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6th January 2020 by Karen Constable

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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Filed Under: Food Fraud

30th October 2019 by foodfraudadvisors

Frequently Asked Questions

Vulnerability Assessment Tool (BRC Packaging Materials) – Frequently asked questions (FAQ)

Is this assessment tool suitable for businesses operating to management system standards other than BRC Packaging Materials?

This spreadsheet is especially designed to meet the requirements of BRC’s (British Retail Consortium) PACKAGING MATERIALS Issue 6, which requires that businesses assess their raw materials for vulnerability to economically motivated (fraudulent) substitution.

It is not recommended for businesses that need to meet the requirements of other management system standards.  It is not suitable for food defense or TACCP vulnerability assessments.  We recommend you purchase one of our other tools instead.

Is this assessment tool suitable for businesses that do not operate a food safety or quality management system?

If your business is not operating to a food safety or quality management standard and does not have supplier approval processes, purchasing specifications and robust systems for receiving materials then it is more vulnerable to accepting fraudulent material and this tool will underestimate the risk.

What about the Threat Assessment Tool?

The threat assessment tool is a bonus add-on for purchasers of the packaging vulnerability assessment tool, it is not sold separately.  Is is also designed to meet the requirements of BRC Packaging Issue 6.

What happens if I can’t complete all the questions?

If you have not answered all the questions the tool will estimate your material as being vulnerable (very likely to be affected by fraudulent substitution). However it is possible to supplement the calculated rating with your own estimate if desired. This means that if you already think that a particular raw material has a very low risk you may choose to simply enter your best estimates of likelihood instead of completing all the data fields. This will allow you to prioritise your time and focus on the most important raw materials first.  Note that if you do this the resulting assessment documents are unlikely to be acceptable to an auditor because they will not contain a complete explanation of how the risk assessment was performed.  To obtain a complete explanation, every question should be answered.

What if I disagree with the results?

The Vulnerability Assessment Tool calculates the vulnerability using information entered by the user.  Users are encouraged to also enter their own estimates.  The reported results are based on the user’s estimates if they have been entered; if not, calculated results are used.

Why is the Vulnerability Assessment Tool an Excel spreadsheet instead of specialised software?

The tool was created with Microsoft Excel because most of its intended users are familiar with excel and so can begin entering data as soon as they open the spreadsheet, with no special training.   Data can be copied, pasted and searched just as you would in any spreadsheet and results can be easily extracted for use in other documents. Blank and completed spreadsheets can and should be incorporated into a company’s controlled documents and record-keeping system and Microsoft Excel files are usually suitable for this purpose.

The tabular format of the data entry pages allows users to have a ‘whole picture’ visual understanding of the data that has been entered and the gaps that need to be filled.  Other types of software such as questionnaire-style assessments do not provide a visual overview and require information to be entered in a defined series of steps which can be frustrating. Within the tables of the Vulnerability Assessment Tool, colour-coding functions provide instant feedback about whether an answer affects vulnerability in a positive or negative way, which can be a valuable learning tool.

Why are some of the cells password protected?

Password protection has been applied to many of the cells in the spreadsheet.  There are a number of reasons for this, the most important of which is so that users do not accidentally ‘break’ the formulas which would be very easy to do if it was unlocked.

This means that users are not able to make changes to the wording of the questions or the automatically generated answers.

Can I copy the results into my own spreadsheet or other document?

Yes. The data can be copied, pasted, sorted and manipulated as in any spreadsheet. When copying from the tool use the excel function ‘paste special – values’, which will prevent pasting formulas that might return error values in a different document.

Do I have to purchase a new spreadsheet for each material group?

No, you may make as many copies of this spreadsheet as you need for ONE business in one manufacturing location.  You may not share it with other businesses or take it when you change jobs.  For complete terms and conditions click here.

Is there a telephone number I can call for help and support with the tool?

For support, please email support@foodfraudadvisors.com with your query, including your preferred contact details and geographical location (for time zone purposes). We will contact you by telephone or Skype or email an answer to you.

Can I have access to the formulas that generate the results?

If you disagree with the results the tool allows you to override them; the reported results are based on the user’s estimates if they have been entered; if not, calculated results are used.

If you think the methodology, including the risk calculations should be amended or you think there is an error in any formula please contact us. We want the Vulnerability Assessment Tool to be the best that it can and value your feedback.

Want to buy an unlocked version that is fully customisable?  Request a quote here.

My security settings will not allow me to run macros, is this a problem?

No problem; the Vulnerability Assessment Tool has been created without macros to keep things safe and secure and to prevent headaches with your internal IT systems.

Which version of Excel do I need to use the tool?

The Vulnerability Assessment Tool is compatible with Microsoft Excel 2004 onwards (file extensions .xlsx) and Microsoft Excel for Mac 2011 onwards.

