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How to design a food fraud testing plan

Authenticity testing of ingredients and foods is an important tool in the fight against food fraud, but it’s not easy to get it right.  Here are our recommendations to help you design a food authenticity testing plan.

  1. First define the goals of the testing plan.  Because different materials have different food fraud risk profiles, you will need a different testing protocol for each material that you want to test.  For each material to be tested, choose a test type and laboratory and set accept-reject criteria for test results.  Use our testing checklist to help.
  2. Decide how samples will be collected, and define the sample size with the help of your chosen laboratory. For each lot or batch of material that needs to be tested, figure out how to obtain a sample that is properly representative of that batch. Sampling protocols will depend on the size of the lot, the form of the food (solid, liquid, bulk, etc.) and the practicalities of accessing materials within the batch.  Learn more about sampling protocols from the US FDA’s laboratory manual.
  3. Choose a frequency of testing for each material and document it in the plan.
  4. Write down your goals, test methods, accept/reject criteria, sampling procedures and approved laboratories.  This written information will be the foundation for your testing plan document. Add a description of what action you will take if you get results that confirm or imply authenticity problems with the sample. Who will you report the results to? Who is responsible for making decisions about actions to be taken?  Add document control features and file the plan within the food fraud section of your food safety management system.
  5. Implement your plan.  Be prepared to change your test frequencies or test methods as new information becomes available.  Review your test plan at least annually to make sure it aligns with your food fraud vulnerability assessment results.

Read this next: Food fraud testing frequency: how often should you test?

 

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Food testing checklist

Like many other food safety and quality professionals, perhaps you are thinking about implementing a testing program for food fraud detection.  Are there vulnerabilities in your supply chain? Maybe you are buying products or raw materials that are on our food fraud hot list, or perhaps your food fraud vulnerability assessments identified materials that might be affected by food fraud.

Food authenticity testing laboratory lab

Testing is an important tool in the fight against food fraud, but it’s not always easy to get it right. Are you prepared for testing? Before you begin to contact laboratories, make sure you can answer these questions:

  • Do you need a ‘snap-shot’ of a product at a single point in time or are you aiming to build a longer-term picture of authenticity?
  • Are you acting on any specific information, such as a tip-off or allegation from a competitor?
  • Is there a particular adulterant you need to look for?
  • Are you a brand owner checking possible counterfeits or diverted products to determine if they are legitimate?
  • Do you need the test results to stand up in a court of law or other legal scenario?
  • Is the test material a single agricultural product or a processed multi-component food?
  • Is the material shelf stable or will it need special sample storage/transport conditions between sampling and testing?
  • Is the testing needed to check on credence claims, for example, organic, free-range, country of origin?
  • Do you need qualitative or quantitative results? For example do you need to know if an adulterant is present or absent in the tested material or do you also need to know the amount of the adulterant that might be present?
  • What level of certainty do you require?
  • How much time have you got?
  • What’s your budget?

And finally…

  • Are you prepared for what you might find; do you have a plan of action to take if food fraud is detected?

There are many laboratories that perform some type of food authenticity testing, but few that perform many types. Expect to speak to a number of different laboratories before you find one that can meet your needs.

Read this next: How to design an authenticity testing program

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Trends and developments in food fraud 2017

Our principal consultant, Karen Constable, spoke at the World of Food Safety Conference in Bangkok in June 2017 about trends and developments in food fraud.  Here are some of the highlights of her presentation.

Recent incidences of food fraud

 

Emerging trends in fraudulent activities

Recently, we have been seeing more sophisticated operations being discovered.   As an example, a large operation that was making counterfeit versions of popular brands of sauces and condiments was discovered in China in January of 2017.  The operation was being conducted in a residential area, with processes spread across 50 buildings.   The operation was said to have been active for over ten years and was producing goods worth around $14.5 million per year.

Halal fraud appears to be on the rise, with developing countries such as Indonesia and Malaysia at high risk.  Halal meat is often indistinguishable from its non-halal counterpart which means that everyday consumers are not able to verify food sellers’ claims about halal status.  Falsely claiming halal for a food item is an easy fraud to perpetrate, especially during the retail sale of un-packaged food in restaurants and takeaway stores.  Halal fraud can be as sophisticated as forgery of certification documents accompanying bulk shipments of food or as simple as dishonest signage in a takeaway store.  There have been a number of incidences of halal fraud in the news lately and these are almost certainly the tip of the iceberg.  Indonesia and Malaysia are some of the world’s biggest markets for halal food.  Both countries have variable and sometimes chaotic food supply chains accompanied by uneven regulatory enforcement.  Halal forgery also happens in the developed world, with a recent prosecution in the United Kingdom in which the fraudster is alleged to have netted a quarter of a million pounds.  With this kind of money up for grabs, you can expect halal fraud to continue.

