the food fraud toolbox: the weapons you need to fight food ... · intentional adulteration from...
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The Food Fraud Toolbox: the weapons you need to fight food fraud.www.integritycompliance.com.au1300 367 810
What is food fraud?Economically Motivated AdulterationFood safety: HACCP hazards: prevention of unintentional/accidental adulteration Science based. food borne illness.
Food Defence: TACCP: threats Prevention of intentional adulteration. Ideologically motivated i.e. bioterrorism.
Food Fraud: VACCP: vulnerabilities Prevention of intentional adulteration. Economically motivated.
What is food fraud?Definitions by country:FSMA (USA): Intentional adulteration from acts intended to cause wide-scale harm to public health, including acts of
terrorism targeting the food supply. Hazard may be intentionally introduced for purposes of economic gain.
UK: Food fraud is considered to encompass the deliberate & intentional substitution, addition, tampering or
misrepresentation of food, food ingredients, or food packaging, or false or misleading statements made about a product for economic gain.
Australia: Gaining a financial advantage or causing a financial disadvantage through deception or dishonesty.
Most common foods susceptible to food fraud:1. Olive oil
2. Fish
3. Organic foods
4. Milk
5. Grains
6. Honey and maple syrup
7. Coffee and tea
8. Spices (saffron and chilli)
9. Wine
10. Fruit juices
Source: EU 2013/2091
Oceana conducted one of the largest seafood fraud investigations in the world to date, 1200 seafood samples from 674 retail outlets in 21 states of the USADNA testing found that one-third (33%) of the 1,215 samples analysed nationwide were mislabelled, Mislabelling was found in 27 of the 46 fish types tested (59%).
Salmon, snapper, cod, tuna, sole, halibut & grouper were the top collected fish types.
Snapper (87%) & tuna (59%) were the most commonly mislabelled fish types.
Only 7 of the 120 red snapper samples were correctly labelled.
44% of all the grocery stores, restaurants & sushi venues visited, sold mislabelled seafood.
Sushi restaurants were far more likely to mislabel their fish than grocery stores or other restaurants.
In Chicago, Austin, New York & Washington DC, every single sushi restaurant sampled sold mislabelled tuna.
84% of fish samples labelled "white tuna" were actually escolar, a fish that can cause prolonged, uncontrollable, explosive, oily, orange diarrhoea.
http://www.franciscoblaha.info/blog/2017/2/22/59-of-the-tuna-americans-eat-is-not-tuna
“Organic” Food
The labels said ‘organic.’ But these massive imports of corn & soybeans weren’t.
• A shipment of 36 million pounds of soybeans sailed late last year from Ukraine to Turkey to California.
• The cargo began as ordinary soybeans & they were fumigated with a pesticide.
• But by they arrived in California in December, the soybeans had been labelled “organic,” according to receipts, invoices & shipping records.
• The addition of the “USDA Organic” designation — boosted their value by approximately $4 million, creating a windfall for at least 1 company in the supply chain.
• About 21 million pounds of the soybeans have already been distributed to customers.
https://www.washingtonpost.com/business/economy/the-labels-said-organic-but-these-massive-imports-of-corn-and-soybeans-werent/2017/05/12/6d165984-2b76-11e7-a616-d7c8a68c1a66_story.html?utm_term=.0e79bc2238f8.
“Where did all this big production come from? Where are these organic farmers?”
• The USA has seen large spikes in the amount of organic corn & soybeans entering from Turkey.
• Between 2014 & 2016, the amount of organic corn arriving from Turkey rose from 15,000 to more than 399 000 tons; the amount of organic soybeans coming from Turkey rose from 14,000 to 165,000 tons.
• Under USDA rules, a company importing an organic product must verify that it has come from a supplier that has a “USDA Organic” certificate. It must keep receipts & invoices, but need not trace the product back to the farm.
• The soybeans arrived aboard the “Four Diamond” at the port of Stockton in December 2016.
• A set of health certificates that accompanied the soybeans allowed the Washington Post to trace the soybeans from California to Turkey & to their origin in the Ukraine.
• The soybeans were fumigated with tablets of aluminium phosphide, a pesticide prohibited under organic regulations.
