Fighting Food Fraud - IFT.org http://www.ift.org/food-technology/past-issues/2015/march/columns/f...

Neil H. Mermelstein | March 2015, Volume 69, No.3

FOOD SAFETY & QUALITY

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Foods and food ingredients can be adulterated both intentionally and

unintentionally. In its efforts to protect the food supply, the U.S. Food and Drug
Administration (FDA) undertakes both food defense and food safety activities.
Food defense is the effort to protect the food supply against intentional
contamination due to sabotage, terrorism, counterfeiting, or other illegal,
intentionally harmful means. Potential contaminants include biological, chemical,
and radiological hazards that are generally not found in foods or their production
environment. Food safety is the effort to prevent unintentional contamination of
food products by agents reasonably likely to occur in the food supply, such as
Escherichia coli, Salmonella, and Listeria. Another form of adulteration is
economically motivated adulteration (EMA), which is fraud carried out for
financial gain. Although it may not be intended to cause safety problems, EMA
also has the potential to cause harm.

USP Addresses Economic Fraud

On November 17, 2014, the U.S. Pharmacopeial Convention (USP), Rockville,

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Md. (www.usp.org), issued a proposed document, “Guidance on Food Fraud

Mitigation,” as a framework for the food industry and regulators to develop and
implement preventive management systems to deal with EMA of food ingredients.
A nonprofit scientific organization that develops standards to help ensure the
identity, quality, and purity of food ingredients, dietary supplements, and
pharmaceuticals, the USP publishes its food ingredient standards in the Food
Chemicals Codex (FCC).

Jeff Moore, senior scientific liaison, USP, said that the USP’s expert panel on food
adulteration spent one year discussing which problems the document would
address and one year writing it. The proposed guidance document is available on
the FCC website and is open for public comment until March 31, 2015. Moore
said that the comments received and the expert panel’s response to them will be
posted online this summer. If the committee needs more time to evaluate the
comments or requests additional information, the comment period may be
extended. The finalized document is scheduled to be published in appendix XVII
to the third supplement of the ninth edition of the FCC on September 1, 2015.
Calling it a first-of-its-kind guidance document dealing specifically with EMA of
food ingredients, Moore said that it is intended to help users develop a fraud
management system that prioritizes and focuses mitigation resources on
ingredients that not only carry the most vulnerability but also have potential for
detrimental consequences when fraud occurs.

The approach consists of four steps. The first three characterize the overall fraud
vulnerabilities of an ingredient by assessing factors contributing to fraud
occurrence and the potential public health and economic impacts when fraud does
occur, and the fourth provides guidance on how to use information from the first
three steps to develop a mitigation strategy. The document describes the factors to
be considered in each step and provides in-depth discussions of actual fraud cases
to illustrate the value of assessing the impact of those factors. The first step is to
conduct a vulnerability assessment addressing the following factors:

• Supply chain. A food ingredient’s vulnerability to fraud increases with the

complexity of the supply chain. The lowest vulnerability is when a single-
ingredient food is sourced directly from a trusted supplier who in turn sources

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from a trusted supplier. The highest vulnerability is when ingredients are sourced
from multiple sources in an open market where there is limited knowledge about
the supplier and when the ingredient is handled by multiple parties and the source
identity is lost or not actively tracked, as when ingredients are blended. An
example is the supply chain aspects of the melamine-tainted pet food incident,
which involved the addition of low-purity melamine to inferior grade wheat gluten
and other protein-rich ingredients to boost the apparent protein content.

• Audit strategy. The vulnerability of a supply chain to food fraud depends on the
auditor’s qualifications, the type of audit (onsite or other), inclusion of anti-fraud
elements in audits, who conducts the audit (the ingredient customer, the supplier,
or an independent third party), the frequency of onsite auditing, and the use of
unannounced audits. An example is an incident involving the marketing of frozen
unsweetened orange juice concentrate that was adulterated with beet sugar using a
cleverly designed manufacturing facility to conceal the fraudulent practices. It
illustrates the extent of deception used to hide fraudulent practices and thereby the
strengths and weaknesses of different audit strategies as a way to prevent fraud.

