Food Fraud Advisors

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Secrets of the horsemeat scandal

How did the enactment of an obscure transport law in Eastern Europe change the face of food manufacturing forever?  Karen Constable investigates the link between Romanian road rules and the horsemeat scandal.

More than six years after it first made headlines, the series of incidents that became known ‘horsegate’ continues to impact the global food industry.  It began in January 2013, when Irish authorities revealed they had discovered horsemeat in burgers that were supposed to contain 100% beef.  The discovery sparked a frenzy of testing and soon horsemeat was being discovered in dozens of different products in countries all over Europe and beyond.  The sheer scale of the contamination sent shock waves through the food manufacturing world.  Occurring five years after the melamine in milk powder scandal of 2008, which sickened over 300,000 babies in China, this incident was unfolding much closer to home for food manufacturers in Europe.  It was a wakeup call for our industry: we could no longer pretend that food fraud of a similar scale and impact as the melamine milk scandal could not happen in the western world.

Numerous massive recalls

The scandal resulted in market withdrawals of tens of millions of food products across Europe, millions of euros of lost business and multiple prosecutions.  Consumers’ trust in manufactured food plummeted and sales of frozen hamburgers and frozen ready meals dropped by 43% and 13% respectively in the United Kingdom in the month following the first product withdrawal.

Multiple investigations

Despite some media reports claiming that the first horsemeat discovery was the result of ‘routine’ testing, it is now known that the scandal was uncovered almost by accident.  As strange as it may seem to the wider community, it is unusual for food manufacturers and regulatory authorities to test foods for materials that are not expected to be present.  This is, of course, how the perpetrators of the Chinese melamine fraud could conduct their activities on such a large scale for what is thought to be a significant length of time.  The original horsemeat tests were conducted by the Food Safety Authority of Ireland because a sharp-eyed inspector had noticed a discrepancy between packaging and labelling of frozen meat.

As the investigations began it became apparent that law enforcement and regulatory authorities were ill-equipped to manage the complex cross-border issues that arose.  Supply chains seemed hopelessly complicated to unravel, with on-paper ownership of meat often disconnected from the physical whereabouts of the food.  By the time the scandal was declared over, investigators had identified at least three entirely separate supply chains involving different slaughterhouses, traders, processors and criminals.

Beef an easy target

Horsemeat and beef meat are similar in appearance, texture and flavour.  Yet the European market for horsemeat is relatively small compared with beef; it is not consumed by people in many Western European cultures. For unscrupulous merchants, however, horsemeat’s abundance and low price made it the perfect substitute for beef.   With access to a cheap, abundant adulterant, the criminals appeared to have an easy job of it.  It was so easy, in fact, that swapping horse for beef appears to have been a long-term business plan for at least one of the meat traders involved in the scandal, Jan Fasen.  Fasen had been convicted and jailed for a similar fraud in 2007.  The name of his company, Draap, is the Dutch word for horse spelt backwards.

In 2019, Fasen and his partner Hendricus Windmeijer were convicted of false labelling by a court in Paris for their role in the supply of 500 tons of meat to ready-to-eat meal-maker Comigel in France in 2012 and 2013.

Complex supply chains

Much of the horsemeat found in the affected products originated in Romania, the by-product of a unique set of circumstances which affected the availability and price of horse meat in that country.  Six years prior to the scandal, a law had been passed banning horse drawn vehicles from the streets of cities and towns in Romania.  Within a few years there was a surplus of unwanted horses, with abandoned animals roaming city streets and parks.  The horses were rounded up and exported to slaughterhouses in neighbouring countries where they were slaughtered for legitimate human and pet food.  By 2007, however, concerns about the spread of equine infectious anaemia, a disease which was endemic in Romania, resulted in a ban on the trading of live Romanian horses.  With live exports stopped, there was nowhere for the horses to go.  Enterprising local businessmen built their own slaughterhouses in Romania and began to export horse meat to Europe.