Can I get a tax receipt?

Australian purchasers receive a tax invoice for GST purposes in their confirmation email.  Purchasers in other countries are not charged any tax but receive an itemised purchase receipt in their confirmation email.

Filed Under: Vulnerability Assessment Tools

7th October 2019 by foodfraudadvisors

Latest news in food fraud

US beef sellers behaving badly and new information about lead in turmeric

In September 2019, four men from the United States beef industry were accused of food fraud by authorities. The men were owners and executives at two unrelated companies; one a beef wholesale company in New York, the other a Texan supplier to the US government.

Why would any person perpetrate food fraud? It is alleged that the New York men were struggling to make a profit in their business, even going so far as to successfully audition for a business makeoever reality TV show. They are alleged to have systematically removed United States Department of Agriculture-approved meat quality labels from cuts of beef and replaced them with counterfeit labels of a higher grade, enabling them to sell the beef at a higher price.

The men in Texas, who plead guilty for their role in a scheme to illegally add cow hearts to ground beef and who admitted to hiding the cow hearts from government inspectors, were almost certainly doing it for the money. The courts have heard that they sold the more than $1m worth of the adulterated meat to the Federal Bureau of Prisons.

In both of these cases, the frauds resulted in customers receiving food that was not true to label, and those customers proceeded to unknowingly sell and serve it to un-suspecting consumers. In one case, the meat was mislabelled but not physically modified, in the other case, the meat itself was adulterated with unauthorised material. When food is adulterated or otherwise modified, processed or (re-)packed in a fraudulent manner, the result is a product that can present significant food safety risks to consumers.

Texan meat processors have pleaded guilty to adding beef heart to $1m of ground beef.

 

Food fraud perpetrators generally wish to avoid causing serious or obvious food safety issues; after all, they do not want to be caught.  As a result, not all food frauds result in food safety incidents.  In a terrifying exception to this rule, however, it was alleged that a group of at least five people who adulterated black pepper in Vietnam in 2018 were aware that the adulterants were toxic.  The weight of the pepper was fraudulently increased by the addition of home-dyed gravel and coffee bean skins.  The dye was made by breaking open batteries to extract black-coloured manganese dioxide powder.

Another example of a toxic adulterant and one that has caused widespread illness and suffering is the industrial chemical melamine.  Melamine, which contains nitrogen atoms, can be used to trick some protein test methods which calculate protein content of food based on nitrogen within the food.   Melamine adulteration can therefore be used to boost the apparent protein content of foods such as milk powder, that are priced according to their protein content. Three hundred thousand babies became ill after drinking milk adulterated with melamine in China in 2008.  Six babies died and tens of thousands of other infants, who are now teenagers, received irreversible kidney damage, condemning them to a life of renal dialysis and ongoing surgeries.

Melamine has also been used to fraudulently adulterate wheat products, meat products and animal feed.  In the United States, melamine adulteration of dog and cat food caused the deaths of up to 3600 pets in 2007.

One of the scariest food safety issues to arise in connection with food fraud in recent years affects a food product favoured by some wealthy western consumers for its health-giving properties.  Turmeric has been lauded as a wonder-food; with properties that are said to cure joint pain, reduce inflammation, improve mood, brain function and protect against heart disease.  But powdered turmeric also presents real food safety risks to consumers because a significant proportion of powdered turmeric traded worldwide contains unsafe levels of lead.  Lead is a potent neurotoxin that damages organs including the brain.  Research released in September 2019 confirmed that the lead in turmeric is added to the spice in the form of toxic lead chromate which has a beautiful, intense yellow colour, the exact colour favoured by turmeric traders and buyers as an indicator of freshness and quality.  Curry powder, cumin and cinnamon have also been affected.  Another 2019 study, which surveyed more than 1496 samples of 50 spices from 41 countries found that 50% of the spice samples had detectable lead, and more than 30% had lead concentrations greater than 2 ppm, a level 200 times higher than the recommended maximum lead content of candy in the USA.

While not all food fraud represents a risk to food safety, fraudsters who adulterate food to make extra money for themselves put consumers lives at risk.  Stay up to date with new food fraud incidents on our free, open-access food fraud database.

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Filed Under: Food Fraud

29th September 2019 by foodfraudadvisors

Authenticity testing – recommended frequency

Part 3 in our series about food fraud testing

Part 1: Food testing checklist

Part 2: How to design a food testing plan

Guidance on test frequencies:

When developing a food fraud testing plan, one of the biggest challenges is choosing the frequency of testing.  Food Fraud Advisors has developed these guidelines to use as a starting point.   They are not a definitive guide, always follow the advice of your analytical laboratory and specialists.

For any given material, the frequency of testing should be based on its susceptibility to food fraud.  Suggestions for five different types of materials (A, B, C, D) are described below. Test frequencies should be reviewed and adjusted on a regular basis. Frequencies can be decreased if results are consistently acceptable and increased if problems have occurred or if there are changes to the product or the supply chain.

