When I (Brian) was a kid, I remember eating dyed pistachios that turned my fingers pink. While the color was amusing to me then, it turned out that red food coloring had been used by the producer in Iran to cover stains, blotches, and mottled markings that occurred during harvesting and drying. I also remember news of cheap types of fish being substituted for or misbranded as the more expensive orange roughy or mahi mahi, misleading consumers to pay more for a lesser product. Each of these was considered food fraud and, unfortunately, the issue has not gone away.
In fact, due to increased oversight and detection tools, food fraud seems to be happening more than ever and is likely more prevalent in the supply chain than is widely known. As we can see from the examples above, it is not a new problem either; the practice of adulterating food for economically motivated reasons has been going on for years.
Estimated to cost the industry $30-40 billion annually, food fraud can take place through various means. The most common of these are adulteration by substitution, omission, dilution, falsification, deception in the production method or its origin, intentional mislabeling, or masking a defect or contamination.
In addition to the industry, brands, and products that can be impacted by fraudulent ingredients, end consumers are also harmed by food fraud. One example that resulted in a food safety issue is the wheat gluten that was contaminated with melamine to inflate its protein content measures and imported from China in 2007. When used as an ingredient in pet foods, it sickened and killed hundreds of cats and dogs by causing kidney failure in those animals.
Another instance of food fraud that may have caused illness occurred in 2015, when it was speculated that suppliers added cheaper ground up peanut shells and almond husks to ground cumin, a premium quality spice. Meant to “bulk up” the product and make it heavier to increase the supplier’s margins, the obvious concern was ingestion by consumers with peanut or tree nut (almond) allergies.
Food Fraud During a Pandemic
The current COVID-19 pandemic has likely further incentivized criminals to commit food fraud. In some countries, stay-at-home measures and employee illness have increased the number of employees absent from their jobs. One example was the number of positive virus cases in meatpacking plants here in the U.S., which has led to a reduction in the number of active operators in those plants, with the consequence being a decrease in production. In some cases, this decrease has led to a shortage of raw materials and consumer-ready products, creating a domino effect in the next links in the food supply chain. This shortage and others around the world are then sometimes replaced by fraudulent ingredients and products that don’t meet client and consumer expectations.
Dependence on materials imported from countries with food manufacturing workers impacted by the pandemic has also put the continuity of the supply chain at risk. International trade has been hindered due to the lack of appropriate logistics, with closed borders and a decrease in the availability of transportation preventing materials from arriving on time. Each of these has created an opportunity for fraudulent activity.
Further, because the economy in most countries has been impacted and consumers have lost some of their purchasing power, people are looking to buy products at the lowest possible cost. As a result, they may be more interested in a product’s price than the brand they are used to or its quality, thus increasing vulnerability in the products they are purchasing.
In each of these scenarios, fraudsters may be tempted to obtain economic gain through the intentional adulteration of the food. They may choose to send their clients lower quality materials, or they may replace, dilute, or modify, without declaration, certain ingredients or products, just to meet their customer’s order. They may also be taking advantage of the fact that clients have fewer personnel to supervise the reception and oversight of those materials due to the pandemic.
Assess, Implement, and Review
So, what can be done to minimize food fraud? Foremost, FDA’s Food Safety Modernization Act and Global Food Safety Initiative (GFSI) Benchmarking Requirements require food manufacturing facilities to develop and document a food fraud vulnerability assessment and mitigation plan.
Generally, a risk or vulnerability assessment begins by understanding what ingredients are used at a facility to make your products. The Food Protection and Defense Institute defines the top 10 most fraudulent foods as alcoholic beverages, oils and fats, meat and meat products, honey, spices, grains and grain products, coffee and tea, fish and seafood, dairy, and produce. Separately, Decernis’ Food Fraud Database defines their top 10 most fraudulent foods as olive oil, milk, honey, saffron, orange juice, coffee, apple juice, grape wine, maple syrup, and vanilla extract.