“Where did all this big production come from? Where are these organic farmers?”
• Some of the soybeans originated from ADM Ukraine, a company that does not produce or trade organic soybeans & did not sell or label them as such, a company spokeswoman said.
• Invoices for those soybeans showed that they were originally priced at about $360 per ton.
• By the time they reached the USA, the price reached almost $600 per ton.
• Global Natural, the Annapolis-based firm that was marketing the soybeans in the USA, said it has stopped selling “all potentially affected product.”
• The importer of the soybeans is Agropex International. Ashley Anderson, the president of AgropexInternational, insisted that the soybeans that arrived in Stockton are legitimately organic.
Thousands of years of food fraudSource: Independent, 18 February 2015
2014–2016 there were 67 different cumin related recalls in the UK (15), EU (2), USA (675 food products in 47 recalls) and Canada (3) for undeclared allergen of tree nuts and peanuts supplied from Turkish brokers, most likely sourced from India. The presence of nut allergens caused by the cumin powder being “watered” down with ground almond/peanut shells/husks (5000–100 000ppm) of peanut).
Peanut protein was found in ground cumin in North America, in late 2015. This started a cascade of recalls, which in turn made the UK authorities start testing and they found both peanut and almond contamination.
The product recalled in Canada, ended up not being contaminated with nuts but with Mahaleb — ground up seeds from a type of cherry.
http://www.independent.co.uk/life-style/food-and-drink/news/six-more-uk-food-products-recalled-as-nutsforspices-crisis-spreads-across-europe-10052390.html
How it happened?Source: Independent, 18 February 2015
Higher-than-normal temperatures in India decimated the 2014- 2015 cumin crop, with yields 40 % to 50% less than those of past harvests. Prices skyrocketed as a result.
Cumin is the most commonly used spice in the EU.
Adding just 1 percent peanut shells at zero cost is essentially a profit of $350 to $400 on a sale of 10 tons of ground cumin.
http://www.independent.co.uk/life-style/food-and-drink/news/six-more-uk-food-products-recalled-as-nutsforspices-crisis-spreads-across-europe-10052390.html
Thousands of years of food fraudSource: The Times of India, 19 November 2015: The kingpin behind adulteration of spices, Rajesh Gupta, has a wide network to carry out his nefarious activities in the city. On Wednesday, south zone police arrested 14 persons, including 11 traders of Begum Bazar, Hydrabad for adulteration of spices like black pepper, poppy seeds, cumin and shazeera (caraway seeds). Gupta has been supplying 20,700 kilos of adulterated black pepper, cumin, poppy seeds every month to 11 wholesale merchants in Begum Bazar. He similarly would supply 15,000 kilos of adulterated spices every month to traders in Delhi and Raipur.
"Gupta used to supply the adulterated spices at 75 percent rate of the market price to the wholesalers and they in turn used to package them under various fancy labels and dispatch them to retailers for 10 to 15 per cent profit. The retailers make about five to 10 per cent profit by selling them at a market price. Gupta is making about Rs 7 to Rs 10 lakh profit per month and he used to pay Rs 5 per KG to cargo services for illegal transportation of spices along with raw material across various states," the DCP said.
timesofindia.indiatimes.com/city/hyderabad/Cops-arrest-kingpin-of-spices-adulteration/articleshow/49838743.cms
A 2014 US Congressional Research Service uncovered extensive fruit juice fraud.
“Juices might be watered down, or a more expensive juice (such as from pomegranates or other ‘super’ fruit) might be cut with a cheaper juice (such as apple or grape juice).
Some juice may be water, dye and sugary flavourings, although fruit is the listed ingredient on the label.
Orange juice has been shown to sometimes contain added unlisted lemon juice, mandarin juice, grapefruit juice, high fructose corn syrup, paprika extract and beet sugar.
Apple juice has been shown to have added unlisted grape juice, high fructose corn syrup, pear juice, pineapple juice, raisin sweetener, fig juice, fructose and malic acid.”
https://fas.org/sgp/crs/misc/R43358.pdf
Flavor Fresh Foods of Chicago pleaded guilty to defrauding consumers of more than $40 million.