Type A: a material known to be very susceptible to food fraud (eg. honey, white fish fillets) but for which no specific incidences have occurred within your supply chain and for which no intelligence related to your supply chain has been received.

Phase 1: test a sample from 5 out of 5 incoming batches from every supplier and/or geographical source. For agricultural materials, this sampling protocol should be repeated on a seasonal basis across the year. The aim is to build a picture of authenticity across the year for your suppliers. Progress to phase 2 if all the results from phase 1 have been satisfactory. If test results have revealed problems with authenticity, phase 1 should continue for the affected suppliers or places of origin. Suppliers with satisfactory results can progress to phase 2.

Phase 2: reduce the frequency of testing to one sample per 5 to 10 incoming batches, with the frequency based on your estimate of the ongoing risk. As in phase 1, materials with seasonal supply fluctuations should be tested over various seasons. Use the results from phase 2 to continue to add to the overall picture of authenticity for this material type within your supply chain. Continue until you have at least 10 results. Progress to phase 3 if all results are satisfactory.

Phase 3: is an ongoing maintenance phase. Aim to test one sample per 10 to 20 incoming batches as an ongoing protocol.

Type B: Material for which you have received specific intelligence related to authenticity that pertains to your supply chain.

Phase 1: focussing on the implicated products or ingredients, take samples from at least 5 incoming batches. If the material is non-homogenous – for example if it is in individual packages, or individual pieces rather than being a bulk liquid or powder – consider taking duplicate or triplicate samples from each incoming batch, if budget allows. If all of these samples ‘pass’ the tests, consider trying alternative test methods or test types. Move to phase 2 if all test results are satisfactory.

Phase 2: reduce the frequency of testing to one sample per 5 incoming batches. Continue this frequency of testing until your intelligence information and your test results are sufficient to suggest that the risks within your supply chain have passed. If the risk has abated, reduce the frequency to that of phase 3 for type A.

Type C: Moderately susceptible materials

Phase 1: test a sample from 1 of 5 to 10 incoming batches from every supplier and/or geographical source. For agricultural materials, this sampling protocol should be repeated on a seasonal basis across the year. The aim is to build a picture of authenticity across the year.  Continue until you have at least 5 results per supplier or geographical source. Progress to phase 2 if all the results from phase 1 have been satisfactory. If test results have revealed problems with authenticity, phase 1 should continue for the affected suppliers or places of origin. Suppliers with satisfactory results can progress to phase 2.

Phase 2: test one sample per 10 to 20 incoming batches with the frequency based on your estimate of risk. As in phase 1, materials with seasonal supply fluctuations should be tested over various seasons. Use the results from phase 2 to continue to add to the overall picture of authenticity for this material type. Continue until you have 5 results. Progress to phase 3 if all results are satisfactory.

Phase 3: If all results from phases 1 and 2 are satisfactory, the frequency of testing can be significantly reduced. One test per year per supplier should be adequate for most materials and suppliers.

Type D: Food products at risk of counterfeiting or suspected of being from illegitimate sources

A market surveillance sampling plan should be devised. Retail and/or wholesale sources in high risk markets should be targeted in addition to online marketplaces. Anonymous market ‘buyers’ could be engaged to obtain the samples. Buyers can be instructed to purchase a specific number of items per batch per outlet, or they can be instructed to inspect or photograph samples in situ. The amount of surveillance will depend on the brand owner’s tolerance of counterfeiting and the testing budget.  Products at high risk of counterfeiting are likely to need ongoing surveillance.  Food products that have been found to have entered marketplaces through theft, diversion or grey market channels can have their risk reduced by implementing controls within distribution chains.

Type E: low risk materials. If a food ingredient or product has been shown to be low risk in a food fraud vulnerability assessment then authenticity testing should not be required. If the material or supply chain has changed such that the material requires authenticity testing then its food fraud vulnerability should be re-classified to medium or high risk.

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Filed Under: Food Fraud, Learn

10th August 2019 by foodfraudadvisors

Learn the lingo; food fraud terms explained

Food fraud occurs when food or drink is sold in a way that deliberately misleads or deceives consumers or customers for financial gain (Food Fraud Advisors, 2015)

(other definitions)

Food fraud occurs in two different forms:

1. Fraudulent activity that does not involve tampering with the food itself:

This includes activity such as avoidance of taxes, duties and quota restrictions (fishing), fraudulent paperwork such as forged importation documents, misrepresentation of origin, changing best-before dates and counterfeiting of popular brands.

2. Adulteration of food for economic gain:

This is sometimes referred to as economically motivated adulteration or EMA.  In this phrase, the word ‘adulteration’ is used to encompass many types of tampering, such as adding unauthorised substances, substituting undeclared substances for genuine components of a food or diluting a food product with cheaper substances.