Draap Trading, a company operated from Belgium and registered in Cyprus, was among those that purchased Romanian horsemeat.  It shipped the meat to the Netherlands where it was re-labelled as beef.  From there it was sold to legitimate meat processors, including one in France who supplied the factory in Luxembourg that manufactured lasagne and spaghetti bolognese for Findus and Aldi.

Separately, a French meat processing company, À la Table de Spanghero was also purchasing horsemeat from Romania and selling it to food manufacturers labelled as beef.  The former director and manager of Spanghero were convicted for their crimes in Paris in April 2019, with the former director being jailed for his role in the saga.

Romania was not the only source, however: the burgers at the centre of the initial discovery in Ireland contained horsemeat that came not from Romania but from Britain, Germany and Poland, via another Dutch trader, Willy Selten.  In 2015 Selten was jailed for 2.5 years for crimes related to the fraudulent supply of horsemeat in 2011 and 2012.  In November 2016 he was ordered to pay €1.2m – the estimated proceeds of his crimes – to the Dutch government.

A long history of horsemeat adulteration?

Given the history of Selten and Fasen, it seems likely that undeclared horse was present in the European food supply for many years, remaining undetected and causing no apparent harm to consumers.  We will never know whether those responsible considered the safety of consumers when planning their crimes.  We do know that unsafe adulterants are more likely to be detected, which makes them less attractive to fraudsters.  Certainly, in the melamine scandal in China, just a few years prior, consumer harm played an important role in the detection of the fraud.  In that case, it is likely that low levels of melamine had been added to milk powder and other products for many months or years without causing any immediate or obvious harm to anyone.  It is thought that the concentration of melamine in baby formula increased in 2007 and 2008 and it was the higher levels that caused kidney problems in babies.  The fraud was uncovered by authorities investigating the illnesses.  Perhaps the extra melamine had been added by mistake, or perhaps the fraudsters got greedy.  Either way, the adulteration was costly for the criminals as well as their victims: two of the people responsible were executed by firing squad in China in 2009.

During the horsemeat fiasco, and to the relief of the entire industry, no person was sickened or injured by the presence of horse in ‘beef’ products.  There was, however, a major health scare: horsemeat can contain veterinary drugs, including phenylbutazone – “bute”, which can be harmful to human health.  It was a lucky coincidence that the overwhelming majority of the contaminated products proved not to contain phenylbutazone.

From horse and beef to chicken, donkey and buffalo

As investigators worked behind the scenes, public events in the European food industry took on the appearance of collapsing dominoes: first was the withdrawal of 10 million burgers by Tesco, Lidl, Aldi, Dunnes Stores and Iceland in United Kingdom.  Tesco lost £300m in market value overnight.  In the following weeks, Asda also removed tens of thousands of products from its shelves; Tesco and Aldi extended their withdrawal from burgers to ready meals; Waitrose withdrew meatballs because of fears they might contain pork; slaughterhouses in Yorkshire and Wales were raided by regulatory authorities; the scandal spread to France and multiple arrests were made on both sides of the English Channel.

By the end of March 2013, authorities had found horse labelled as beef in three Polish factories; equine DNA had been found in chicken nuggets in Greece; water buffalo and donkey had been found in South African burgers and more big brands, including Ikea, Birdseye and Nestle had been affected with their products withdrawn from markets in Cyprus, Belgium, Spain and Czech Republic.

By year’s end, Tesco’s annual profits had fallen by 52%.  Consumer trust in large food manufacturers and retailers was at an all-time low: British consumer organisation ‘Which?’ reported that sixty percent of consumers had changed their shopping habits because of the scandal.

Standards updated

The British government commissioned Professor Chris Elliott to review and report on the implications of the horsemeat contamination for the British food industry.  The Elliott review, as it became known, resulted in the creation of a special food fraud crime unit in that country and the development of a range of other collaborative enterprises across Europe including special functions within the European Joint Research Council (JRC) and food-focussed operations by Interpol known as Operation Opson, now in its sixth year.