Peninsular Products, shipped the juice from Brazil to a Canadian company which added sugar. The juice was sent on to Flavor Fresh Foods, which diluted it with a cheap, bitter by-product of squeezed oranges called pulp wash.
To cover the adulteration, Flavor Fresh added citric acid and amino acids that occur naturally in juice.
The juice then went back to Peninsular, which added more orange juice, more pulp wash and preservative.
https://www.newscientist.com/article/mg14219263-700-real-juice-pure-fraud-trading-standards-inspectors-in-europe-and-north-america-are-cracking-down-on-the-fraudsters-who-adulterate-fruit-juice-but-sell-it-as-pure-says-tara-patel/
Raw material assessment: variables for considerationLikelihood:of fraud occurring currently.
Detectability:within the current process.
Profitability:how profitable the activity would be for a fraudster.
Historic incidences Existing controls: Audits that assess adulteration, mass balance, traceability.
Economic factors/price changes.
Emerging issues Routine product testing: how likely are they to detect adulterated materials and frequency.
Availability of cheaper substitutes.
Economic factors/price changes.
Geographic origin/length and complexity of supply chain i.e. more entry points.
Geographic origin/length and complexity of supply chain i.e. more entry points.
Complexity and cost of committing the fraud.
Ease of access to raw materials & availability Ease of access to raw materials i.e. broken tamper proof seals?
Ease of access to raw materials.
Value of raw material Nature of the raw material i.e. value and sizeof the market.
Physical form: whole, minced, dried, liquid. Physical form: whole, minced, dried, liquid.
Information sources:Worldwide Recall notices:
www.foodstandards.gov.au/recalls
http://ec.europa.eu/food/food/rapidalert
http://www.food.gov.uk
http://www.fda.gov/Safety/Recalls/default.htm
EU border rejection notices:
https://webgate.ec.europa.eu/rasff-window/portal/?event=notificationsList&StartRow=1
FICA (Food Import Compliance Agreement) failing foods list http://www.agriculture.gov.au/import/goods/food/inspection-compliance/failing-food-reports
The following highlights have been added to HorizonScan.
Issues concerning Honey Date Notified By Issue Country of Origin Company 27/Jul/2018 The Czech Republic Honey found to show several signs of
adulteration - addition of sweetener,strange smell, enzyme diastase, high levels of HMF, pollen analysis suggests honey is form a different origin to that declared
The Czech Republic
Český med, Valašské MeziříčíČeská republika
Highlights concerning Oils and fats Date Issue Summary 24/Jul/2018 Spain’s largest olive oil cooperative under fire for its importing practices.
The fine originated from outstanding import tariffs that Qorteba International failed to pay on olive oil it had imported from Tunisia and Morocco. The imported oil was then blended with low quality Spanish olive oil that had been obtained in second extractions from olives used in the production of extra virgin olive oil. This blend was then sold as virgin olive oil in the United States at prices 40 percent lower than other Spanish and Italian olive oil and up to 100 percent lower than olive oils from California.
Food fraud in olive oil
Reported Food Fraud:www.foodfraud.org
Food fraud information sources?
https://www.europol.europa.eu/newsroom/news
https://secure.fera.defra.gov.uk/foodintegrity/index.cfm
Food fraud information sources?
https://trello.com/b/aoFO1UEf/food-fraud-risk-information
Ingredient Pricing
https://www.alibaba.com/showroom/
https://www.agmrc.org/commodities-products
https://www.tridge.com/intelligences
https://www.freshfruitportal.com
https://www.allthingssupplychain.com
http://www.commoditiescontrol.com/
https://www.thegrocer.co.uk/buying-and-supplying/categories/
USDA Global Ag Trade System: http://apps.fas.usda.gov/gats/default.aspx
Indian Govt commodity prices: https://data.gov.in/keywords/commodity-prices
Raw material assessment: Priority Risk NumberLikelihood: of fraud occurring currently.
Detectability: within the current process.
Profitability: how profitable the activity would be for a fraudster.
1 = Improbable event: Once every five years
1 = Will be detected, i.e. detection procedure is applied frequently and is reliable.
1 = Very low profit %
2 = Remote possibility: Once per year 2 = Detection procedure is applied. 2 = Low profit %
3 = Occasional event: Once per month3 = Fairly unlikely to be detected.
