learning to find violative seafood shipments. “The pilot program will help the agency not only gain valuable experience with new powerful AI-enabled technology but also add to the tools used to determine compliance with regulatory requirements and speed up detection of public health threats,” FDA stated in a news release. “Following completion of the pilot, FDA will communicate on our findings to promote transparency and facilitate dialogue on how new and emerging technologies can be harnessed to solve complex public health challenges.”

The pilot program is part of the agency’s efforts that fall under the New Era of Smarter Food Safety.

Karen Everstine, Decernis
Food Fraud Quick Bites

Food Authenticity: 2020 in Review

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

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.
  • Honey. Greece issued multiple alerts for honey containing sugar syrups and, in one case, caramel colors. Turkey reported a surveillance test that identified foreign sugars in honeycomb.
  • 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

RASFF

RASFF, melamine detection
Figure 1. RASFF notifications for the detection of melamine in two products.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.

Reference

  1. 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