The food safety community, initially shocked and alarmed at the potential safety implications of the adulteration soon began a period of discussion and introspection, which often centred around the unspoken question ‘What if the meat had been dangerous?’.  The scandal broke at a time when the GFSI food safety standards were consolidating their revered positions at the pinnacle of ‘best practice’ manufacturing: the standards were being strengthened, lengthened and broadened.  Audit durations were increasing, auditor qualifications and certification systems had become more stringent and standards for packaging, storage and distribution had been upgraded.  And yet these GFSI-endorsed food safety management systems, considered to be the gold-standard for food manufacturing and administered with the strictest oversight, had revealed an Achilles heel the size of Bucharest.   The GFSI promptly created the ‘Food Fraud Think Tank’ to address the gaps and suggest solutions.  This resulted in changes to GFSI’s guidance for food safety standards, with GFSI-endorsed standards being updated to reflect the updated guidance.  The new guidance requires food businesses to formally address the risks from fraudulently adulterated ingredients when they design their food safety management systems.

The food safety landscape had changed, seemingly overnight, from one that was focussed almost exclusively on unintentional or natural contamination to one that requires food manufacturers to consider, control and prevent more unpredictable and sinister events.

In the wake of these changes, a new discipline of food study has appeared.  It is now possible to study food fraud at prestigious educational institutions, attend international conferences devoted to the topic and tune in to webinars conducted by specialists in compliance, legislation and testing.  Analytical chemistry researchers are developing ever-more sophisticated test methods for detecting adulterants.  Food businesses large and small are developing better systems to prevent, deter and detect economically motivated adulteration within their supply chains.

Food manufacturers are slowly regaining the trust of consumers, helped by the visible presence of enforcement operations and government initiatives such as the United Kingdom’s Food Crime Unit and Interpol’s Operation Opson in Europe as well as the Food Safety Modernisation Act (FSMA) in the United States.

And what of the adulterated beef?  We can only guess at how many tonnes of it was eaten by unsuspecting consumers in countries all over Europe before the scandal broke.  Contaminated product that was withdrawn from the market – tens of millions of units – was destroyed; either buried in landfill or used as animal feed.  It seems a sad and wasteful journey for the unwanted horses of Romania; a journey conceived by men who wanted to be rich and one that ultimately changed the face of food manufacturing forever.

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Verifying traceability; MSC certified seafood passes the test

The Marine Stewardship Council (MSC) has published a report describing the results of a DNA survey on MSC certified fish from 16 countries.

Businesses that handle MSC certified sustainable seafood are required to comply with the MSC Chain of Custody Standard to ensure that they have effective traceability systems in place.  This helps to ensure that the consumer receives fish that are from sustainable fisheries, as promised by the MSC sustainable seafood label.  MSC conducts a survey every two years to verify the effectiveness of the standard and to ensure that distributors, processors and retailers trading in MSC certified sustainable seafood are complying with the standard.

fish species fraud

The results of the latest survey are really positive.  The MSC sampled fish and fish products carrying the blue MSC certified label from 16 countries.  Of the 256 samples tested, only one of those was identified as being mislabelled.  Upon further investigation MSC found that the mislabelled ‘Southern rock sole’ was in fact ‘Northern rock sole’; it was an accidental misidentification of two closely related species, rather than a deliberate fraud.  So it seems that the MSC Chain of Custody Standard is working really well across the world.

Interestingly, the final pages of the report include a discussion about how the results compare with similar surveys conducted by other organisations.  Those other surveys included species testing of many fish types, within many countries, mostly from retail outlets.  The levels of mislabelled fish species were generally low in Europe, with more than 90% being of the samples being accurately labelled.  The only countries that had less than 70% accuracy were Belgium, USA, South Africa and Canada.  Sadly, the Canadian results were the poorest, with less than 60% of samples in that survey being accurately labelled.   The Canadian results were also the oldest, being from 2011, with most of the European results from 2015.  Perhaps seafood labelling in Canada has improved in the last five years, just as it has in Europe.

