Since the 2008 recession, companies and global organizations have reported an uptick in food fraud, spurring initiatives to address the growing concern about it. The effects of a food fraud incident can range from significant economic losses for processors to harming people’s health. However, guarding against this criminal act requires a different perspective and uses different skills than those of food defense, which specifically protects against tampering with the intent to harm, or food safety, which addresses unintentional or accidental adulteration.
The Food Protection and Defense Institute (FPDI) maintains the Economically Motivated Adulteration Incidents Database (foodprotection.umn.edu/innovations/food-fraudema/incidents-database) that contains information compiled through literature and media searches of economically motivated adulteration (EMA) incidents in food products since 1980. The food groups historically linked to fraudulent practices are: fish and seafood, dairy, oils/fats, meat, alcoholic beverages, honey, grain, produce, spices and extracts, fruit juices, eggs, coffee and tea. Many of these are premium products that are globally sourced and shipped around the world.
Simply put, food fraud is the act of deception using food for economic gain. This includes the intentional adulteration of food by substituting one product for another, using unapproved enhancements or additives, dilution, misrepresenting something about the product—such as country of origin—counterfeiting and stolen food shipments. As with other criminal enterprises, it is unclear just how big this industry is, especially since it is global in scope. Even the results from reporting agencies vary; the EMA Incidents Database contains detailed information on approximately 475 occurrences worldwide since 1980. The United States Pharmacopeia describes more than 2,000 food fraud incidents.
“However, this is likely just the tip of the iceberg,” says Karen Everstine, FPDI research associate. Formerly known as the National Center for Food Protection and Defense, FPDI was officially launched in July 2004 as a Homeland Security Center of Excellence at the University of Minnesota. Developed as a multidisciplinary and action-oriented research consortium, the organization works with government agencies on EMA incidents.
As those in the food industry business know, food fraud is nothing new. However, the watershed moment in Europe was the 2013 horsemeat scandal, where undeclared meats, including pork and horsemeat, were found in packages labeled as ground beef. In the wake of that crisis, Professor of Food Safety and Director of the Institute for Global Food Security at Queen’s University Belfast Chris Elliott was asked by government officials to carry out an independent review of Britain’s food system. His report recommends a systems-based approach with eight pillars to tackle food fraud.
The Elliott report on the integrity and assurance of food supply networks
Chris Elliott, professor of food safety and director of the Institute for Global Food Security at Queen’s University Belfast, was asked by the UK’s Department for Environment, Food and Rural Affairs (DEFRA) to carry out an independent review of the country’s food system in the wake of the 2013 horsemeat scandal.
The report suggests a systems-based approach to tackle food fraud, including the following elements:
- Industry, government and enforcement agencies should always put the needs of consumers above all other considerations; this means giving food safety and crime prevention absolute priority over other objectives.
- There is zero tolerance for food fraud, so minor dishonesties are discouraged, and the response to major dishonesties is punitive.
- There is a shared investment between government and industry in intelligence gathering and sharing, while having due regard to the sensitivities of the market.
- Those involved with audit, inspection and enforcement have access to resilient, sustainable laboratory services that use standardized, validated methodologies.
- Industry and regulators give weight to audit and assurance regimes to allow credit where it is due, but also try to minimize duplication where possible.
- Government support for the integrity and assurance of food supply networks is kept specific, measurable, attainable, realistic and timely (SMART).
- There is clear leadership and coordination of investigations and prosecutions, and the public interest is recognized in active enforcement and significant penalties for significant food crimes.
- When a serious incident occurs, the necessary mechanisms are in place so that regulators and industry can deal with it effectively.
Also created was the EU’s Food Integrity Project designed to bring all the stakeholders together to address food fraud and act as a hub for research and best practices. The organization is currently working on methods to anticipate where food fraud incidents are more likely to occur by looking at identifiers such as changes in commodity prices that might indicate a potential criminal interest in a certain food.
The US government’s efforts to address food fraud have not been as ambitious, although FSMA’s Preventative Controls Final Rule does include the prevention of food fraud incidents. Also, FDA, USDA and the Department of Homeland Security all have ongoing efforts to protect the food supply from adulteration, but often it is included as just one element of managing food safety risks.