Food fraud is a type of food crime, with food crime including food fraud and other activities such as the use of food shipments to mask drug trafficking and money-laundering through the trading of food and food commodities.

food fraud,defense,safety,security

Food fraud and the risks it presents to the food industry is a separate subject to food safety, although fraud-affected food can be unsafe.  Food safety relates to unintentional contamination of food and the presence of naturally occurring contaminants.

Food defence (food defense) is a term that has come to be defined as the effort to prevent acts of adulteration that are intended to cause harm to a food business or to consumers, such as acts of terrorism or attempted extortion.

Food security, as defined by the World Health Organisation exists “when all people at all times have access to sufficient, safe, nutritious food to maintain a healthy and active life”.

Risk or vulnerability?  In the language of food fraud, the term risk is usually replaced with the term ‘vulnerability’, so food standards bodies are increasingly talking about vulnerability assessments rather than risk assessments.  ‘Vulnerability’ is used because food fraud ‘risks’ do not exactly fit with the accepted definition of risk as something that has occurred frequently, will occur again and for which there is enough data to make quantitative assessments.  Vulnerability is a better term for food fraud, due to the fact that the ‘risk’ of a specific fraudulent activity occurring cannot be quantitatively assessed.

Horizon scanning is another term that has been co-opted to the language of food fraud.  Horizon scanning is the act of looking for and analysing threats and opportunities that will emerge in the medium to long term.  It is used across many industries, including the financial and health care industries.  Within the food industry, horizon scanning refers to the act of collecting information about current trends in food production and predicted incidences that could increase the likelihood of food fraud for a particular food material.  For example, climate change is likely to affect coffee production which could drive up prices and increase fraudulent activity in that sector.  Click here for the complete low-down on horizon scanning.

TACCP: Threat Assessment Critical Control Point.  TACCP = prevention of malicious threats to food.

VACCP: Vulnerability Assessment Critical Control Point.  VACCP = food fraud prevention.  Learn more about TACCP and VACCP here.

Intentional Adulteration:  Although food fraud activities often involve the intentional adulteration of food with unauthorised substances, within the food safety industry, Intentional Adulteration has recently been given a more specific meaning.  And it is not related to food fraud at all.  It is related to food defense, and more specifically to activities intended to cause wide scale harm to consumers.  There is a rule within the USA’s Food Safety Modernization Act (FSMA), that addresses these activities.  It is known as the Intentional Adulteration rule.  According to the US FDA (2019), Intentional Adulteration is the deliberate contamination of food with a biological, chemical, radiological, or physical agent by an individual or group of individuals with the intent to cause wide scale public health harm.  How to protect against intentional adulteration. 

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Filed Under: Learn, TACCP, VACCP

23rd June 2019 by foodfraudadvisors

Beyond vulnerability assessments

How to verify a food defense plan

The USA FSMA Intentional Adulteration Rule deadline is fast approaching, with implementation required by 26th July.  Food defense plans are our most requested service this month, and not just for companies in the United States.  Businesses that export to the US are also affected.

The Intentional Adulteration (IA) rule

The Intentional Adulteration (IA) rule requires food businesses to identify vulnerable parts of their food manufacturing processes, implement strategies to reduce the vulnerabilities and monitor and verify that those strategies are working.  As part of the verification processes, some experts are recommending that food businesses challenge their food defense system on a regular basis.  Food safety management system standards, including SQF Edition 8, also require that manufacturing facilities challenge their food defense system.  What exactly does it mean to ‘challenge’ a food defense system, and how is that different to monitoring and verification of the system?

Monitoring vs verification vs challenge testing

Monitoring, verification and challenge testing are different, but the terminology can be confusing when used with food defense plans.  Some commentators and trainers are using the three words almost interchangeably; however, the three words actually refer to different elements of a food defense plan.

Monitoring means, at its most basic level, to check that procedures are being followed and that processes are happening as they should.  The checking process must be documented.  So, the act of monitoring is documenting in real time the actions taken to follow a given procedure or the measured outputs of a specific process.

Within a food safety plan, an example of monitoring would be checking the internal temperature of three pies from each batch after a cooling step and recording the temperature on a form.  Within a food defense system, a mitigation strategy might be the implementation of a procedure to lock all external doors, or to leave all external doors locked.  For this procedure, the monitoring activity could be a once-per-shift process of checking and recording the lock/unlock status of each door.

Verification is the process of making sure that monitoring has been done properly.  When cooling pies, for example, verification could include a once-per-shift check by a supervisor or manager that the cooled pie temperatures are being recorded AND that appropriate action has been taken if the temperature has exceeded critical limits.  Verification also includes internal audits; the internal auditor checks that the managers have been signing off the monitoring records, that the records are complete and available for all shifts and that corrective actions have been properly recorded.

