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What is a food fraud team? (and what to do if you can’t get one)

A food fraud prevention team is a group of employees in a food business that is responsible for creating, implementing and supervising food fraud prevention activities in the business.

Food fraud teams are ideally made of representatives from various departments of the food business, such as Food Safety, Quality Assurance, Procurement, Production, Marketing, Site Security, Legal, Warehousing and Laboratory.

Members should be trained in food fraud awareness.

Typically, a food fraud prevention team would meet on an as-needed basis as determined by the food fraud team leader or as directed by senior management, with at least one full meeting every 12 months.  Meetings should also be held in the event of a food fraud crisis or if there have been major changes to supply chains or operations.

Attendance and minutes of the meetings should be recorded and filed within the food fraud prevention section of the food safety management system.  Action items from each meeting should be noted in the minutes, and subsequent meetings should address action items from previous minutes.

Agenda items for food fraud team meetings

  • Action items from the previous meeting – status of actions.
  • Discussion/report on new products in development and/or launched since the last regular meeting, with respect to food fraud vulnerabilities.
  • Discussion/report on changes to raw materials, suppliers.
  • Discussion/report on new raw materials, new suppliers and contract manufacturers.
  • Review of current food fraud procedures – do they represent current best practice, are they being followed?
  • Discussion/report on any food fraud incidents or new risks emerging in relevant supply chains.
  • Review of the composition of the food fraud team; any changes needed?
  • Discussion/report on changes or upcoming amendments to certification requirements or customer standards.
  • Review of audit results (internal, external and customer audits), with respect to food fraud elements.  Improvement suggestions and/or status of corrective actions.
  • Review of mitigation plans and/or testing results; any new mitigation activities needed, new tests available?
  • Report to senior management re. food fraud vulnerabilities and status of mitigation activities, request for further resources if needed.

What to do if you can’t get a food fraud team

Handling food fraud prevention activities is a tough task – tougher than senior managers may realise. So if your company doesn’t have a food fraud team, it’s important to ask loudly, and often, for cross-disciplinary help with food fraud matters.

Food fraud poses financial and reputation risks to businesses, and a single person should not be expected to understand every vulnerability across the business. The consequences of missing a vulnerability can be severe, and this must be explained to senior managers when requesting resources for a food fraud team.

Even in a very small company, a food fraud team containing a senior manager/owner, food safety representative, purchasing officer and production manager is best practice. The cost of man-hours used by a food fraud team is far lower than the cost of any serious food fraud event.

However, if you are responsible for food fraud prevention and you haven’t succeeded in getting a food fraud team, there are a few things you can do to reduce the risks. Firstly, you can approach members of other departments informally and ask them for their thoughts about specific products, ingredients or processes. You can also engage the services of an external food safety consultant if the budget allows. They can bring a fresh perspective, new knowledge and may even be able to persuade senior management of the importance of forming a team.

Finally, you could borrow the food safety hive mind in a forum or professional group to assist with tasks such as identifying or prioritising vulnerabilities. Try the forums of the International Food Safety and Quality Network (IFSQN) which are free and can be used anonymously, LinkedIn groups or professional food science associations such as IFST (UK), IFT (USA) or AIFST (Australia).

Food Fraud Advisors has food fraud awareness training for your team, and a downloadable template for food fraud team SOPs, agendas, minutes and personnel lists.  Learn more by clicking the icons below.

online training food awareness senior management food fraud teams
Food fraud awareness training is recommended for senior management and food fraud team members by SQF, FSSC, IFS and other food safety standard owners. Our training is cost-effective and convenient. Certificate included.

 

Food fraud teams are an important component of a food safety management system. Our ultra-popular template has everything you need to form a food fraud team for your business.

 

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How to Ace Your Next Food Safety Audit: A Step-by-Step Guide

Audits (sigh).  They’re a thorn in the side of many food safety professionals, taking our time and attention away from proactive work and getting in the way of important projects.  It often feels like we’ve barely finished one audit before the next one starts.  Add in the time it takes to stay on top of all the different audit requirements and it’s no wonder food safety professionals find audits a disagreeable part of their jobs.

However, with the right preparation and mindset, you can turn your next audit into an opportunity for improvement rather than a source of stress. This short guide describes actionable steps to ace your next food safety audit and reduce the scramble. Let’s dive in!

1. Understand the requirements

It’s almost too obvious to include in this guide, but understanding the audit’s requirements is an absolute must-have for success audit.  That means having a thorough understanding of the standard or regulation your company is being audited against.