 

 

 

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Traceability myth #3: Traceability equals authenticity

Traceability in the food supply chain leads to authentic food: it’s a myth.  In this third and final look at common misconceptions about traceability, I examine the links between traceability and authenticity of food.

Traceability can be difficult with a complex food, but it’s not impossible.  At the simplest level it is about knowing where every ingredient in a food product has come from and being able to identify the ingredients in each batch of your product to their own individual lots.  If you are a food business that has managed to achieve a transparent supply chain then in addition to basic traceability you will also know the sources of each of your suppliers and their suppliers, resulting in a ‘trail’ that leads all the way back to the farm or fishing boat.

Knowing where your ingredients have come from and being able to trace them back to your suppliers is a great start when it comes to protecting the authenticity of your finished product.  Knowing more about your supplier’s suppliers can also give a food business peace of mind when assessing the risk of receiving fraudulent materials.  Unfortunately, though, even within a completely transparent supply chain there can be opportunities for fraudulent adulteration, substitution or misrepresentation of food materials.

Take for example a bottle of virgin olive oil on the shelves of an inner city specialty grocer; the retailer purchases from a wholesaler who has a direct relationship with the olive processor which processes olives for a collective of farmers from a small olive growing region.  It’s a short supply chain and very transparent.  The retailer knows exactly where the oil comes from.  But that does not mean that the retailer knows what was going on at the oil processing facility.  Perhaps the most recent local harvest was very poor, perhaps the processor was under financial stresses and was tempted to dilute the pure local oil with cheaper bulk oil from another region or country.  Maybe the wholesaler was tempted to switch labels on some of his olive oil ranges to increase his profits…   Each of these scenarios result in fraudulently adulterated, diluted or substituted product.  If the retailer is selling the oil with regional provenance claims, organic claims or claims about special grades or standards of oil and the oil has been adulterated, diluted or substituted he is then unwittingly committing food fraud himself.  It’s an unpleasant scenario, and one that is unfortunately common.

Transparency has many benefits to supply chain management, and can provide some assurances against food fraud but it does not automatically guarantee authentic food ingredients and food products.

Traceability myth#1; consumers want transparency

Traceability myth #2; traceability is expensive

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Traceability myth #2: Traceability is expensive

My recent article Traceability myth #1 ‘Consumers want transparency’ discussed how consumer attitudes to transparency are positive, but may not have much affect on purchasing decisions.

Traceability myth #2 explores the myth that traceability is expensive for food businesses.  This myth is based on the belief that traceability can only be achieved through the use of specialised business software.  Let’s explore this myth in more detail.

Specialised business software is expensive but it is not the only way to achieve traceability.  Traceability is the ability to access information about all the ingredients of a food product down to the individual batch or lot of the ingredient, to understand the disposition of all the ingredients and intermediate materials within a production process and to know where the food product went after it was manufactured.  The information should be accessible to the food business and able to be retrieved within four hours.

Why is traceability important?  Safety of consumers is the number one reason for traceability; it allows fast and effective recall of food products that have been affected by unsafe raw materials or improper processing.  Every food safety management system standard includes requirements for traceability.  Traceability can also be a huge benefit to market access; put simply, if you have robust traceability systems in place, more retail and food service customers are going to be willing to purchase your foods.  Thirdly, traceability comes with huge cost savings in the event of a recall or withdrawal situation; a food business that can accurately trace affected product down to individual lots can save huge sums of money by recalling only those lots that are affected. This can also have a positive affect on insurance premiums.

How to implement a traceability system without using expensive software? The most important thing you will need is a traceability ‘champion’ who is dedicated to the task and who has the support of top management.  As the system is implemented it is this person who will check that things are working as they should, that information is being recorded and that their colleagues in the business understand the process and the reasoning behind it.  A good first step is to start by editing production record worksheets, such as batch sheets and packing sheets and adding spaces to record a number or code that will identify each lot of finished product and intermediate product.  This code should ‘follow’ the lot through the production process, any quality checks and all the way to dispatch.  It should be able to be linked to the best before or use-by date on every pack; this can be done with a simple batch number book that contains a list of unique numbers and space to add date of manufacture, product and (afterwards) final disposition of the lot next to each number.