Counterfeiting of middle range foods, rather than luxury foods is another emerging trend.  Most well-known examples of food counterfeiting in past years have been linked to premium brands and luxury goods such as expensive wines, whiskys, truffles, saffron and caviar.  However there are increasing reports of mid-range goods being ‘faked’, with condiments, sauces, chocolate bars and beverage mixes all having been fraudulently counterfeited in recent times.

Are these new types of food crime?  It’s unlikely.  However our awareness and our detection activities are increasing.  It also appears that there are more whistle-blowing activities; it is possible that more people are willing to report on suspicious activities, as was the case with the aforementioned Chinese condiment operation, or perhaps authorities are more likely to act upon reports, as was the case with the recently uncovered Brazilian meat scandal.

New responses to food fraud

Prosecutions, fines and other enforcement activities are increasing in some countries.  India, in particular, is investing heavily in new laboratories and extra resources in the fight against food fraud.  The Indian press writes about food fraud on an almost daily basis and consumer awareness is at an all time high.  India is also considering enforcing a life-long prison sentence for perpetrators of food adulteration.  Fines of more than $3 billion have been proposed for one of the businesses at the centre of the Brazil meat scandal.  That’s quite a fine!

Europe has also discussed increased sanctions for food fraud, with the hope of harmonising the sanctions across the European Union.

Operation Opson, the annual food fraud operation of Interpol and Europol, which this year netted EUR 230 million worth of seized foods, will be extending its reach beyond Europe in coming years.

Anti-counterfeiting technology continues to be developed, expanded and improved at a fast rate.  The big news in the previous 12 months in this area is the implementation of block-chain technology into the management of supply chain traceability.  Walmart are using block-chain technology for pork and baby formula in China, while Blackmores Australia is using it to protect their brand in Asia.

Updates to food safety standards

Food fraud prevention and mitigation measures are being introduced into all major food safety management systems.  The Global Food Safety Initiative (GFSI), a group of food companies whose mission is to harmonize, strengthen, and improve food safety management systems around the globe, sets guidance for food safety standards.  Well known GFSI standards for food manufacturing include BRC, FSSC 22000 and SQF.  Starting in 2016, all GFSI food safety standards have been progressively updated to include requirements for food companies to perform a food fraud vulnerability assessment and create control plans for food fraud.  Issue 7 of the BRC standard and version 4 of FSSC 22000 already incorporate these requirements.  SQF Edition 8 has been published and will be implemented from January 2018.

All GFSI-endorsed food safety standards and many standards that are not endorsed, such AIB and Woolworths Australia’s VQA standard will require or already require food fraud vulnerability assessments and food fraud mitigation plans to be implemented by food manufacturers.

GFSI standards have been updated to address hazards from food fraud

 

Regulatory changes

The Food Safety Modernization Act (FSMA) in the USA includes specific requirements which are aimed at preventing public health hazars from malicious tampering as well as fraudulent adulteration.  Hazards to food safety from intentionally adulterated food must be included in the preventive controls hazard analyses under FSMA.  The rules associated with the FSMA are being progressively introduced in the USA.  They will also apply to food businesses that export to America.

Want to learn more?  Ask us a question, we love to help.

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Supplements, the last frontier?

The supplement industry received a wakeup call last year, particularly in the USA, after the New York attorney general commenced legal proceedings against 13 supplements manufacturers alleging that the supplements did not contain exactly what they should have contained.  The sampling and test methodology used to support the prosecution has been widely criticised, and the industry considers the results to be questionable at best.  Nevertheless, the issue of authenticity and adulteration has received extra attention among producers and users of supplements since then.

Some examples of recent supplement frauds have involved grape seed extract adulterated with peanut skins.  Ironically, grape seed extract has also been found to be an adulterant itself, with some cranberry products adulterated.  Within the supplements investigated by the New York attorney general, valerian was found to contain garlic and wild carrot, echinacea was found to contain rice and buttercup DNA while St Johns wort was alleged to contain DNA from a species of ornamental house plant.