External audits can come in the form of regulatory checks (often called ‘inspections’ rather than audits), second-party audits, which are audits by customers, and third-party audits, which are audits by certification bodies.

The requirements for each of these types of audits, and their durations are quite variable.  A customer audit, for example, can take the form of a short visit to check your facility and systems or an in-depth and time-consuming process based on a long checklist or complicated standard.

For this step, you’ll need a copy of the audit standard or checklist and familiarity with its contents.  To stay on top of changes to standards, keep a lookout for free webinars from the standard owner or certification body.

Keep up to date with the standard if you want to ace your audit. Image: kues1 on Freepik

 

If you’re new to food safety systems, consider formal training in the relevant standard(s).  Also, keep an eye out for guidance documents published by standards owners on specific topics such as food fraud or food safety culture which are usually very helpful for audit preparation.

2. Conduct a self-assessment

Most standards require food businesses to conduct internal audits which check that systems are working as they should throughout the year.  However, internal auditors can easily overlook key areas of non-compliance, especially if they are very familiar with the system.

A self-assessment means checking that your systems meet the requirements of the standard. It allows you to identify gaps and correct areas of potential non-conformity before the audit. A self-assessment includes activities such as checking that documents are up to date; records are available; procedures reflect what is actually being done and the physical environment is clean and organised.

Top tip: If you don’t have time to do a complete self-assessment, check industry news for articles that list common non-conformances and focus your efforts on those areas.  See past posts Top 5 Audit Non-conformances: BRCGS spills the beans on a year of audits and Top Food Safety Non-Conformances and How to Avoid Them for inspiration.

3. Get your docs ready

Auditors love an organised set of documents!  It saves them from having to waste their time searching through mounds of paper or digital files looking for answers and allows them to focus on important food safety issues rather than navigating paperwork tangles.

If your system is organised so that auditors can easily find their way around, they’ll be more relaxed and you won’t need to sit and hold their hand throughout the audit, freeing you up to get on with other tasks.

Whether your food safety program is published with sophisticated software or filed in simple paper folders, it should have a contents page (or electronic file) that names all the elements of the program and includes links or guidance to where each section is located.

If some of your records are supplied electronically by contractors, such as cleaning contractors or pest management professionals, be sure to include instructions or links for access to their records.

It goes without saying that you should make sure that all documents referenced in your program are available and accessible at the time of your audit.  For example, make sure all paper folders are where they should be, check that you can log in to your contractors’ portals and ensure that electronic folders can be accessed from the right devices.

4. Borrow a colleague for a walk-through

If it has been a while since your last audit, it might be worth borrowing a fresh set of eyes to take on a walk-through of your facility.  It’s easy to miss areas of non-compliance if you see them every day.

Tell your colleague – ideally someone who doesn’t go into food handling areas often –  to help you look for problems such as inaccessible hand wash sinks, open ingredient containers, doors propped open, improper wearing of PPE, unlabelled WIP (work in progress), temporary maintenance solutions like cardboard or sticky tape, peeling paint, condensation drips, non-functioning lights, uncovered waste containers, empty hand soap dispensers and the like.

If you find something, fix it before the audit.

5. Reframe the audit for yourself and your team

If you’re anxious about an upcoming audit, or treat it as nothing more than an unwanted intrusion, your attitude is likely to rub off on your team.  Auditors have a sixth sense for bad attitudes, and will not only pick up on it, but may also unwittingly reflect it back to you in their approach.

An auditor who feels unwelcome and unappreciated might even imagine that your company’s food safety culture is not up to scratch.

A good auditor will raise issues in a way that promotes a positive, rather than a defensive response from the auditee.  But not all auditors are good.  The trick to dealing with a difficult auditor is to imagine that the auditor has highlighted an issue with the aim of helping your business do better, not so they can give you a fail.

Most auditors are in the job because they want to use their expertise to help food businesses do better, and most genuinely want their work to result in better food safety outcomes for consumers.  They are auditing to help your business make food safer every day – they certainly aren’t in it for the money.

Tips for reframing:  Remind yourself that the auditor’s primary role is to help your business do better.  Also remind yourself that auditors are subject to an unconscious bias that means they can feel like they haven’t done their job properly if they haven’t raised at least a few non-conformities.

6. Prepare your colleagues

This step is about making sure everyone knows what to expect on the audit day(s).  Assign roles and responsibilities for various topic areas so everyone knows who is responsible for answering questions about each aspect of the food safety program.

Warn senior managers they may be asked questions about food safety culture, such as how they prioritise resources or handle staff turnover.