Enlarge this Image • Supplier relationship. The vulnerability of ingredients

to food fraud ranges from low for a trusted supplier to
high for a new supplier with whom no relationship has
been established. For example, a brand of apple juice for
infants was marketed and labeled as pure apple juice but
contained water, beet sugar, cane sugar syrup, corn
syrup, water, malic acid, artificial coloring, and artificial
Figure 1. A food fraud
flavoring.
management system.
• History of supplier quality and safety issues. This
factor estimates the vulnerability to fraud due to the lack of sufficient controls by a
supplier. For example, although Salmonella was not intentionally introduced into
certain peanut products, company executives knew about the contamination but
sold the products anyway.

• Susceptibility of quality assurance methods and specifications. This factor

describes the vulnerability based on a lack of sufficient analytical methods and

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specifications. One example is whey protein ingredients, for which the lack of
selectivity and specificity of the Kjeldahl nitrogen method for protein nitrogen
dramatically increases the vulnerability. Another example is a fruit juice
concentrate purchased on the basis of methods and specifications for only Brix,
pH, and visual color.

• Testing frequency. This factor describes the vulnerability based on a lack of

sufficient testing frequency.

• Fraud history. This factor characterizes the potential for fraud in an ingredient,
based on the pattern and history of reported fraud issues. Examples are
adulteration of milk, for which criminals constantly develop new ways to
circumvent the latest adulteration detection methods; cassia oil, which is prone to
adulteration even when new detection methods are developed; and a false report
that street vendors in China were selling pork dumplings containing cardboard.
The examples illustrate how combining the information in the USP’s Food Fraud
Database (www.foodfraud.org) and the National Center for Food Protection and
Defense’s EMA Incidents Database (www.FoodShield.org) for a particular
ingredient can provide insight into the history of food fraud.

• Geopolitical considerations. This factor describes the vulnerability based on a

lack of food control, regulatory, and other geopolitical factors that ensure food
safety and prevent food fraud in any region of the world. The factor is integrally
tied to the number of raw materials used to produce the finished ingredient, the
geographic sources of the ingredients, and the number of geographic regions
through which the ingredients and components of ingredients may transit. For
example, chili powder from India was adulterated with the suspected carcinogen
Sudan I dye and was found in Worcestershire sauce in the United Kingdom.

• Economic anomalies. This factor describes the vulnerability of ingredients to

food fraud based on economic anomalies occurring in the marketplace. An
example is the spike in price of vanilla, the second most-expensive spice (saffron
is the first), caused by extreme weather conditions and increasing consumer
demand for natural vanilla instead of synthetic vanilla as well as analytical
difficulties to authenticate vanilla due to its complex and variable composition and

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challenges of available analytical methods.

Enlarge this Image The second step is to assess the potential food
safety/public health and economic impacts of fraud. The
traditional food safety risks associated with food fraud
where the adulterant has the potential to cause illness or
death are the most obvious public health impact
concerns. While those who commit EMA do not intend
to cause illness or death, they do not always understand
Figure 2. Matrix used in
the potential harmful effects of the adulterating material.
step 1 for assessing
Melamine adulteration of dairy proteins, denatured
factors’ contribution to
rapeseed oil adulteration of olive oil, and methanol
vulnerability. Illustration
contamination of vodka are examples. The adulteration
courtesy of the U.S.
of foods that constitute the major, sole, or necessary
Pharmacopeial
component of a diet substantially raises the potential
Convention.
public health impact. Pet food, infant formula, and baby
food are examples as are foods that provide baseline nutrition for a sub-population.
The loss of consumer confidence illustrates that damage to a brand can be
expensive and long-lasting.