3 = Moderate to significant profit %
4 = Probable even: Once per week 4 = Unlikely or remote chance of detection.
4 = High profit %
5 = Frequent event: Once per day. 5 = No detection controls are applied. 5 = Very high profit %
Raw material assessment: Priority Risk Number
The final stage is to multiply the three ratings to obtain a PRN score, as follows: Priority risk number (PRN) = Likelihood (L) × Detection (D) × Profitability (P)
The output of the calculation is therefore a PRN for each raw material (or group of raw materials) with a value of 1 (overall very low risk) to 125 (overall extremely high risk).
Product and supply chain: CINNAMON GROUND: dried, ground bark of Cinnamomum cassia blume
Hazard and cause The presence of almond powder & cassia bark.
Emerging issuesIn 2015 there were 3 cases of undeclared tree nut allergens (almonds) in the EU. In 2016 70% of samples of cinnamon bark in India have been found to be adulterated. In 2013 more than 50% of Danish bakery items were found to contain illegal levels of coumarin, indicative of cassia substitution.
Economic factors The price of cassia is far below that of cinnamon and is imported in large quantities from India to China. This product is purchased via a broker & the price has more than doubled in the last 5 years but very little volume is purchased.
Access to raw materials through the supply chain
Cinnamon has a long shelf life, is readily available in powdered form. The spice is grown on developing countries (southern India & Sri Lanka) & travels through a complex supply chain. Long history of substitution of cinnamon with cassia bark as the 2 plants grow closely together and have similar colours and smells.
Complexity and cost of committing the fraud.
The product specification states “Made in Vietnam & China”. But no information with regard to the identity or certifications for the source manufacturer is given. It is possible that it is made by Olams at their Vietnamese spice processing plant and if so, they are BRC certified.
Controls in place. No samples are assessed & no Certificate of assurance is received from the supplier.
Likelihood of hazard occurring Cinnamon is at very high risk of food fraud and no information has been supplied with regard to the actual source. Rating of 4
Detectability Based on current control measures, it can be assessed as not in place & very unlikely to detect potential substitution: Rating of 5
Profitability Based on current information, it can be assessed moderate to significant margins. Rating of 3.
Priority Risk Number Likelihood 4 x Detectability 4 x Profitability 3 = 60
Product and supply chain: CINNAMON GROUND Cinnamomum verum syn. Zeylanicum
Hazard and cause The presence of almond powder & cassia bark.
Emerging issuesIn 2015 there were 3 cases of undeclared tree nut allergens (almonds) in the EU. In 2016 70% of samples of cinnamon bark in India have been found to be adulterated. In 2013 more than 50% of Danish bakery items were found to contain illegal levels of coumarin, indicative of cassia substitution.
Economic factors The price of cassia is far below that of cinnamon and is imported in large quantities from India to China.
Access to raw materials through the supply chain
Cinnamon has a long shelf life, is readily available in powdered form. The spice is grown on developing countries (southern India & Sri Lanka) & travels through a complex supply chain. Long history of substitution of cinnamon with cassia bark as the 2 plants grow closely together and have similar colours and smells
Complexity and cost of committing the fraud.
The product purchased states “Made in Sri Lanka”. No information has been supplied about the source supplier and the Australian importer has only supplied an out of date 2nd party HACCP certificate.
Controls in place. No assessment of received material. Certificate of assurance is usually received from the supplier initially not regularly- but no C of A has been supplied at all for this specific product.
Likelihood of hazard occurring Cinnamon is at very high risk of food fraud. Rating of 4
Detectability Based on current control measures, it can be assessed as not in place and very unlikely to detect potential substitution: Rating of 4
Profitability Based on current information, it can be assessed moderate to significant margins. Rating of 3.
Priority Risk Number Likelihood 4 x Detectability 5 x Profitability 3 = 48
Product and supply chain: CINNAMON GROUND S/S: steam treated, dried, ground bark of Cinnamomum cassia blume
Hazard and cause The presence of almond powder & cassia bark.