Many food products that are susceptible to fraud, such as fish, honey and saffron, are inherently expensive to produce and bring to market. Plus, they have a high premium, and their appearance makes it hard to visually detect any adulteration.
Some products with a history of well-documented fraud and adulteration are subject to global standards and governmental regulations. However, because a number of regulatory bodies set different standards using their own criteria, there can be confusion about the quality and grades of products. For example, the International Olive Oil Council (IOC) sets the parameters for chemical and sensory tests to determine the quality and grading levels of olive oil. But, individual countries are responsible for enforcing the standards. In the US, there are only voluntary standards set by USDA, except in certain states.
Italian hard cheese also is an at-risk industry, according to Neal Schuman, CEO of Arthur Schuman, Inc., one of the largest Italian cheese producers in the US. Schuman says when his company conducted tests of hard cheeses, it found over 20 percent of the samples were adulterated.
“Some cheeses contained 30 percent cellulose, even though the Code of Federal Regulations recommends using only what is required for anti-caking purposes, which is generally understood to be around 3 percent,” Schuman says. Other forms of adulteration the company found were cheeses that contained vegetable-based products, had excessive starches and/or substituted cheeses with higher sugar levels. The company conducted a national quantitative study that determined many consumers are unaware of these issues, but 95 percent of those polled said they would be concerned if they found their cheese was adulterated.
Although the most common consequence of food fraud is economic loss, more disturbing potential outcomes exist, including public health risks, the ability of consumers to make educated food choices and the negative effect on the profits of legitimate producers.
The most recently publicized occurrence of a health risk associated with an EMA incident was in 2007 when melamine was substituted for wheat gluten in pet foods and linked to the illness or deaths of thousands of pets in the US. The source of the chemical came from China, which also had a melamine scare of its own the following year when it was found in infant formula reportedly causing widespread illness in Chinese children and possibly at least six deaths.
“While not all food fraud results in a public health risk, any act involving the intentional adulteration of food has the potential to do harm,” explains Don Hsieh, director of commercial industrial marketing for Tyco Integrated Security.
Some of the health risks may come from counterfeit products being produced, shipped or stored in conditions that would not meet the standards for regulated foods. “When food fraud occurs, many of the safety processes associated with food production are sidestepped,” notes Steven Guterman, CEO of InstantLabs, a molecular diagnostic device company that developed the Hunter real-time polymerase chain reaction system for pathogen and species detection. The species identification test kits focus on seafood, which is particularly vulnerable to fraudsters because a fish’s species is hard to identify once distinctive features like its head, tail and skin have been removed.
“When a fish is mislabeled, the consumer has no way of knowing if it was farmed in clean or polluted waters. For pregnant women, who should avoid any fish containing mercury or other toxins, this can be a major issue in the health of the child,” says Guterman.
Allergens also can present public health concerns. For instance, in 2015, the FDA sent out an advisory on products containing ground cumin that may have been contaminated with undeclared peanuts. “While there has been no definitive answer from the FDA about whether the adulteration may have been related to EMA, the high levels of peanut identified in cumin samples led many people to speculate the incident was, in fact, EMA,” says FPDI’s Everstine.
Experts agree prevention is the best way to stop food fraud. Even the Food Safety Modernization Act includes EMA in the preventative controls portion, with an emphasis being put on food producers to understand their food could be susceptible and for them to control their supply chain. However, processors might have to go beyond the measures in their current food safety plan.
“Risk assessment for EMA can be more complex than traditional food safety risk assessment because of the intentional nature of the act,” Everstine says. “Processors may need to consider additional factors that increase EMA risk.”
Some of these include the supplier relationship and whether an effective audit strategy is in place that includes anti-fraud measures, such as the ability to detect adulteration. Moreover, Everstine suggests paying attention to the economic environment surrounding a particular ingredient that might make it more susceptible to fraud, as well as any previous history of fraud associated with that ingredient.
John Spink, assistant professor and director of the Food Fraud Initiative at Michigan State University, says food is most vulnerable for fraud when it is in the supply chain and “more so when there is a change in ownership.”
In other words, the more vendors a product passes through, the more at risk it is for adulteration, which is why experts advise food or ingredients from third-party vendors should be tested by commercial food companies. In fact, more testing throughout the food production process was one of the recommendations made in the 2014 Elliott report. “These tests provide more than a back-stop against consumer complaints,” states Guterman. “They offer brand and business protection in the food marketplace where consumer health issues and recalls can quickly become the center of unfavorable media attention.”