The third step is to combine steps one and two to generate an overall
characterization of vulnerabilities. And the fourth step is to develop an appropriate
mitigation strategy with three possible outcomes: 1) “new controls are optional,”
in which a user can decide that documentation of the assessment is all that is
necessary; 2) “new controls should be considered,” in which a user needs to
consider if the vulnerabilities are acceptable and, if not, determine where to apply
food fraud mitigation resources to yield an acceptable level of vulnerabilities; and
3) “new controls are strongly suggested.”

With regard to other anti-fraud activities at the USP, Moore said that the USP is
developing a toolbox of methods for skim milk powder to deal with unknown
adulterants, not known adulterants, and standardized and validated methods for
unknown adulterants. The first tool is for detecting the non-protein nitrogen
content of skim milk powder. More tools are being developed but are not yet ready
for public comment, he said. They include such methods as non-targeted analysis

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with near-infrared or nuclear magnetic resonance and an amino acid fingerprinting

method. The USP has also developed reference materials containing melamine in a
skim milk powder matrix as standards for users to verify the performance of
non-targeted methods and expects to release them later this year. In addition, the
USP has several other ongoing projects related to EMA, such as adulteration of
paprika oleoresin and olive oil.

Moore said that the USP is continuing to improve its Food Fraud Database. A
compilation of scholarly and media reports on food ingredient fraud from 1980 to
2010, the database can be used to assess existing and emerging risks and trends for
EMA. It also includes a library of detection methods reported in peer-reviewed
journals. A large amount of new data is being vetted for validity and usefulness
and will be entered into the database in early to mid 2015.

GFSI Adds Food Fraud to Guidance

The Global Food Safety Initiative (GFSI), Paris, France (www.mygfsi.com), is a
global consortium that brings together international food safety experts from the
entire food supply chain to share knowledge and promote a harmonized approach
to managing food safety across the industry. Karil Kochenderfer, GFSI’s North
American representative, said that the GFSI doesn’t audit or certify companies for
food safety but instead sets standards for food safety schemes that companies
around the world can meet. It sets benchmarking schemes and identifies certifying
bodies, auditors, and inspection teams that inspect facilities. This system ensures
that companies adopting the standards have good food safety protocols in place.
She added that the GFSI’s network of schemes for various sectors such as grain,
meat, processing, retail, and others has been growing at a double-digit rate over
the past ten years.

Enlarge this Image The GFSI issued a position paper on mitigating the
public health risk of food fraud on July 14, 2014,
outlining steps that food businesses should take to
protect consumers from the consequences of food
adulteration, counterfeiting, and other illegal practices.
In its position paper, the GFSI proposed adding two key
Figure 3. Matrix used in
elements to its guidance document, available on the

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step 2 for evaluating GFSI website. The first would require food companies
safety and economic to carry out a food fraud vulnerability assessment in
impacts. Illustration which information is collected at the appropriate points
courtesy of the U.S. along the supply chain (including raw materials,
Pharmacopeial ingredients, products, and packaging) and evaluated to
Convention. identify and prioritize significant vulnerabilities for food
fraud. The second would require food companies to put in place appropriate
control measures to reduce the risks from these vulnerabilities. These control
measures would include a monitoring strategy, a testing strategy, origin
verification, specification management, supplier audits, and anticounterfeit
technologies. A clearly documented control plan would outline when, where, and
how to mitigate fraudulent activities.

Elements of the food fraud guidance document were sent to technical experts in
the food industry last year, Kochenderfer said, and the document is undergoing
revision. The GFSI will incorporate the new elements, which address food safety
rather than EMA, in the next full revision of its guidance document to be released
in 2016.

The FDA Adds Focus on Adulteration

The Food Safety Modernization Act mandates that the FDA work to prevent both
intentional and unintentional contamination of foods through a variety of
preventive and risk-based strategies and through enhanced regulatory authority. It
provides for increased food protection by requiring food companies to identify and
implement preventive controls to ensure that adulterated products are not sold and
to share their food safety plans with the FDA. The law requires the FDA to issue
seven implementing regulations by May 31, 2016. The agency published its
proposed rule “Focused Mitigation Strategies to Protect Food Against Intentional
Adulteration” in the Federal Register on December 24, 2013, with a June 30,
2014, deadline for comments. The proposed rule focuses on protection of food
against intentional adulteration caused by acts of terrorism, but it also included a
request for public comment on whether it should address EMA and how.