Emerging issuesIn 2015 there were 3 cases of undeclared tree nut allergens (almonds) in the EU. In 2016 70% of samples of cinnamon bark in India have been found to be adulterated. In 2013 more than 50% of Danish bakery items were found to contain illegal levels of coumarin, indicative of cassia substitution.
Economic factors The price of cassia is far below that of cinnamon and is imported in large quantities from India to China.
Access to raw materials through the supply chain
Cinnamon has a long shelf life, is readily available in powdered form. The spice is grown on developing countries (southern India & Sri Lanka) & travels through a complex supply chain. Long history of substitution of cinnamon with cassia bark as the 2 plants grow closely together and have similar colours and smells.
Complexity and cost of committing the fraud.
The product purchased states “Made in India with ingredients from: India & China”. Imported into Australia by a BRC certified company who have a documented food fraud assessment of all ingredients, who must be able to prove full traceability but choose to not disclose the source supplier.
Controls in place. All deliveries tested assessed for taste, smell and conformation to specification. Certificate of assurance is received from the supplier.
Likelihood of hazard occurring Cinnamon is at very high risk of food fraud. Rating of 4
Detectability Based on current control measures (sensory testing & C of A), it can be assessed as in place and applied. Some types of substitution will be detected but not all substitution will be detected: Rating of 2
Profitability Based on current information, it can be assessed moderate to significant margins. Rating of 3.
Priority Risk Number Likelihood 3 x Detectability 2 x Profitability 3 = 24
Product and supply chain: MODIFIED TAPIOCA STARCH & TAPIOCA STARCH.
Hazard and cause
White fine powder. A number of food fraud cases could be found for food chemicals generally including: unlabelled colours and flavours, melamine, added sodium nitrate & added malic acid. None could be found for this product (only undeclared allergens & micro contamination) as this product is usually used as a filler in other products.
Emerging issues No emerging issues could be identified.
Economic factors No economic factors could be identified as incentive for food fraud.
Access to raw materials through the supply chain
To match the products visually would be easy with numerous substitutions but unless they matched the chemical properties of each product the final product would not meet requirements.
Complexity and cost of committing the fraud.
The products are made in the same Thai processing plant. The Thai plant has supplied a current BRC certificate.
Controls in place. No samples are taken or tests undertaken on the raw materials. Certificate of assurance is received for the all products.
Likelihood of hazard occurring Possible likelihood of fraud occurring and being purchased. Rating of 1
Detectability Based on current control measures, it can be assessed as in place and applied but may not detect all potential substitution: Rating of 3
Profitability Based on current information, it can be assessed as low margins. Rating of 2.
Priority Risk Number Likelihood 1 x Detectability 3 x Profitability 2= 6
Potential Cinnamon control measures• All deliveries tested assessed for taste, smell & conformation to specification.
• Random testing of raw materials to verify the Certificates of analysis.
• Should highly consider testing for coumarin content as cassia contains 0.8% to 10.63% coumarin & cinnamon only 0.2%.
• Read your specification in detail. Know what you are buying.
• Cross check the information in the specification to the carton downstairs. Does the info match ?
• Identify all steps within the supply chain & obtain & verify all supplied Food Safety certificates.
• Use the SQF/BRC Databases.
• Understand the different standards & if they include food fraud assessment & supply chain traceability ie GFSI requirements.
If it doesn’t look right, feel right or smell right it probably isn’t right.
EU Horsemeat Scandal
What happened next ….…• Findus changed their purchasing practices so that all
purchasing activities were centralised, along with the supplier approval process.
• All purchasing staff were retrained in risk assessment & HACCP, so that they fully understood the implications of their purchasing decisions.
• The commercial staff had routinely collated information on food commodity prices so that purchasing decisions could be made for the whole company.
• The food safety team were given the market commodity knowledge so that they could look at the rise & fall of the prices & see what product could be substituted by another cheaper product.
Since then …
To improve technical risk analysis, commodity & pricing information were incorporated into the food safety assessment, so that future likely substitutions could be identified & tested.
Findus UK purchased a PCR analyser & equipped their in-house analytical laboratory with the capability to carry out DNA testing, thus increasing their ability to test incoming raw materials, co-packed products & the testing frequency & flexibility of their own production.
Is Blockchain the only answer?