Top tip: Don’t forget that auditors are people too.   Offer them a drink, make sure they have a space to work that is not too hot or cold, arrange a comfortable chair, check that they have brought something to eat, and arrange something for them if they haven’t.

7. Aim for transparency

The surest way to make an auditor suspicious is to try to hide problems or deny evidence.  Be open and honest and make sure your colleagues know that this is the approach you want to take with auditors. When issues are pointed out, avoid acting defensively, but stay calm.

8. Correct problems on the spot if you can

Most auditors are fine with instant corrections to minor problems, so don’t hesitate to fix problems while you are with the auditor if you can.  For example, if you are authorised to update a document where the auditor has found a minor error, you could make the correction during the audit.

Instant corrections save the auditor from having to write up a non-conformance and they save you from having to document a corrective action process after the audit.

9. Get clarification and push back if needed

Auditors make mistakes, and different auditors have different ideas about how things should be done.  If you don’t agree with something an auditor says, make sure to discuss it with them as soon as they say it.  This can help prevent small misunderstandings from becoming big ones.

For example, if an auditor says they have found a problem with something that previous auditors did not highlight, it’s fine to question their opinion.  They could be working with an incorrect assumption or may have misjudged the evidence.

When you seek clarification you are giving the auditor a chance for them to provide you with current best practices and help your business improve.  On the other hand, if they realise they have misunderstood a situation, your input might save them from an embarrassing mistake.  Either way, you are doing them a favour.

If you are not one hundred percent clear on any findings the auditor describes at their closing meeting, ask them to clarify before they leave.  If you still aren’t satisfied, request more details in writing too, and check that the auditor has evidence to back up their findings.

Truly problematic audit results and auditor behaviour can be discussed with your certification body if you are not able to resolve issues with the auditor.

Final thoughts

Food safety audits are not just about compliance, they are an opportunity to get feedback on your systems and stay up to date with best practices in food safety. By following the steps outlined in this guide, you can transform potential stress into a structured process that fosters confidence and promotes teamwork.

Embrace the feedback from audits as a pathway to continuous improvement, remembering that the ultimate goal is to improve food safety outcomes and protect consumers.  And remember, if you aren’t convinced about the auditor’s findings, be sure to seek clarification.

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Food Fraud Databases Compared

Updated 30 April 2025

A food fraud database is a collection of information about food fraud incidents and food fraud risks. There are paid and free databases operated by governments, not-for-profits and private companies.  The type of data varies from database to database, as does the cost and the features.

Pay-To-Use Databases

There are a number of pay-to-use food fraud databases.  The four best-known commercially operated databases are listed below.

(1) HorizonScan (FERA).  This tool was developed by the UK government’s Food and Environment Research Agency (FERA). It includes alert systems and information about food safety, food fraud and suppliers.  In the U.S., it is distributed by FoodChain ID.  https://horizon-scan.fera.co.uk/

(2) FoodChainID Food Fraud Database (formerly the Decernis Food Fraud Database, which was previously the United States Pharmacopoeia (USP) Food Fraud Database).  This database includes scholarly articles on testing and detection methods as well as food fraud incidents.  https://www.foodchainid.com/products/food-fraud-database/

(3) Agroknow’s FoodAkai uses sophisticated computer modelling to analyse data from global food safety agencies to offer insights into hazards in raw materials, ingredients and products.  Like HorizonScan, it includes food safety as well as food fraud issues and incidents.  https://agroknow.com/foodakai/

(4) MerieuxNutriSciences’ Safety HUD monitors official agencies and other sources for alerts on food safety and suspected fraud incidents. Safety Hud 2.0 | Food Compliance Solutions (mxns.com)

Costs

There is a notable lack of transparency in the pricing of food fraud databases.  Fees to access the databases are usually levied on a subscription basis.  The cost varies depending on the number of users and whether you are a consultant, a small food company or a multi-site organisation.

All the databases listed above offer either a free trial or a guided demonstration, so you can compare them to decide which might be best for your company’s needs.

Affiliation

Food Fraud Advisors has no financial relationships with the products or companies listed above, though we do have contacts at each organisation, so if you would like a no-obligation introduction, just ask. We do not earn a commission from such introductions.