According to Douglas Karas, FDA spokesperson, the agency is reviewing the

comments received and will publish a final rule by the court-ordered deadline of

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May 31, 2016. The FDA intends to publish within six months after publication of
the final rule a guidance document to help businesses identify actionable process
steps and implement focused mitigation strategy requirements.

The FDA has created a software program called the Food Defense Plan Builder to
help companies develop customized plans to minimize the risk of intentional
adulteration, and on September 3, 2014, the agency posted training videos on how
to use the program. Users answer a series of questions about the food facility and
the food manufactured, processed, packed, or held there to develop a
comprehensive food defense plan, including a vulnerability assessment, broad and
focused mitigation strategies, and an action plan. The software and videos are
available free of charge on the FDA’s website.

In October 2014 the FDA posted an online learning module consisting of three
videos to help the seafood industry, retailers, and state regulators ensure that
seafood products are properly labeled. The module, “Fish and Fishery Products
Hazards and Controls Guidance—Learning Module Videos,” provides an
overview of the federal identity labeling requirements for seafood offered in
interstate commerce; a list of the specific laws, regulations, guidance documents,
and other materials pertinent to the proper labeling of seafood; a description of the
FDA’s role in ensuring the proper labeling of seafood; and tips for identifying
mislabeled seafood in the wholesale distribution chain or at the point of retail. It
also references the FDA’s DNA testing at the wholesale level to evaluate proper
labeling of seafood species.

Leading Food Fraud Categories

The January 10, 2014, report “Food Fraud and ‘Economically Motivated
Adulteration’ of Food and Food Ingredients” by Renée Johnson of the
Congressional Research Service (www.loc.gov/crsinfo.gov) used data from the
USP’s Food Fraud Database, the National Center for Food Protection and
Defense’s EMA Incident Database, and other sources to identify leading food
categories with reported cases of food fraud. They are as follows:

• Olive Oil. Olive oil is often substituted or diluted with lower-cost oils.

• Fish and Seafood. Some higher-value fish and seafood are replaced

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with less expensive fish.

• Milk and Milk-Based Products. Milk from cows has been adulterated with milk
from sheep, buffalo, and goat antelope and with reconstituted milk powder, urea,
rennet, and other food and nonfood products.

• Honey, Maple Syrup, and Other Natural Sweeteners. Honey and maple
syrup have been adulterated with other syrups and sugars. Honey has also
contained unapproved antibiotics or other additives and heavy metals.

• Fruit Juices. Some juices, especially expensive ones like pomegranate juice,
have been diluted with water or a cheaper juice such as apple or grape.

• Coffee and Tea. Ground coffee might contain ground leaves and twigs as
well as roasted corn, ground roasted barley, and roasted ground parchment.
Instant coffee may include chicory, cereals, caramel, parchment, starch, malt, and
figs. Tea may contain leaves from other plants, color additives, and colored
sawdust.

• Spices. Saffron, the world’s most expensive spice, has been found to have added
glycerin, sandalwood dust, tartrazine, barium sulfate, and borax. Ground black
pepper has been shown to have added starch, papaya seeds, buckwheat, flour,
twigs, and millet. Vanilla extract, turmeric, star anise, paprika and chili powder are
also prone to fraud.

• Organic Foods and Products. Conventionally produced foods fraudulently

labeled as organic have been detected by the U.S. Dept. of Agriculture for a range
of foods and food ingredients from both domestic and international suppliers.

• Clouding Agents. Food-processing aids to enhance the appeal or utility of a food

or food component are often used in fruit juices, jams, and other foods. Of
particular concern is the fraudulent use of phthalates as a substitute for other
ingredients.

Neil H. Mermelstein, IFT Fellow,

Editor Emeritus of Food Technology
[email protected]

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