In our food defense example, verification could include a check of the door lock monitoring records by a manager or supervisor.  The manager would review the records to see that they were completed on time, at the correct frequency and that any deviations, such as a broken lock, have been identified and actioned correctly.  Verification of door lock status could also be included in a weekly plant walk-through by a manager.  Internal audits would check that all these activities were being done and recorded properly.

Challenge testing is real-world scenario testing of a system’s efficacy.  A challenge test aims to validate whether procedures are effective when implemented as expected, as well as highlighting any failures in implementation.  A challenge test is different to a verification process because it would usually test the implementation and effectiveness of many food defense mitigation strategies rather than focussing on one element such as door locks.

What is the weakest link in your food defense plan?

 

How to conduct a food defense challenge

  1. Decide on a challenge action. For example, a common food defense challenge test is a penetration test, in which an unauthorised person attempts to gain access to a sensitive area.
  2. Create a food defense challenge report. In the report document exactly what you plan to do in the challenge test.  Include what, when, how, who and next steps.

For example: A person unknown to staff (Ms Jane Doe, of Acme Services) will attempt to get from the main reception area into ingredient weighing area A.  She will be wearing a business suit covered by a lab coat.  Once there, she will remain for up to twenty minutes unless challenged by an employee.  She will then leave.

If the intruder is challenged, she will claim to be a new food safety consultant/pest control account manager/new human resources manager and attempt to remain in the area.

  1. Include written contingency plans in case of escalation, for example, what will be done if police are called.
  2. Get approval for the plan from senior management.
  3. In the report record the following:
    • Name of Senior manager who has signed off on this plan.
    • Names of people who have been informed of the challenge test
    • Names of people who will be working in the affected areas at the time of the challenge, have they been trained in food defense?
    • A description of what staff are supposed to do in this scenario; what procedures should be followed.
  4. Define and document the criteria for failure and success; what will happen if the food defense procedures are working 100% correctly; what will happen if the food defense procedures are working only partially; and finally, how might the scenario progress if there is a complete fail of procedures and systems?

For example, if the ‘intruder’ is able to remain in the ingredient weighing area for 20 minutes without being challenged by an employee this could be considered a complete fail of the food defense system.  If the intruder is challenged but can convince the employee to allow them to remain in the area unattended, this could be considered a partial fail; if the employee chooses to remain with the intruder to ‘keep an eye on them’ this could be considered a better outcome than leaving the intruder unattended.

  1. Run the challenge. Have a trusted staff member observe from a discreet distance.
  2. Describe in the report what happened.
  3. Convene a meeting of the food defense team and analyse the results of the challenge test.
  4. Perform root cause analyses and raise corrective action/s for any failures in the system.
  5. Close out corrective action/s
  6. Take action to prevent a scenario like this from reoccurring, based on the root cause analyses.

Learn more about food defense

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Filed Under: Food Defense, Learn

9th June 2019 by foodfraudadvisors

About that “16 easy tests for fake food” video

A video about easy tests for food fraud went viral on Facebook on 1st Jun 2019.  It purports to show how consumers can test for real and fake foods at home.   Food fraud is estimated to affect 10% of all foods worldwide, so it’s a pretty big problem.  At Food Fraud Advisors we are in favour of increasing awareness about food fraud but that particular video is not a good way to do it; it’s full of scare tactics and misinformation.

Much of video in question, published by First Media under their banner Blossom is based on online articles published in India, where food fraud and unethical food business practices are a massive problem that presents both economic and public health risks.  In that country, it is not uncommon for powdered tea to be dyed with textile dyes and for ghee (clarified butter) to be adulterated with undeclared vegetable oil.  Likewise, there is a long history of adulteration of dairy products like milk with chemicals such as urea which is added to trick protein tests, vegetable oil and sugar.   Sadly, in that country, as in other developing countries, it is also common for some fruits, vegetables and dried pulses to be dyed with undeclared chemical dyes.

In India, consumers and government authorities are very aware of food fraud and there is much information online for consumer ‘fraud detection’ tests that can be done at home.   Many of the ‘tests’ in the Blossom video appear to be based on these methods.  Most of them don’t work, or show chemical characteristics that are not evidence of fraud or fakery.

Food fraud occurs more often in developed countries in North America, Europe and Australia, than many people might imagine.  However, it rarely occurs in the ways that are shown in the video.   Lets take a closer look at each of the ‘tests’ in the video with Karen Constable, Food Fraud Advisors Principal Consultant, a food scientist and food fraud specialist.