Many of these ingredients are known historically to be at an increased risk for fraud, which means there is a higher risk of fraud in your supply chain if you are receiving or using these ingredients. As an example, the gap between production and consumption of both olive oil (specifically extra virgin olive oil) and honey has been studied. While the global industry is only currently producing a certain amount of these ingredients, the world consumes more than what is produced. Thus, they are being fraudulently diluted, substituted, concealed, or mislabeled.
When conducting a vulnerability assessment to determine the risk of fraud in your supply chain, consider historical risk as a factor within the assessment. Additional examples of risk factors could include your history or relationship with a supplier and complication of the supply chain, such as how many points along the supply chain the ingredient goes through until it reaches your facility. Economic factors can also make fraudulent activity more attractive and could include a pandemic or ecological factors such as drought, pestilence, and the nature of the ingredient, such as a powdered or liquid ingredient versus a solid item such as an apple.
Once these factors are chosen, you should develop a risk rating system. These ratings could be Low, Medium, and High or Minor, Major, and Critical; what this would mean for each risk factor must be identified. Next, conduct an assessment using the risk factors and risk rating system established, while documenting your results.
In addition to the high-risk ingredients, look at your most expensive ingredients. Often, those products that have assured status, such as organic, gluten-free, and non-GMO, are most easily susceptible to fraud. Others might be easy to adulterate and/or difficult to test, so manufacturers and suppliers need to stay current with historical and developing threats. Resources to do so are offered through various trade associations, government sources, and private centers. Some also offer access to food fraud databases and free assessment templates.
Once you identify the risk of potentially fraudulent activity for an ingredient during your vulnerability assessment and per GFSI requirements, you are required to develop and implement mitigation strategies to significantly minimize or prevent it. If you identify economically motivated adulteration (food fraud with a food safety issue), then you will need to develop or implement preventive controls. Some common strategies include supplier audits, sampling and testing, final product testing, and approved supplier programs.
Once you’ve completed your assessment and developed mitigation strategies to address identified risks, there is still work to do. You’ll need to review your program on a regular basis, understanding that fraudsters will always look for opportunities. For example, GFSI audits such as BRC and SQF require that a food fraud vulnerability assessment be conducted annually to consider the susceptibility of raw materials.
Further, it is important for suppliers and customers to maintain a close relationship while continuing to oversee supplier approval and evaluation processes. An in-depth, approved supplier program is essential. Processors must continue to carry out analysis that, based on their risk assessment, each has determined is necessary to corroborate the legitimacy and origin of the materials received. You must continue developing rapid and accessible analytical methodologies that identify in a timely manner whether a food is fraudulent.
You will also need to continually review and assess to determine if there is new information that may identify an increased risk of fraud. This process is called horizon scanning. An example of increasing risk of fraud could be the situation we have all experienced with the pandemic. As you scan the horizon, have there been disruptions specific to your supply chain and are you prepared for the next potential disruption?
The Need for Diligence
Unfortunately, there will always be unscrupulous people who will mislead consumers to achieve dishonest profits. These actions severely impact those companies that cannot compete against fraudulently low prices and poor quality, and that are unwilling to put consumers in harm’s way. Additionally, it seems that those who are responsible for committing fraud are often one step ahead of the rest of us. Once a possible adulteration case is detected, criminals are already working to go unnoticed again. As long as there is demand for a product, there will continue to be a threat of fraudulent activity related to that product.
However, more information is available today on the production methods used, the regions from which products originate, and the methods that allow for the identification of adulteration. There is also a wealth of information available to assist in planning and executing mitigation strategies.
While food fraud may not always be as easy to detect as red food coloring on your fingers, the steps to mitigating food fraud are definitely right at your fingertips.
Watterson is Food Safety Professional, Operations, Americas, AIB International. Reach him at [email protected]. Hernandez is Food Safety Professional, Operations, Americas, AIB International. Reach her at [email protected].
ACCESS THE FULL VERSION OF THIS ARTICLE
To view this article and gain unlimited access to premium content on the FQ&S website, register for your FREE account. Build your profile and create a personalized experience today! Sign up is easy!
GET STARTED
Already have an account? LOGIN