What’s being done?  Well you won’t read about it in the press but there’s no question that large retailers, including those that were targeted by the New York attorney general, such as Walmart, Target, GNC and Walgreens, have reviewed and tightened up their purchasing contracts; supplement testing methodology has been reviewed and reputable supplement manufacturers are testing more of their ingredients more often.  And that’s great news for consumers.

 

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What next?

Updated 30th April 2022

Now you have a food fraud vulnerability assessment, what comes next?

 

First, make a home for the vulnerability assessment documents so that they can easily be found for reviews and audits.  They should be incorporated into an existing quality manual or food safety manual, with correct document reference numbers and with review dates scheduled in the same way as other sections of the system.  If the business operates a risk register or an enterprise risk management system, talk to the owner of that register about whether it is appropriate to reference the documents in that system also.

Second: communicate!

If food fraud vulnerabilities have been identified the business will need to make a plan to

prevent deter detect

  • Prevent the purchase of fraudulent ingredients or products
  • Deter fraudsters from adulterating materials that your business is going to purchase
  • Deter counterfeiters from copying or ‘faking’ your products
  • Detect fraudulent materials before they are used to make food
  • Detect fakes in the marketplace so enforcement action can be taken

This is a job for the whole business, not just food safety or food quality personnel.  Communicating what has been found in the vulnerability assessment is the first step in engaging people from other parts of the food business.  Ideally the top levels of management of the food business are committed to preventing, deterring and detecting fraud and will be willing to implement changes to protect the business.  It may be necessary to make changes to purchasing policies, supply chain strategies and supplier contracts to help prevent fraudulent materials from reaching the doors of your factory.  Changes to sales agreements, sales channels and packaging might be needed to prevent food fraud from affecting your products after they have left your facility.  Personnel from purchasing, finance, marketing, sales and legal departments will need to be involved to implement changes within these business areas.   If the business has a Risk Officer or an Enterprise Risk Manager that person should also be involved in the prevention and mitigation planning process.  The result should be a cross-functional team with upper management support and a commitment to prevent food fraud, plus the resources to implement changes to policies, practices and programs.

That is the theory anyway; without support from upper management and a cross-functional team, any fight against food fraud is going to be tough.  However there are some things that can be done by food safety personnel that are relatively quick to implement and do not require a lot of investment from other parts of the business.  These are listed below.

Third: action!

Create and implement a food fraud prevention and detection plan (‘control plan’).

Here are some actions that can reduce your exposure to food fraud:

  1. Update your raw material specifications to include authenticity requirements.  Guidance for raw material specifications.
  2. Review your vendor approvals systems and revise questionnaires and requirements if required.  Consider implementing more stringent requirements for suppliers that provide vulnerable materials.
  3. (Re)assess vendors’ backgrounds: the financial stability of the vendor’s company, the legal status of the company (licensed? bankrupt?)
  4. Check vendors for previous prosecutions, fines and warnings from food authorities.
  5. Request certificates of analysis (CofA) from suppliers of vulnerable materials and make sure they include analyses that reflect authenticity attributes as described in your purchasing specifications.  This won’t actually prevent fraud but will help your business to enforce penalties if problems are found later.
  6. Incoming goods inspections.  Make sure they include: checking seals for evidence of tampering; verifying batch IDs on delivery documents; verifying relevant certificates.
  7. Begin analytical testing of vulnerable materials.
  8. Investigate the costs and benefits of supply chain audits, including whether ad-hoc, one-off visits to certain suppliers might be worthwhile.
  9. Request tamper-evident packaging and bulk container tamper seals for vulnerable raw materials.
  10. Ask suppliers of vulnerable materials to undertake a mass balance exercise at their facility or further upstream in the supply chain.
  11. Make a business case for switching suppliers of materials that prove to be consistently problematic and present it to your purchasing department.
  12. Make sure that senior staff in the business understand the risks posed by food fraud, by providing Food Fraud Awareness Training.
  13. Stay up to date with changes to commodity prices and supply issues (‘horizon scanning’).

Need help with your food fraud control plans?  Get easy instructions and downloadable templates from our online training course.

Check out our low-cost, self-paced, on-demand training courses