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How To Do a Vulnerability Assessment for Food Fraud

Updated 30th December 2022

What is a vulnerability assessment?

 

A vulnerability assessment is a risk-assessment-style evaluation of a food’s vulnerability to food fraud.

A food fraud vulnerability assessment is a documented assessment that identifies vulnerabilities to food fraud and explains how those vulnerabilities were identified.

Vulnerability assessments are also done to assess the threat of a malicious attack on food.  Malicious attacks include attacks conducted for extortion, ideological reasons or terrorism. We call these issues of food defense. To learn more about vulnerability assessments for food defense (intentional adulteration), click here.

Why ‘vulnerability’ and not ‘risk’? 

 

  • A risk is something that has occurred before and will occur again. A risk can be quantified using existing data.
  • A vulnerability is a weakness that can be exploited.  A vulnerability can lead to a risk.

Food fraud is difficult to estimate and quantify, so we use the word vulnerability rather than risk.

Why do a vulnerability assessment?

 

  1. To protect consumers: Food that is vulnerable to food fraud presents significant risks to consumers.  Food that is adulterated or diluted   [Read more…]

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Interpol and Food Fraud; Celebrating 10 Years of Operation Opson

Operation Opson is a joint activity of Interpol and Eurpol that targets counterfeit and sub-standard food and beverages.

This year marks the tenth iteration of Operation Opson.

Operation Opson X ran from December 2020 to June 2021 in 72 countries. Food and drinks worth €53.8 M were seized and 663 arrest warrants were issued.  Honey, beverages and horsemeat were areas of focus for this operation.  You can find the official Europol press release here.

Honey

Authorities performed 495 checks on honey samples as part of Opson X.  Samples were obtained from all along the supply chain, including from the farmgate, wholesalers, distributors and retailers. Most of the checks aimed to detect added sugars or corn syrup in the honey.  Of the 495 checks, 7% were found to be non-compliant and 51,000 kg of honey was seized.

Beverages

During Opson X, the most problematic beverages were wine and vodka.  A total of 1.7 M liters of alcoholic beverages were seized by authorities.  For wine, fraudulent bottling and labeling was a notable problem, with wine bottling operation(s) in Italy allegedly applying labels that misrepresented the geographical origin of the wine. In Spain, whisky with added colorant was found.  The colorant was said to have been added to enhance the perceived quality of the product.

Horsemeat

Horsemeat and the use of unapproved horsemeat for human food continues to be a focus for food fraud enforcement in Europe.  During Opson X, authorities uncovered sophisticated operations in which horses that were not approved for human consumption were being traded across international borders with false documents.  Investigations are continuing.

Other Meat

A survey of meat products in Germany found that 3% of samples (n = 264) were affected by species substitution, that is, the meat contained species that were not declared on the label. Source: Food Safety News

Unsafe and Fraudulent Seafood

Spanish and Portugese authorities identified illegal fishing of bivalve seafood such as clams in a wide-ranging investigation.  The seafood was harvested illegally and was not processed, handled or labeled properly, resulting in potential food safety issues.  At least 12 fishing vessels were implicated.

Food Supplements

In this iteration of Operation Opson, food supplements and additives were the second most seized food type, by quantity, after alcoholic beverages.  At the time of writing no details of such seizures are available.

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2019; the year in review

Happy New Year and welcome to 2020.  Last year included many pleasing, positive developments in food fraud prevention.  More and more people from within the international food industry are becoming aware of the prevalence of food fraud and becoming better educated about the risks it poses to consumers and businesses.  There were new developments in technology and more enforcement activities, plus awareness has continued to spread to peripheral industries and unconventional marketplaces.   Food Fraud Advisors and our sister company Authentic Food launched new products and continued to serve our growing customer community across the globe.  Thank you for your support in 2019.  I look forward to serving you in 2020.

Karen Constable, Principal Consultant, Food Fraud Advisors

Better assessments and tests

Food safety professionals are becoming more comfortable with performing food fraud vulnerability assessments and I have seen the quality of assessments improve markedly in the past year.  Food laboratories are also gaining more expertise in food authenticity testing.  Better test methods have been developed, and this is helping the labs to do their jobs more easily,  but for me I think the most important thing is that laboratory sales personnel are becoming better at understanding the needs of their food business customers when it comes to food fraud detection.