Production records will also need to be amended so that batch numbers or other unique identifiers for raw materials can be recorded.  Records need to be kept for all ingredients, intermediate foods and primary packaging materials that go into the process.  Personnel responsible for ‘batching’ or adding materials to the process will need to be trained and re-trained to remind them to record these numbers religiously; in a paper-based manual system, these operators are the difference between an effective traceability system and one that will be full of holes.

Raw materials and incoming goods systems are the next part of the implementation; if any of your materials are not supplied with a unique identifier or batch code you will need to create your own and attach it to each lot of material as it is received.  This same code will need to accompany any portion of the material as it moves around the facility.  Work in progress, re-work, faulty product and product that is on hold awaiting quality checks also need to be labelled.

The final piece of the puzzle is with the sales and dispatch operations; your operators will need to keep a record of which batch lots were dispatched to which customer.  The result is a batch number book that contains a unique identifier for each lot of product, with the product and final disposition (sold, destroyed, discarded) accompanied by sets of records for incoming goods, production , quality checks, on-hold or destruction records and sales or dispatch records that can all be linked back to the numbers in the batch book.

Paper-based traceability systems can be simple and relatively inexpensive but they need constant vigilance to ensure that every person who is supposed to be recording batch numbers is doing so in a conscientious manner.  All records should be cross checked by a supervisor before being filed and a traceability exercise should be conducted on each product line on a regular basis to make sure the system is working properly.

There are many advantages to be gained from an electronic traceability solution, because they typically allow for more efficient ordering and stock management processes, as well as removing much of the ‘fiddly’ and tedious work from the record-keeping processes and improving access to records.  If you have a complex business or are working with materials with a short shelf life, business management software can be worth its weight in gold.  However, paper-based systems can and do work very well and are perfectly capable of meeting the traceability requirements of the most picky customers and stringent standards.  All you need is a champion.

Traceability myth #1; consumers want transparency

Traceability myth #3; traceability equals authenticity

 

 

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Traceability myth #1: Consumers want transparency

Consumers want transparency.  It’s a phrase I hear all the time in supply chain and food safety circles.  Ask consumers if they want transparency and the answer is overwhelmingly ‘yes’.  It seems obvious; transparency equals knowledge, knowledge equals informed decisions, informed decisions result in good purchasing practices and good purchasing practices are a win for both consumers and suppliers.  But is that how food purchasing really works?

If consumers say they want transparency, and in a study by BBMG, GlobeScan and SustainAbility  a total 82% of consumers reported that “ingredient transparency is a very important or important factor” when shopping for food and beverages, why is it that ingredient transparency remains relatively unusual for most food products?

As a young food technologist working for a large snack food manufacturer, I learnt a valuable lesson in understanding consumer behaviour; those of us in marketing and product development jobs were very good at imagining the wants and preferences of our core consumers.  We were almost always wrong.  I was lucky enough to work for an organisation that was willing to spend money on focussed, in-depth and product-specific market research and we used that research to refine our product offerings and strengthen our brands.  What we learnt was that our own white-collar preferences were quite unlike the preferences of our core consumers and that self-reported attitudes to products almost never aligned with actual purchasing behaviour.  When it was time for consumers to select a bag of snacks from a retail store shelf, the qualities that we had been focussing on in our product development laboratory contributed very little to the decisions that were made.

I see the same thing in the current commentary of food safety and integrity professionals.  Traceability and transparency are important to food professionals and this is likely to be reflected in our food purchasing habits.    But for most people, food purchasing decisions are dominated by availability, cost, quality and sensory preferences.  Transparency is nice to have, but if it comes with a higher price tag it is unlikely to result in increased sales of a food product.  I don’t doubt that this is something most large food processors already understand.  We will continue to hear calls for supply chain transparency but we won’t be seeing it on an ordinary big-brand box of cookies any time soon.

Traceability myth #2; traceability is expensive

Traceability myth #3; traceability equals authenticity