Melting ‘plastic cheese’

The first part of the video shows a person holding a naked flame to processed cheese and claims this shows that it contains chemicals.  It’s tempting to imagine that all food manufacturers are evil multinationals full of mad, greedy scientists.  But the reason that food companies make and sell processed cheese is because it is convenient to use and it melts really beautifully, so people buy it.  Some people even buy it for the taste!  To achieve the pliable, smooth texture and perfect melting profile loved by consumers, manufacturers add emulsifiers when they make processed cheese.  The emulsifiers tightly bind the protein and fat in the cheese and this means that it behaves differently to non-processed cheese when exposed to a cigarette lighter.  No kidding.  This video by Kraft food scientists explains it perfectly: https://youtu.be/OTH11_oPT20.  Conclusion; processed cheese melts differently to unprocessed cheese and that’s why we buy it!  Conclusion:  this is not a test for ‘fake’ food.

Plastic rice

This part of the video shows a non-stick pan with rice grains interspersed with other white particles that turn clear as the pan is heated.  Rumours of plastic rice have surfaced in various developing countries a number of times since 2011, however none have been substantiated.  There have been credible reports of sacks of rice within large shipments being replaced with sacks of other materials, including paper pellets, sweet potato pellets or plastic resin, to increase the apparent value of the shipment, but there is no evidence that this ‘fake’ rice ever reached consumers.

Food scientists and government authorities in India have investigated but never found plastic rice.  However they acknowledge that rice in India has occasionally been adulterated with chemicals, including boric acid, to close its pores and make it appear shinier and brighter.  These chemicals could give the rice a strange texture or behave strangely when cooked.  This occurs only very rarely.

Rice-like granules made from plastic resins would be completely unchanged by cooking in boiling water, which does not match descriptions provided by consumers who claim to have cooked ‘fake rice’.  In the video, the melting crystals in the pan look like something you could buy in a see-through window art hobby kit.  Just sayin’.  Conclusion:  Reports of consumers cooking or eating plastic rice have never been substantiated.  This is not a test for ‘fake’ food.

Black calcium rocks in baby food

The ‘rocks in baby food’ part of the video is a great example of  how “a little learning is a dangerous thing” (Alexander Pope, 1709).  In the video, a person runs a magnet over a plastic bag of baby food and collects black particles.  Baby food manufacturers deliberately and legally add minerals like calcium and iron to their products, a practice which is called ‘fortification’.  Babies (and adults) need these minerals to grow and thrive.  The minerals used to fortify foods do ultimately come from the earth’s crust, so it’s probably fair – though somewhat disingenuous – to claim that they are ‘crushed up rocks’.  It is indeed possible to get tiny black particles out of fortified foods with a magnet, as you can see in this awesome food science experiment by Scientific American.  However, the magnetic particles are iron, not calcium; calcium is not magnetic.  (Food scientists around the world give a collective face-palm).  Conclusion:  Minerals added to baby food keep babies alive.  Black stuff in baby food is not calcium, it is iron and it is supposed to be present.  Conclusion:  this is not a test for ‘fake’ food.

Baking vitamins

My gosh where do I start with this one?  In the video, a person puts a collection of different coloured and shaped pills and capsules on a tray in an oven and shows some of them bubbling and melting.  Put any collection of different pills in the oven and they will behave differently.  That’s because they contain different things.  Legitimate, authentic vitamins and supplements contain fillers, active ingredients and casings that have both high melting points, low melting points and many different kinds of smoking, burning and bubbling behaviours when heated.  The video claims ‘Synthetic supplements burn; natural supplements don’t‘ but if I made a ‘fake’ pill with chalk or talcum powder it most certainly wouldn’t melt or burn in a domestic oven.

This video is the perfect visual ‘filler’; no real claims, no real evidence, I didn’t even find a historical or anecdotal basis for this one.  Having said that, there have been credible reports of supplements containing smaller quantities of authentic ingredients than they claimed to contain.  Worse, there have been cases of supplements that have been spiked with illegal and undeclared drugs to boost their efficacy.  Conclusion:  supplement fraud does occur, but the oven test in the video will not reveal ‘fake’ supplements.

supplements. authentic, ignite, burn, test
Supplements can be affected by fraudulent adulteration, but you cannot detect inauthentic supplements by baking them in the oven

Glue in meat

In most countries, it is legal to add binders, enzymes and edible ‘glues’ to processed meats and most of those ingredients must be declared on the package.   It is not legal to add chunks of ‘fake’ fatty substances to meat pieces and then sell them as if they were whole cuts.  The video shows what looks like a whole cut of meat, possibly lamb, with fat and connective tissue on and within the muscle.  (Yes, meat is animal muscle, people!)  The meat and fat is prodded and pulled by a fork to supposedly show ‘glue’.

Why on earth a food company would bother making fake, unappealing grisly, fatty bits to add to their ‘whole’ cuts of meat is beyond me; it would be expensive, technically difficult and result in an undesirable product.  Having said that,  there are legal and safe enzymes, including transglutaminase that can be used to bind muscle pieces to make larger pieces of meat.  Pulling such meat apart with a fork would not reveal enzymic binders like transglutaminase.  If binders are present, this ‘test’ would do nothing to reveal them.  Conclusion:  this is not a test for ‘fake’ food.