Food testing labs have better tools to meet the needs of their food industry customers

 

New food fraud prevention strategies

The past year saw significant increases in proactive prevention initiatives that extend beyond typical anti-counterfeit tools.  As an example, a famous Scottish salmon brand has recently implemented a chemical ‘fingerprint’ system to allow them to pursue suppliers of inauthentic product across their growing global supply chain.  BeefLedger is a new provenance verification product, which supports Australian beef exporters through the use of blockchain technology.

International enforcement

In India, there has been an ongoing effort by the media to publicise food adulteration problems in that country.  In response, government authorities are tackling the problem head on, with the aim of increasing trust in the food supply.  Indian news outlets feature stories of seizures and shutdowns of illegal food outlets on an almost daily basis.  Tea, spices, ghee, jaggery, cooking oil and milk are often affected.  The Food Safety and Standards Authority of India has promised to reimburse the cost of food fraud testing for consumer samples tested by credible consumer organisations.

The food crime unit in the UK benefitted from more funding last year, which increased its investigative capacity and its ability to train people in other agencies on food fraud awareness and intelligence handling.

In Europe there appears to be a growing acceptance that some organised crime groups are actively choosing to include food fraud operations within their money-making portfolios.  Although this type of operation may not be the norm, it does occur and acknowledgement of the problem is an important step in the fight to intercept and control such crimes.

Operation Opson, a joint operation between Interpol, Europol and national law enforcement agencies was run again in 2019, for the eighth year.  Operation Opson sees fraudulent food, drink and supplements investigated, located and seized by authorities across the globe, from sub-Saharan Africa to South America.  The categories of items seized most often in 2019 were illicit alcohol, cereals (grains) and condiments.  This year also included targeted actions that focussed on organic foods, coffee and 2,4-Dinitrophenol (DNP), an illegal fat-burning supplement that has caused multiple fatalities in recently years.

Grain was the second most-seized food type in Operation Opson VIII

 

In the USA, enforcement activities are also on the rise.  In 2019 there were a number of high profile prosecutions of business owners in the seafood, beef and pet-food industries.  The implementation of the Food Safety Modernisation Act (FSMA) has improved the standard of knowledge about food safety hazards and controls across the food industry in that country.  Also in 2019, many USA food companies were required to meet the International Adulteration (IA) rule of FSMA for the first time.  The rule is designed to prevent malicious threats to public health from food adulteration.  While the IA rule is not technically related to food fraud, it has made an important contribution to the concept of food safety.  As the new decade unfolds, I predict we will continue to expand our understanding of food safety; from our historical focus on natural and accidental contaminants to wider awareness of the risks posed by deliberate, human-mediated hazards.

Marketplace improvements

The good news continues, with 2019 witnessing a small but subtle shift in the willingness of online marketplace owners to talk about the problem of counterfeit goods in general, and counterfeit foods, drinks and supplements in particular.  There has been a change in the discourse around counterfeit products which increasingly addresses safety issues in addition to financial costs.  While many consumers and retailers continue to tolerate, or even seek out, counterfeit fashion items, more businesses are becoming aware of the prevalence of unsafe counterfeit supplements, foods and electronic components in online marketplaces.  And as awareness grows, I expect enforcement and preventive activities to follow; resulting in gradual improvements to the way we source and supply goods online.

Beyond food and drink

The food industry’s anti-fraud crusade has spilled over into related industries, including agricultural chemicals and packaging materials.  These two global heavy-weights are benefitting from the food industry’s food fraud awareness and prevention strategies of recent years.  As an example, the British Retail Consortium (BRC) included raw material fraud prevention activities in its most recent Packaging Materials Standard.   In pesticides, Operation Silver Axe resulted in the seizure of 550 tonnes of illegal or counterfeit pesticides across Europe.

The packaging materials industry has benefitted from lessons learned in food fraud prevention

Our year in review

Last year Food Fraud Advisors passed the 2000 downloads milestone for our tools and templates.  We continue to receive wonderful feedback and rave reviews for  our tools, templates and downloads.