Free Databases

(1) Food Fraud Advisors’ Food Fraud Risk Information Database (hosted on Trello) is a free and open-access online database of food fraud incidences and emerging threats, organised by food type.  No log-in required.  https://trello.com/b/aoFO1UEf/food-fraud-risk-information

(2) FoodSHIELD is a US Government-Academic partnership.  Access to the FoodSHIELD food fraud and food defense database is limited to representatives from local, state, and federal governments, the military and laboratories that perform analyses.  https://www.foodshield.org

(3) Food Protection and Defense Institute (USA)’s Food Adulteration Incidents Registry. Access by special request only. https://incidents.foodprotection.io/about

(4) Rapid Alert System for Food and Feed (RASFF) is managed by a group of European national food safety authorities and alerts its member states to incidences of food and feed safety and integrity.  RASFF publishes a searchable database for investigating incidences of food fraud.  To learn more about RASFF click here.  For direct access to the database, open the RASFF Portal.

(5) US FDA’s Recalls and Food Safety Alerts, has a searchable database and includes incidents arising from food fraud.  http://www.fda.gov/Safety/Recalls/

(6) MEDISYS for Food Fraud (MEDISYS-FF) is a food fraud media monitoring system that uses information from the Europe Media Monitor to collect media reports related to food fraud.  The reports can be filtered by country of origin, keyword and date.  You can request access to the system by submitting a form.  https://bigdata-wfsr.wur.nl/2020/09/18/medisys-for-food-fraud/ 

Which Database Should I Use?

How do I know which database will meet my needs?

 

What are your needs? Check the headings below to see which best describes your company’s needs for food fraud information. 

 

Low budget and/or need information infrequently

If you have a low budget and don’t need real-time monitoring, use Food Fraud Advisors’ free Food Fraud Risk Information Database.

Custom alerts for specific ingredients or foods

Custom alerts and real-time monitoring is offered by the four paid databases listed at the top of this post.

Food safety and food fraud alerts

HorizonScan, FoodAkai and FoodSafety HUD all include food safety hazards as well as food fraud hazards in their reporting and alert systems.

Analytical test methods information

FoodChainID’s Food Fraud Database includes test method information and research papers.

Large number of users across multiple sites

If you have a high number of users who want to access the database or a very large number of products, HorizonScan, FoodChainID and FoodAkai have enterprise-level subscriptions so users on different sites can set up their own reports and alerts.

Predictions about future hazards

FoodAkai promises early warning of emerging risks, which are predicted using AI technology. The makers of FoodAkai say their software predicted the multi-country, multi-product ethylene oxide in sesame recall disaster of 2020-2021.

Students, occasional needs, non-food professionals

The Food Fraud Information Database hosted on Trello is a great place to start your food fraud journey if you are a student or new to the food industry.  It is free and contains summaries of the types of food fraud that affect various foods.  However, it is not easily searchable (you can buy a searchable ‘snapshot’ in Excel form) and it does not provide custom alerts.  Incidents added to the database are mostly drawn from international media and are heavily weighted to English language media, so are not suitable for accurate counting or mapping of incidents.

Other free information about European and North American foods

RASFF (Europe) and FDA Recalls and Food Safety Alerts (USA) mostly contain food safety incidents, with few food fraud incidents.  Much of the data derives from cross-border food movements, especially in RASSF.  They are both free and searchable and can be a useful adjunct to the free food fraud database on Trello.

 

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What to do About Food Fraud (USA)

I was talking to a new client the other day.  They are based in the United States and had discovered their competitors’ products contain undeclared ingredients.

What should they do, they asked.

There is no simple answer, especially not in the US where there is a patchwork of overlapping government agencies and rules to navigate.

Here’s the process I follow with this type of enquiry:

  1. Establish whether food fraud has occurred or not
  2. Categorise the fraud into one of two types
  3. Determine which regulations and agency(s) are relevant to the fraud
  4. Review the evidence – what made you think this was fraud in the first place?
  5. Decide whether more evidence is needed before pursuing the matter
  6. Choose who to tell, and in which order
  7. Choose how to progress after initial responses
  8. Inform interested parties
  9. Follow up if needed
  10. Execute further action if required

Example: hazelnut oil

We’ll use the example of a company that sells pure hazelnut oil and has discovered that their competitors’ products, labelled “100% pure hazelnut oil” actually contain significant quantities of sunflower oil.

1. Establish whether food fraud has occurred or not

Is this food fraud?  Yes, because consumers or customers are being misled by the labels, the mislabelling provides an economic benefit to the seller and the mislabelling is illegal.

2. Categorise the fraud into one of two types

At this step, I ask myself “Has the food itself been affected in some way – for example by adding or subtracting an ingredient – or not?”, and categorise accordingly.

In this example, the food contains an ingredient that isn’t expected or declared.  Therefore the food has been affected.  On the other hand, if the fraud was a false organic claim on the pack I would categorise that as not affected.