Bubbling ice cream

The Is your food fake or real? Find out with these 16 easy tests video shows ‘bad’ ice cream which bubbles if you douse it with lemon juice, supposedly because it contains washing powder.  The basis for this myth is probably the very sad situation in India in which local, small-volume suppliers of fresh cows milk have been caught adding detergent to the milk.  The adulteration makes the milk look fresh and foamy when poured from small milk cans into the larger containers used to collect local milk supplies in rural areas.  As for ice cream, I only found one obscure Indian post that suggests washing powder might be found in ice cream.  Perhaps instead, this is a nod to an incident in which noodles were adulterated with non-approved optical brighteners in Vietnam.  Optical brighteners make things look whiter and are found in washing powder.

When it comes to making bubbles with lemon juice, ice cream would need to contain a significant amount of washing powder to achieve the result shown in the video; a small amount of adulteration with washing powder is unlikely to be detectable with lemon juice while a large amount of washing powder would affect the product in other ways, including changing taste.  Let me assure you that of all the food frauds you might encounter in a developed country, washing powder in ice cream is not one of them:  I guarantee that even an unethical ice cream manufacturer is much too smart to feed their consumers washing powder.  Conclusion:  this would be a fun experiment.  It is not a test for ‘fake’ food.

Testing for rice in milk with seaweed

In this part of the video, seaweed is mixed into milk that is said to contain ‘rice water’ and the liquid turns blue.  In most – if not all – countries, it is illegal to add rice to milk without declaring it on the label.  As bizarre as this seems, this ‘test’ is actually plausible: rice starch would make a good adulterant for milk powder in developing countries and seaweed naturally contains iodine which forms blue-black-coloured reactants when exposed to starch, including the starch found in rice.  However I am not sure that seaweed contains enough iodine to produce the strong blue colour in the video.  Conclusion: if you had reason to believe that your milk contained a significant quantity of rice, this test might actually work.  But note that if you live in North America, Europe, Australia or New Zealand, the chances of your milk containing rice water is vanishingly small.

Floating coffee grounds

Ground coffee containing ‘additives’ is shown floating on water in this part of the video, which claims that pure ground coffee will sink quickly.  I don’t know enough about ground coffee to confirm or deny the claims that fresher coffee floats more than stale coffee due to its carbon dioxide content or not, however it sounds plausible to my food scientist brain, as does the claim that different degrees of roasting will result in different densities after grinding.   However I do know that there are many historical records of both coffee beans and ground coffee being adulterated with cheaper fillers like sticks, stones and corn husk to increase profits, most commonly in developing countries.

Coffee consumers in wealthy countries are unlikely to be affected by this type of food fraud.  It is possible that consumers in poor countries could detect adulterants like corn husks or undeclared chicory in ground coffee using a ‘float’ test but I can’t confirm that such a test would be accurate or repeatable.  Conclusion:  this test might be able to reveal certain unexpected contaminants in coffee grounds, however it is unlikely to be reliable.

Cloudy ‘fake’ salt

Sadly, there have been reports of industrial grade salt being repackaged as food grade salt in some African countries in recent years.  The video claims that if the water turns cloudy when you dissolve table salt that the salt contains chalk and is ‘fake’.  It’s true that chalky salt would be easy to identify: if salt contained chalk it would leave undissolved powder in the bottom of the glass when added to water.  On the other hand, you can get cloudy water with authentic, pure salt if the water is warm and contains dissolved air before the salt is added.  Chalk in salt is NOT a common type of food fraud, probably because chalk powder (calcium carbonate) is up to ten times more expensive than salt.  Conclusion:  this ‘test’ is a trick that can be done with pure salt.

salt chalk
Chalk in table salt? Unlikely!

Illegal dyes in tea, peas and sweet potatoes

Unfortunately, unscrupulous food sellers have been known to add undeclared, illegal colourants to food.  If you live in North America, Europe or Australia you are most likely to have encountered this type of food fraud in olive oil, green olives or chilli powder.  There isn’t a lot of evidence of it occurring frequently in dried peas, which are shown in the video being cooked in water that turns a pale green colour.   Tea that is claimed to be ‘impure’ is also shown leaching colour in the video.  In some countries, authorities have seized tea powder that contains illegal dyes or other materials such as brick dust.