We have customers in 48 countries, from large multinational food conglomerates to small start-ups, and everything in between.  While most are food manufacturers, this year we have had more customers from businesses peripheral to food production, such as brokers, logistics businesses and packaging manufacturers.  Students and consultants continue to make up a small but significant proportion of our online learning community.

 

New products

With our sister company, Authentic Food, we developed and launched the Intentional Adulteration Vulnerability Assessment Tool in June.  It filled an important gap for businesses in the USA, as there are few resources to help meet the requirements of the new FSMA IA rules and regulations.

Our vulnerability assessment tool for packaging materials was launched in November.  This tool is designed specifically to meet the requirements of BRC Packaging Materials Issue 6 which, for the first time, includes requirements to address food-fraud-like issues within the supply chain of packaging materials.  Purchasers of the packaging vulnerability assessment tool also receive a free threat assessment tool that generates a product defense plan for site security and product safety.

Our free Food Fraud Risk Information Database continues to grow.  It currently contains more than sixty five thousand words.

My favourite thing about 2019 was having the opportunity to interact with so many intelligent and resourceful food safety professionals from all over the world, as we work together to make our food supply safer for everyone.   I look forward to more of the same this year.

 

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How food fraud is uncovered; two cases of origin fraud

Origin fraud occurs when a food is misrepresented with respect to its geographical origin; it’s a type of fraud that can be categorised as ‘mislabeling’.

Examples of mislabeling include:

  • describing a fruit or vegetable as ‘organic’ when it was conventionally grown
  • cheeses and meats labeled as kosher or halal that are not
  • Spanish olive oil falsely declared as being ‘Italian’.  This is origin fraud.

Mislabeling is also called misbranding in some countries.  Because it is intended to deceive customers and consumers it is illegal under consumer protection laws and trade/contract laws just about everywhere.  Because almost every type of food fraud involves mislabeling to some extent, quoting statistics on mislabeling is difficult.  As an example, a botanical supplement labelled as 100% turmeric extract but that actually contains 15% filler is both mislabeled and diluted.  To make it even trickier, different organisations using different words to describe similar food fraud activities.  Learn more about classifying food fraud types in this great Food Safety Tech Article.  Suffice to say, mislabeling fraud is very common and, according to US Grocery Manufacturers Association, it affects around 10% of food products globally.

Coffee growers in Hawaii have launched a class action to protect their products

How do we expose origin fraud?  Typically, origin fraud is uncovered after authorities have been tipped off about suspect activity in a supply chain, either by people from within the supply chain or by competitors of the mislabeled product.   The evidence used to pursue the fraudsters often comes from either fraudulent documentation, or from testing of finished products.  This year we have seen an increase in the use of authenticity testing by representatives of ‘authentic’ brands to expose fraudulent products.  This is a trend that I expect to continue as test methods are improved, refined and can more easily be extended to assess specific product attributes.

I have been following this trend with interest and was reading, today, about alleged origin fraud in coffee in the United States. This is a case that is representative of the trend to use sophisticated test methods to authenticate finished product attributes.  Another recent example would be honey testing in Australia.  In the coffee case, growers from the Kona district of Hawaii have filed a lawsuit against retailers for allegedly selling ‘Kona’ coffee that does not contain a reasonable amount of coffee from the district. Kona coffee production is 2.7 million pounds, however more than 20 million pounds of coffee labelled ‘Kona’ is sold each year.  The plaintiffs claim to have analytical test results to support their claims.  Nineteen brands of coffee, sold by retailers including Walmart, Cosco and Amazon, have been named in the complaint.  Chemical testing technology underpins this current lawsuit, as it allows the coffee growers to show, for the first time, the actual Kona content of the coffee that is being allegedly mislabeled.  For this to be possible, the coffee growers would have had to organise for testing laboratories to create a database of chemical test results of authentic samples of Kona coffee.  Databases like this are used to model a product’s unique chemical fingerprint using sophisticated mathematical computations.  The test method can then be used to compare the ‘fingerprints’ of suspect brands against those of authentic products, such as Kona-grown coffee, and infer the amount of genuine material in each sample.  Developing databases for this type of testing is expensive and time consuming.  However, there are an increasing number of laboratories that have the machinery, skills and software to perform this work, so it is becoming more accessible to brand owners.