Why is this important?  Because it can highlight any urgent food safety issues and helps me to decide how/where to report and what evidence will be needed.

Speciality oils like hazelnut oil are vulnerable to food fraud, including dilution with cheaper oils like sunflower oil. Image generated with Canva AI

 

3. Determine which regulations and agency(s) are relevant to the fraud

For the hazelnut oil example, the two main agencies are the Federal Trade Commission (FTC) and the US Food and Drug Administration (FDA): the FTC because the oil is ‘misbranded’ according to the Food, Drugs & Cosmetics Act (misbranding means the label is false or misleading); and the FDA because they are responsible for ingredient lists, traceability and quality defects in foods.

4. Review the evidence

In this example, we knew that the fraud-affected products contained sunflower oil because of testing my client had performed.  Before we decide on a course of action we need to know more about this testing:

  • Who did the testing?  Is the testing laboratory independent?  Is it accredited for this scope?
  • What method was used? Has the method been validated or approved?  What is the accuracy and precision?
  • How were the samples chosen?
  • Does the laboratory impose conditions on the use of results and reports?
  • Would the results stand up in court if needed?
  • Have duplicate or repeat test(s) been done?  Alternative methods tried?

For the hazelnut oil, we concluded we can be confident that the results show evidence of fraud, however, an internal laboratory was used, and this means the results are not independent and would not stand up in court, or to media scrutiny.

5. Decide whether more evidence is needed before pursuing the matter

In this case, the test results are not independent, so further testing would be needed if the matter were to be pursued in a court of law, or presented to media outlets.

6. Choose who to tell, and in which order

Who you choose to tell about a fraud depends very much on your relationship with the suppliers of the fraud-affected foods.

For example, if you are a customer – that is if you purchase the fraud-affected products – you should talk to the supplier on the telephone to explain what you found and find out what they have to say.  It’s entirely possible that the company is a victim of their supplier and are unaware of any problem.

If you are a competitor it is best practice to let the company know what you found.  Again, they could be victims of their suppliers.  Give them the laboratory report (if an external lab) and tell them to direct any questions to the lab – if the lab is okay with this.  Let them know you intend to take the matter further.

You can report the fraud to enforcement agencies immediately after you have told the company, or wait to see how they respond.

If there is a credible food safety risk you must report the issue to the relevant authorities so that they can take action to protect consumers.

The hazelnut oil company is in the United States, so we decided to report the issue to the organizations below, after informing the owners of the affected brands.

7. Choose how to progress after initial responses

We decided that if the brand owners did not take action to correct the frauds and prevent them from occurring in future – for example by changing the claims on product labels, or by altering formulations – that we would commence a civil lawsuit against the brand owners.

A lawsuit would require us to obtain further evidence, including independent tests performed by an accredited laboratory.

8. Inform interested parties

We contacted the brand owners first, then the authorities, keeping accurate records of conversations and correspondence.

9. Follow up

We expect to have to follow up with the companies and the enforcement agencies, and have set timeframes for this.

10. Further actions

We hope to avoid taking legal action against the perpetrators in the civil courts, and would like to see the matter pursued by the FTC and the FDA in a timely manner.

We will repeat the tests in the internal laboratory in a few months’ time to see if there have been any changes to the formulation of the products.

Want help with a situation like this?

If can brief senior management, help formulate a plan of action, work with your laboratory and take charge of all the communications.

Get in touch with me

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Paprika, Chilli Powder and Sudan Dye Contamination

Can paprika and chilli powder be “too red”?

This post was originally published in The Rotten Apple newsletter.

 

In 2016 an inspector from the New York State (NYS), Department of Agriculture and Markets visited a food market looking for suspicious spices. There had been a spate of adulteration incidents with paprika and related spices such as chilli powder and curry powder internationally and the New York authorities were surveying local supplies.

The inspector was Audrey, a colleague of Tom Tarantelli, now retired. Tom recently sent me an intriguing photograph of some products from the same brand that Audrey spotted that day.

In one store, Audrey noticed some packages of paprika that looked “too red”. This was, perhaps, a sign the paprika had been adulterated with unauthorised colourants.

She purchased the paprika and took it back to the lab for testing.  It was, indeed adulterated. Tom told me they found 2,400 ppm Sudan 4 and 850 ppm Sudan 1 in the product. It was one of the highest concentrations of Sudan 4 ever found, as high as the worst European case that had been reported up to that time.

The results were so remarkable that Tom purchased more packages to keep. “Realizing this product would be thrown away, I went to the store and obtained more. Such a great sample!” Tom told me.