As for rubbing sweet potatoes with cotton wool, which is done in the video to supposedly prove the presence of illegal dye, I’m not at all surprised to see red colour on the cotton after it has been rubbed on the sweet potato.  In my country (Australia) our tubers often have a reddish colour on their surface from the red-coloured soil in which they were grown.  Illegal dye-ing of fresh produce is thought to occur very rarely if ever in wealthy countries.  In poorer countries it does occur but is most frequent in produce for which quality and  price are determined by the intensity of colour of the fruit or vegetable.  Sweet potatoes are less frequently affected than table grapes or leafy greens.  Conclusion: this ‘test’ is a trick that relies on red soil found naturally on the surface of some sweet potatoes.

Turmeric adulteration

In this part of the video, two spoonfuls of ground turmeric are exposed to a naked flame.  One burns more readily than the other and the video claims that ‘pure’ spice burns more easily than impure spice.  It is interesting that the video makers chose turmeric to represent spices because it has been associated with numerous recalls due to adulteration with lead-containing colourants  in the USA.  This is very worrying given turmeric’s current popularity as a ‘health’ product in North America and Europe.  The lead colourant used to adulerate turmeric is bright yellow and enhances the colour of the turmeric, increasing its apparent value and hence its price.  This type of fraud is not common but does occur in developed countries as well as developing countries.

As for the test, it is possible, though unlikely, that adulterated turmeric powder would consistently burn in a different way to authentic, pure turmeric powder.  It is more likely that the moisture and oil content of each ‘batch’ or brand of powdered spice would result in different burning characteristics.   Conclusion:  adulterated turmeric might behave differently to pure turmeric when burnt however the test is unlikely to be a reliable indicator of purity.

Honey candle trick

I am sorry to say that adulterating honey by adding water, sugars and syrups is a practice that is as old as human trade.  Honey is valuable and adulterating honey, or diluting it with water is profitable, making it an attractive food fraud.  You can read more about the long and sordid history of food fraud in honey here.  In this part of the video, two samples of honey are applied to candle wicks and the wicks lit.  One candle burns properly while the other doesn’t.  I don’t know anyone who has tried burning honey on a candle wick, but it sounds fun (I’m beginning to wonder if the people who made this video are closet pyromaniacs!)

I have no reason to doubt that putting pure honey on a candle wick will result in a good flame.  Likewise if you put watered-down honey on a candle wick it seems very likely that the water in the honey will stop the wick from burning.   So this test seems somewhat plausible.  However, what we don’t know is (1) how much water do you have to add to pure honey for it to stop a candle wick from burning and (2) what about all the other types of honey fraud; the ones that don’t involve adding water?  Honey fraud can include the addition of other sugars, syrups and colours, rather than the addition of water.  Misrepresentation of variety, geographical origin and organic status are also common types of honey fraud.  These could not be detected using the candle wick test.  Conclusion: this test will show if your honey has lots of moisture in it but is not a reliable indicator of authenticity or adulteration.

Oil in butter test

In the video, it is claimed that if butter contains oil then adding sugar to the mix will result in a pink colour.  This is not true; try it yourself!  The claims are based on a test published in Indian media for checking the purity of ghee.  Ghee is clarified butter and used commonly in Indian cooking.  By law, ghee should not contain anything except butter fat.  Unfortunately there is a long history of ghee fraud in countries where it is popular.  Often the fraud occurs when an unauthorized manufacturer counterfeits an expensive brand which can be sold for a high price.  This ‘fake’ ghee isn’t really ‘fake’ but it does often contain vegetable oils, which are cheaper than butter fat.  There are articles published in Indian media that explain how to check ghee for the presence of vegetable oil by adding hydrochloric acid and sugar.  I haven’t been able to confirm or deny the efficacy of that test.  However, without the hydrochloric acid it most certainly won’t work!  Conclusion:  the test shown in the video is not a legitimate test and it wouldn’t work as a test for ‘fake’ food.

Wax on fruit

Have you ever bought an apple from the farm gate, or picked one yourself to take home and eat later?  Freshly picked apples taste great but if you keep them for more than a few days they soon lose their freshness and begin to shrink and become soft.  This is because apples, like many fruits and vegetables, start to lose moisture from the moment they are picked.  To prevent this, fruit growers apply a thin layer of edible wax to retain moisture and keep the produce fresh and tasty.  The wax is inert and safe to eat.  In the video a fresh, juicy bell pepper, also known as a sweet pepper or capsicum, is dipped into a bowl of warm water and a significant quantity of what looks like vegetable oil can be seen floating on the surface of the water afterwards.

I am not sure if the video is actually depicting fruit-coating wax, since I have never observed this much oily substance coming off any fruit or vegetable.  However it is true that bell peppers and many other fresh fruits and vegetables are routinely coated with wax.  And I am glad of it, since I don’t have time to drive to an apple orchard every time I want a fresh, crisp apple. Conclusion:  this is not a test for ‘fake’ food.

Food fraud does occur in both wealthy and developing countries, but almost never in the ways shown in the video.  When it does occur, unfortunately it is difficult for consumers to identify at home.

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