Symptoms of Food Fraud

In July 2019, CFIA (the Canadian Food Inspection Agency) halted importation of over 28,000 pounds of adulterated honey tainted with the addition of sugars that illegally expanded the quantity of the products.

Food fraud can be committed in many ways such as mislabeling, product substitutions, or adulterations. Some examples would be changing the visual look of a product by adding a dye, substituting less expensive ingredient to lower value, or as mentioned, ingredient stuffing that artificially increases volume.

Along with adulterated honey, there’s been horse meat sold as beef, milk diluted with water, lower-quality vegetable oil sold as extra virgin vegetable oil (EVOO), and many more.

We may like to think our food supply chain is large and well established, and that these incidents occur simply through errors. However if this were the case, it would stand to reason there would be as many incidences that result in positive changes, such as adding a costlier ingredient.

Is Economically Motivated Adulteration an Issue for Processors?

When processors in the U.S. and Canada were asked if EMA was a problem, 36% said yes and 64% said no.

This is essentially a mirror to how international processors responded to the same question: 67% saying yes it was a problem, and 33% saying no.

What About First Hand Food Fraud Experience?

When participating processors were asked, “Have you detected food fraud in your supply chain?” 85% reported “no”; neither they nor their companies had detected food fraud directly.

However, nearly 40% of those in the spices industry did report firsthand experience with adulterated products.

What About Protection Measures?

Wehen processors were asked about analytical testing to detect food fraud, most, 71% reported that they do not. So, what ARE they doing?

The most common answer was relying that trusted suppliers had Certificates of Analysis. Some companies take extra measures by dealing with suppliers they’ve had long-term relationships with such as farmers and fishermen, people they know and trust. Others reported counting on certifications, inspections, and supplier approval programs as their main methods of control.

For those that are actively testing, most reported conducting specific tests unique to their products.

Some of these tests include:

• added water in milk
• specific pesticide/chemical residues on fruit/vegetables represented as organic
• Fourier-transform infrared spectroscopy in beverages, supplements, grains, and other products
• PCR in meats and fish

In some product categories, such as spices, processors reported doing more testing and using more testing methodologies such as:

•  gas chromatography
• high-pressure liquid chromatography
• wet chemistry
• infrared spectroscopy
• analyses of indicator parameters including color, odor, specific gravity, and gluten.

Depending on the segment, some smaller companies can’t afford the equipment necessary to do proper testing. They admit that they understand that testing would be a good addition to their program and would help them be more vigilant in their prevention efforts, but instead need to continue to rely on inspections and supplier control.

Final Thoughts

Food fraud is not new, and it is not going to be eliminated anytime soon. As supply chains get longer, and more global with a focus on streamlining, there will be ever more opportunities for food fraud to occur.

While many food companies believe what they are doing may be adequate, there is an ever increasing need for them to be ever more vigilant.

“The most sweeping reform of U.S. food safety laws in more than 70 years.” implemented on Jan 4, 2011, was the result of a development program launched by the FDA under the Food Safety and Modernization Act (FSMA).

Recognizing the need for information regarding new regulatory requirements, the Food Processors of Canada (FPC) held an information session for its members on the impacts of the Preventive Control Rule. The well attended session of 50 participants represented a wide variety of Canadian food manufacturers.

Dr. David Acheson (former assistant commissioner for Food at the USFDA), and Cameron Prince (former vice-president of the Canadian Food Inspection Agency) of The Acheson Group, were invited by the FPC to provide background on FSMA.

The purpose was to highlight the main impacts of the Preventive Control Rule on Canadian food producers exporting to the U.S.

Some key points that came out of the session:

HACCP+

FSMA focuses on preventing, rather than being reactionary, to issues that can cause food-borne illness. The safety schedules apply to firms that manufacture, process, pack or hold food for humans.

These businesses are required to have written plans that identify hazards, specify the steps they’ve put in place to prevent or minimize or those hazards. In addition, they must clearly identify monitoring procedures and record monitoring results, plus specify actions to be taken to correct problems that arise.

When compared to similar HACCP and GFSI programs, there are differences in the new FSMA Preventive Controls Rule that will require companies to re-evaluate and adjust their programs.

With the Preventive Control approach, hazards related to the process, and to plant operation, are controlled under a prerequisite program that now requires the same level of diligence in:

• Documentation
• Monitoring
• Record keeping
• Corrective actions as a CCP under HACCP

The Preventive Control approach is portrayed as “HACCP+” in which Prerequisite Programs are identified as Preventive Controls requiring the same level of control as a CCP such as:

• Cleaning and Sanitation
• Allergen Control
• Recall

Products That Are “Ready-to-Eat”

Processors of Ready-to-Eat (RTE) products exporting to the U.S. may are required to implement an environmental pathogen monitoring program.

If the RTE product is open to the environment after processing and before packaging, and a kill step does not follow the packaging step, an environmental pathogen monitoring program is required.

Foreign Suppliers Verification

U.S. importers must also comply with the Foreign Suppliers Verification Rule, which means U.S. importers need to verify that Canadian Suppliers are in compliance with all U.S. Rules for FDA commodities. The verification could include an audit by the U.S. importer or a third party representing the U.S. importer.

Qualified Personnel

A qualified individual is required to develop, implement, and monitor the Preventive Controls Program by the Preventative Control Rule.

This individual is known as a Preventive Controls Qualified Individual (PCQI). Although experienced food safety managers can qualify for this position, it is strongly recommended that companies have a certified PCQI on staff.

In most cases this means a QA manager will be required to take a two-and-a-half day certified training program.