That was in 2016, eight years ago.  Today, the products Tarantelli purchased are still a brightly-hued, fresh-looking red.

Paprika samples purchased in 2016 retained their “too red” colour for almost 8 years. This photograph was taken in December 2023. Paprika from this brand contained very high concentrations of the illegal, carcinogenic dyes, Sudan I and Sudan IV. Photograph: Thomas Tarantelli

 

The photograph above was taken just a few months ago, more than seven years after the samples were purchased. The colour is bright. Pure paprika, on the other hand, loses its red colour over time and ages to a dull brownish colour.

This is the challenge for spice traders: old paprika doesn’t have an attractive colour. Dull-coloured paprika is perceived to be of lower quality and to have less flavour, and therefore must be sold for a lower price.

One solution is for traders to add colouring agents to their wares. Since pure spices are not allowed to contain even food-grade colourants, the traders do not bother to use colourants that are safe or legal. Instead, they use colourants that are cheap, easy to obtain and easy to handle.

Sudan dyes seem to be popular with unethical spice traders who want to enhance the colour of the spices they sell. The dyes are industrial colouring agents, much cheaper than food-grade colours, and sold for use in industrial oils, waxes and shoe polish. Sudan I has an orange colour and  Sudan IV is a blueish red. Sudan dyes have been found in paprika, chilli powder and curry powder many times over the past decade. They are also a common adulterant in unrefined palm oil, which has a bright red colour when fresh.

Sudan dye adulteration was first detected in food in 2003, and was the cause of a huge recall in the United Kingdom in 2005, which affected 570 foods. Alerts and notifications for Sudan dye contamination continue to this day. Last month Italian authorities rejected palm oil from Ivory Coast because it contained Sudan 3 and Sudan 4 dyes and German authorities recalled cheddar cheese powder from Syria which contained multiple Sudan dyes.

There were 39 notifications for Sudan dyes in foods between 2014 and 2024 in the European Rapid Alert System for Food and Feed (RASFF), and 12 in the US FDA Import Alerts records. Many of the alerts are for adulterated palm oil, but in Europe, paprika, seasoning and spice blends, barbeque rub, chilli pepper, sumac and sweet and sour sauce were also affected. In America, barbeque flavoured snacks were affected in addition to palm oil.

FT-NIR spectra of a pure sample of paprika and the same sample after adulteration with Sudan II, III, IV and Congo red at 5 % (w/w). Source: Castell, et. al (2024)

 

The incident in 2016 wasn’t the only time Tarantelli and his colleagues found Sudan dyes in spices. In fact, they found sixteen commercially available spices containing such dyes in less than two years. The spices included turmeric, curry powder, malathy and chilli powder in addition to paprika.

Chemists from the New York State (NYS), Department of Agriculture and Markets found Sudan dyes in sixteen samples in less than two years. Source: Thomas Tarantelli in Food Safety Tech (2017)

 

The New York State inspectors reported their results to the US FDA, prompting a series of recalls. Unfortunately, the recalls were classed as less serious Class 2 recalls because of the assumption that spices like paprika are consumed in only small quantities.

However, as Tarantelli pointed out in an article he wrote in Food Safety Tech in 2017, assumptions about serving sizes can be wrong. In fact, when he compared the amount of spice consumed by some ethnic groups to the reference serving size used by the FDA they were 20 times higher.

“In the Code of Federal Regulations (CFR) Title 21, the serving size per meal for spice is referenced as ½ gram. However, certain ethnic groups may consume a daily amount of 20 grams of spice per person.”

Takeaways for food safety professionals

  • Foods that appear fresher, tastier or of better quality when their colour is more intense are vulnerable to adulteration with undeclared colourants.
  • Red-coloured foods such as paprika, chilli powder and palm kernel oil are sometimes adulterated with Sudan dyes to enhance their colour and increase their apparent value.
  • Sudan dyes are not approved for use in food, they are industrial dyes with carcinogenic properties.
  • Despite a long history of recalls, safety alerts and import alerts for Sudan dye adulteration, food fraud perpetrators continue to adulterate foods with this dangerous group of chemicals.
  • Although some food regulators consider adulterated spices to present a lower risk to consumers than other foods, because many people consume them in small amounts, some sectors of the population consume significant quantities of spices and are therefore at higher risk.
  • Food businesses that purchase red-coloured foods including spices and unrefined palm oil should consider such foods vulnerable to Sudan dye adulteration, and implement mitigations.