Traditionally, rapid testing has not been available for many products, but PCR testing is now being offered. “It’s our goal as a company to provide the industry with the tools it needs to help with species ID,” Guterman says. InstantLabs has a number of seafood species tests currently available, including catfish, salmon varieties and snapper.
In addition, inexpensive testing using a UV-Vis spectrophotometer can detect the adulteration of foods like olive oil and maple syrup, says Robert Clifford, marketing manager for Shimadzu Scientific Instruments. He explains that oils from canola, corn, hazelnuts, palm, peanuts, safflower, soybeans, sunflowers, vegetables and walnuts have all been used to adulterate olive oil. However, ultraviolet spectra of olive oil and extra virgin olive oil can clearly distinguish the differences between the grades.
Mass spectrometry also played a role in exposing the 2013 European horsemeat scandal. Because it can “fingerprint” samples, mass spectrometry shows a specific compound or food product constituency.
“SCIEX scientists were able to develop an LC-MS/MS method that could detect specific horse protein markers [peptides] down to 0.1 percent in the presence of other meat products, as well as phenylbutazone [Bute], which is administered to horses to relieve pain,” explains Ashley Sage, senior manager of EMEA food business for SCIEX.
Track-and-trace packaging methods have been commonly used to prevent EMA. However, some food fraud incidents, such as this scandal, have proven the bigger problem is verifying the product inside the packaging. Consequently, the hunt is on to find better ways to confirm the integrity and authenticity of food. For example, researchers at Taaneh have developed a technology using diamond powder, an inexpensive and inert material that emits a range of spectral signatures that can be added in trace amounts to foods and beverages or to the labeling and packaging materials. “When diamond powder is added, its unique spectral image can be detected with a handheld scanner, providing a precise, instant confirmation of authenticity,” says Andrew Janoff, chairman and CEO of Taaneh, Inc.
MSU’s Spink says companies should look at EMA from the bad guys’ perspective and take measures to discourage them from attacking their industry. “Companies need to combat food fraud by implementing preventive measures that increase the likelihood of detection or the difficulty in carrying out the crime,” says Hsieh. “Organizations should consider a food defense strategy that addresses the entire food supply chain through the four A’s of actionable food defense: assess, access, alert and audit.”
According to Hsieh, businesses should conduct an initial vulnerability assessment of critical control points to identify likely places for attempted adulteration, focusing further upstream in the supply chain, including suppliers to direct suppliers. Next, processors should consider who has access to critical control points, such as those who could steal labels and place them on a substandard product for economic gain. “Securing cargo in transportation also should be a critical focus of a food fraud program, as product could be stolen, diluted or otherwise adulterated and then sold, again causing risk,” adds Hsieh. He also advises companies to employ technology to communicate food fraud risks as quickly as possible.
“Internet of Everything [IoE] technologies enable a view of the supply chain between farms, labs, manufacturing plants, warehouses and stores, while also showing the connected relationship between information, objects, people and processes,” explains Michele Festuccia, solution team leader for Cisco Systems Italia, which helped Barilla determine ways of using technology to present a unified, real-time digital picture of its entire supply chain.
For instance, Barilla customers can now trace the entire chain of production for the ingredients in their food, from where it was grown to how it arrived at the store, by using their smartphones to scan a QR code on the back of select packages of pasta and sauces. The IoE effort began with Barilla’s implementation of the Safety for Food (S4F) initiative aimed at introducing full data governance to support risk prevention and decision-making in the food supply chain.
“The main objective of the S4F project is the digital evolution of food supply chains to comply with international/Italian regulations in terms of safety, quality standards and origin of raw materials. This open data approach enables the strategic value of ‘information’ by aggregating data from all the disparate data silos,” says Festuccia.
Organizations also are encouraged to know and control their supply chains by auditing them. Hsieh recommends regularly and randomly auditing using remote video technology, as it “can go a long way in confirming appropriate preventative measures are in place and working.”
Addressing all fraud opportunities is key in preventing EMA, concludes MSU’s Spink, “and to consider not if, but how, fraudsters will circumvent your system.”
For more information:
Don Hsieh, Tyco Integrated Security, 800-701-8449,