Specialty vinegars fetch high prices and can be vulnerable to economically motivated food fraud.

In cases that do not originate with product testing, it is activities in the supply chain that provide clues to origin fraud.  This month there have been reports of origin fraud for a specialty vinegar, Modena balsamic vinegar.  Modena balsamic is protected by a special geographical designation under European regulations.  According to these rules, Modena balsamic vinegar must be produced using grapes only from certain regions in order to be considered authentically ‘Modena’.  A massive fraud involving 15 million Euros worth of materials has been uncovered in Italy after a special operation by local authorities found that the wrong grapes were being used to produce this very expensive product.  Although operational details about this investigation are scarce, these types of actions by authorities are often initiated after authorities have received a tip off from someone connected with the supply chain.   Another example of such a tip-off includes this recent wine counterfeiting operation in which authorities became aware that a printing shop had received an order for 4,500 wine labels from a company that was not the brand owner.

More tip-offs and more testing are my predictions for 2019 and 2020.  These are going to lead to more investigations, complaints and enforcement actions against perpetrators of food fraud.  And that’s a win for everyone!

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Where’s my tricorder?

We would all love to have a magic machine that can tell us exactly what is in a food or a health supplement, but our current technology isn’t quite at the level of Star Trek yet.  Here’s a question asked recently on Reddit/foodscience . It follows a common theme for questions asked by entrepreneurs who are investigating food and supplement business opportunities.

Supplement testing

 

Question: How do I test supplements to make sure the ingredients are authentic and organic?

The Reddit poster explained that he had stumbled upon a mix of plant extracts that helped his acne and wants to make and sell a pill with those ingredients.  He writes:  “I sourced some plant extract manufacturers in china but I do want to test the plant extracts to check if they are actually what they are and if they are truly organic. Can someone please point me in the right direction as to how to do that?“.  A food manufacturing expert suggested that he seek a contract manufacturer to make the pills for him, which he said sounded like a good idea.  Then he asked “I’d feel a lot better if there was maybe a machine I could buy to check the composition of what was in there“.

Answer: I think you want a Star Trek Tricorder

I wish it was possible to buy a magic machine that will tell you what is in a product.  On the other hand I am a food/supplement fraud expert so if there was such a thing I wouldn’t have a job.

Organic testing is ‘simple’. Sort of.  To test for ‘organic’ status in a finished capsule supplement you can check that pesticide residues are absent.  There is no technology that allows you to put a pill into a machine and ask it to look for ‘anything’, so you need to ask the machine to look for specific pesticides.  The USDA perform this type of testing every year on fruit and vegetables.  Each sample is tested separately for around 200 different pesticides.  The USDA use a network of independent labs so it should be easy to find a lab that can test your finished product for pesticide.  More on the pesticide testing program here:  https://www.ams.usda.gov/datasets/pdp

Authenticity testing is not simple.

Herb-like ingredients can be tested for authenticity by an expert who looks at them under the microscope.  This only works if they are not ground up too small.

Liquid extracts and soluble powders can be tested using chromatographic methods, such as HPLC and GC.  In these methods the machine creates a chemical ‘fingerprint’ for the material and then compares that to the fingerprint of an authentic sample.  There are two things that make it difficult: firstly you need to find a lab that knows what an authentic sample fingerprint looks like for the material you want to test (they call this ‘having a database’); secondly, these methods are best suited to single ingredients.  Once you mix a whole bunch of ingredients together, if you test the mixture all the chemical fingerprints get mixed up and the machine can’t tell you which peak (which part of the ‘fingerprint’) comes from which ingredient.  There are ways around this but the methods are expensive as the databases are custom-made for each finished product that is to be tested.

Unfortunately it usually comes down to trust in your suppliers and a reliance on their systems and certifications.  Check all certifications to make sure they are not forged as unfortunately that is common in some countries.  Do this by contacting the certifier directly.

Reddit user: Karenconstable4

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