Main sources:

Castell, A., Arroyo-Manzanares, N., López-García, I., Zapata, F. and Viñas, P. (2024). Authentication strategy for paprika analysis according to geographical origin and study of adulteration using near infrared spectroscopy and chemometric approaches. Food control, 161, pp.110397–110397. doi:https://doi.org/10.1016/j.foodcont.2024.110397.

‌Tarantelli, T (2024), correspondence with author.

Tarantelli, T. (2017). Adulteration with Sudan Dye Has Triggered Several Spice Recalls. [online] FoodSafetyTech. Available at: https://foodsafetytech.com/feature_article/adulteration-sudan-dye-triggered-several-spice-recalls/.

‌There are ‘protected origin’ paprikas in Europe (more correctly known as Protected Designation of Origin (PDO)).  These protected paprikas are from specific regions and are known for their unique regional characteristics.  For example, there is a special paprika from a certain part of Spain called Pimentón de La Vera and one from Hungary called Kalocsai fűszerpaprika-őrlemény.  Source: Castell et al (2024)

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Is Food Fraud to Blame for the Cinnamon-apple Recall (Video)

Our Principal, Karen Constable, explains how high levels of lead may have got into applesauce (video audiogram).

For sources and a transcript, click here.

 

 

 

 

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Is Food Fraud to Blame for the Cinnamon-apple Recall?

[Listen to an audio version of this post here]

In October 2023, cinnamon fruit puree baby foods were recalled in the United States after four children were found to have elevated levels of lead in their blood.  Multiple lots of the products were found to have “extremely high” concentrations of lead.

As of 23 January 2024, the number of affected people had increased to at least 385.

And this could be just the tip of the iceberg, because it’s thought that around 1.8 million packages were affected, accounting for around 8 months of production.  That means thousands, or perhaps tens of thousands, of other people also consumed the tainted food.

Watching the case numbers go up, from 4 cases in October to 251 in December and now 385, has been like watching a slow-motion train crash.

a chart of case numbers in the cinnamon applesauce recall
The number of cases has climbed from four to more than three hundred in just a few months.  Source: (US) FDA

How much lead was in the food?

The earliest reports from the FDA said the level of lead in the recalled foods was “extremely high”.  Later, they reported finding lead at levels of 2 parts per million (ppm) in one sample of the fruit puree.  That level is more than 200 times the maximum level proposed by the FDA in their draft guidance for fruit purees intended for babies and young children.

 

How did the lead get into the food?

Cinnamon was suspected of being the source of the lead contamination from the earliest days of the recall because products made by the same manufacturer without cinnamon were not affected.  It took some time for the FDA to obtain samples of the cinnamon for testing, and it was not until mid-December that results were published.

In December, the FDA confirmed that the cinnamon ingredient in the foods was the source of the lead.

How much lead was in the cinnamon?

The FDA found lead at up to 5,110 parts per million (ppm) in the cinnamon.

That is more than two thousand times higher than typical.  Cinnamon usually contains just 2 ppm of lead (Hore, et. al (2019)).  The amount in the cinnamon is also more than two thousand times higher than the ‘safety’ limit of 2.5 ppm proposed for cinnamon by the Codex Alimentarius Commission.

The figures below provide a graphical representation of the amount of contamination. The image on the left shows 5,110 ppm, the amount of lead found in one sample of the contaminated cinnamon, equal to five squares of the 32 x 32 grid. The image on the right represents the maximum amount of lead allowed in cinnamon: less than one pixel on your screen.

A graphical representation of the amount of lead in the samples. Left: 5,110 ppm, the amount of Pb found in one sample of cinnamon; Right, 2.5 ppm, the proposed maximum allowable limit.

Why was there so much lead in the cinnamon?

Cinnamon can become accidentally contaminated with lead in various ways.  Cinnamon trees, from which the spice is made, can absorb lead from the soil as they grow.  Cinnamon can also become contaminated with lead through contact with machinery or transport vehicles that have lead-containing alloys, solders or paints, or lead-containing environmental dust and dirt.

However, accidental contamination such as from the soil or through contact with paint results in low levels of contamination.  The levels of lead in the samples tested by the FDA were thousands of times higher than would occur from accidental contamination.

In the first months of the investigation, many food safety commentators openly discussed the possibility that the cinnamon was deliberately adulterated with lead for economic gain.  Tampering with food for economic gain is more commonly known as food fraud, or, in the USA “economically motivated adulteration”.

Lead adulteration of spices

For buyers and sellers of spices like cinnamon, one way to make more money is to add colourants to the spices to make them look better.  For example, fresh high-quality turmeric has an intense yellow colour, so adding yellow colourant to turmeric can increase its appeal, meaning it can be sold for a higher price.