Is Blockchain the only answer?
Mitigation strategies: Intelligent packaging
When a counterfeiter looks at a supply chain, they look for the weakest link – it’s almost always where counterfeits/parallel imports are introduced in exchange for authentic products.
Embed a Covert Tracer in your packaging inks, dies or plastics, resulting in the anti-counterfeit deterrent becoming part of the product.
Invisible nanocrystals embedded into a product which forms an individualized Nanotag, readable by a proprietary smartphone application.
Invisible to the human eye, scanners can detect a covert tracer & provide instant verification.
Use scanners to verify your own product’s authenticity.
http://www.ypbsystems.com/technology/image_recognition.php
Mitigation strategies: Intelligent packagingApps authenticate Australian wine in China:Chinese IT firm Invengo has joined forces with Deloittes & a company co-owned by retired Australian basketball player Andrew Vlahov to develop an app to authenticate Australian wines.
The app-based system - which authenticates codes placed on wine bottle labels & allows the bottle to be traced back through the supply chain - is being road-tested by Australian winery Ferngrove.
Australia is the second most prolific exporter of wine to China after France, which has just signed an accord to collaborate with the Chinese authorities in the fight against counterfeit wines & spirits.
https://www.securingindustry.com/food-and-beverage/brief-apps-authenticate-australian-wine-in-china/s104/a2030/#.WV5XgIVOLIU
Mitigation strategies: Product authentication & traceability.
• Each item with a unique code can be ‘digitally followed’, grouped into coded boxes & collated into coded pallets. This allows a shipment to be broken down & rerouted to various storehouses, while maintaining full visibility & verification of the original shipment throughout its journey.
• Shipments can be tracked in real time using the location of the registered user’s phone. For example, track the location of a truck shipment by geo-locating the driver’s phone.
• Shipments can be scanned, verified, checked in or out by the registered users of a secure app to ensure the shipment’s integrity at all times.
• User friendly & powerful smartphone applications allow you & your customers to identify & report suspected counterfeit or divergent products.
http://www.ypbsystems.com/technology/image_recognition.php
http://www.reuters.com/article/us-newzealand-australia-china-counterfei-idUSKBN17B10F
Mitigation strategies: Product authentication & traceability.
• SafeTraces' on-food source assurance solutions, use seaweed DNA-based tags that provide producers, processors & consumers with visibility into food origin & safety.
• SafeTracers™ are invisible, edible, tasteless FDA-approved barcodes that are applied directly to the food, not the cardboard & deliver complete source information in minutes.
http://markets.businessinsider.com/news/stocks/SafeTraces-Secures-6-5-Million-Series-A-Financing-Round-Led-by-Omidyar-Network-to-Advance-Disruptive-On-Food-Source-Assurance-Solutions-1004895887
Mitigation strategiesRaw material controls Test (targeted and randomly) and trace.
Testing: retained samples, chemicals, allergens, micro, species & sensory assessment.
Test methods i.e. NIR for species testing without destruction instead of DNA.
Innovative testing methods: identification of the geographical origin of honey using mineral and trace elements, flora genomes, pollen content, isotopes of carbon, nitrogen, hydrogen and sulphur.
Spices tested for: dyes, chemical residues, micro contamination, DNA, volatile oils, geographic source, heavy metals using HPLC methods.
Need to understand what product to test, which test to use and for what end ?
Dunedin company 'fingerprints' free range eggs to prevent food fraud
• A Dunedin company's "fingerprinting" of free range eggs is helping deter food fraud.
• Oritain recently began authentication testing for large Australian free range egg producer Farm Pride, & has just been engaged by Foodstuffs to provide traceability for its Pams free range eggs.
• The testing measures trace elements that occur naturally at each farm & are absorbed by the hens living there.
• Analysis creates a unique fingerprint that is then used to verify the origin of the eggs.
http://www.stuff.co.nz/business/90730144/dunedin-company-fingerprints-free-range-eggs-to-prevent-food-fraud
Food fraud is not new …
Food Adulteration and its Detection by Jesse P. Battershall in 1887.
Detection of the Common Food Adulterants by Edwin M. Bruce in 1907.
TEA AND OTHER LEAVES