Unfortunately, the colourants used by unscrupulous spice traders are not always safe.  Many of them are lead-based pigments, which are cheap, have intense colours and are easy to obtain in some countries.

The most well-studied example of such fraudulent adulteration is the use of lead chromate (‘chrome yellow’) to impart a bright yellow colour to turmeric.

🍏 Read how traders in Bangladesh were using lead chromate to color the turmeric roots they were selling (and what made them stop) 🍏

Lead chromate comes in a range of intense colours, ranging from pale brown to intense oranges and crimson.  In addition, because lead is a heavy metal, it is literally heavy.  Spices are traded by weight, so adding a lead-based pigment increases their weight and hence the price.

Lead-based pigments in spices have caused harm to children in the past. Lead-chromate adulterated turmeric caused children in the USA to be poisoned in 2010 – 2014. Paprika adulterated with lead oxide caused the hospitalisation of more than 50 people in Hungary in 1994.

A sample of the Georgian spice kviteli kvavili, also known as yellow flower or Georgian saffron, was discovered to contain 48,000 ppm of lead in a NYC Department of Health and Mental Hygiene (DOHMH) lead-in-foods survey. In the same survey, which assessed more than 3,000 food samples over ten years, nineteen cinnamon samples had a median lead level of 2 ppm, with the highest level in cinnamon being 880 ppm.

That figure, 880 ppm of lead in cinnamon, from a paper published in 2019, is not as high as in the latest incident, but it is more than four hundred times higher than ‘normal’, and enough to result in dangerously high levels of lead in any food to which the spice was added.

Mean lead concentrations in various spice samples: cumin, red chili, turmeric, coriander powder. The line at 2.5 mg/kg (ppm) is the allowable limit in Bangladesh. Source: Alam et al (2023)

Is this a case of food fraud?

Deliberately adding lead-based pigments such as lead chromate to spices is, unfortunately, a common food fraud practice.  The intention is to make more money for the perpetrator.

Some weeks after the lead results were shared by the FDA, they revealed that the cinnamon contained high levels of chromium as well.  Test results for other heavy metals, including arsenic and cadmium, were not higher than usual.

Two samples of cinnamon contained 1,201 ppm and 531 ppm of chromium, respectively.  The ratio of lead to chromium is consistent with lead chromate having been added to the cinnamon.

There have been many past cases in which food fraud perpetrators have added lead chromate to spices.  Because the cinnamon in this investigation likely contains lead chromate, and because lead chromate is added to spices to increase their apparent value by changing their appearance and adding weight, food fraud is the most probable explanation for the presence of lead.

Probable explanations for the extremely high levels of lead in the cinnamon:

  • lead is a component of the pigment lead chromate, which is used to impart bright colours to textiles;
  • lead chromate is cheap and easy to obtain in some countries;
  • lead chromate is sometimes used to illegally add colour to spices, particularly turmeric;
  • spices coloured with lead chromate appear fresher and of higher quality than uncoloured spices, and can be sold for a higher price;
  • lead chromate comes in a range of colours, including browns, crimsons and yellows;
  • the cinnamon in this incident contained very high levels of chromium as well as lead.  Chromium is also a component of lead chromate pigment;
  • spices adulterated with lead chromate are heavier than pure spice, so they can be sold for a higher price;
  • the addition of lead chromate to the cinnamon could have allowed the perpetrator to sell it for a higher price, resulting in economic gains.

Not a food defence (malicious contamination) incident

While some food adulteration actions are intended to cause harm for malicious purposes, lead adulteration does not lend itself to intentionally harmful adulteration.  Malicious acts are intended to create a high impact on consumers or companies, but lead poisoning is slow-acting and can take months or years to be identified, minimising the potential for a high-impact incident.

If the cinnamon was intentionally adulterated, the slow-acting nature of lead poisoning means the primary purpose of the adulteration was probably not to cause harm to consumers.

Conclusion

When the history of lead chromate adulteration of spices is considered, along with the presence of high levels of both chromium and lead in the cinnamon, and the fact that lead poisoning is slow-acting, it seems likely that the cinnamon used to make the recalled fruit purees was intentionally adulterated with lead chromate-containing material for economic gain.  That makes it an example of food fraud.

More details about the recall and investigation can be found here: Investigation into elevated lead levels in cinnamon-applesauce pouches (US FDA)

An earlier version of this post originally appeared in The Rotten Apple, a weekly newsletter for food professionals, by Karen Constable