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How to design a food fraud testing plan

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

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

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

 

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Food testing checklist

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

Food authenticity testing laboratory lab

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

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

And finally…

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

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

Read this next: How to design an authenticity testing program

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Fraudulent practices cost chicken processor £37m

A large chicken processing business, 2 Sisters was the biggest supplier of supermarket chicken in the United Kingdom with a turnover of £1.1 billion in 2017.  During that year, an undercover investigation revealed poor hygiene practices and tampering with date codes was taking place at one of the firm’s processing plants in West Bromwich.  Investigators also alleged that products returned from distribution centres that should have been destroyed were repackaged as if they were fresh, and that the ‘kill dates’ for chickens were deliberately misrepresented so as to extend the expiry date of the finished products.

The Food Standards Agency investigated and in addition found fraudulent practices within the Salmonella testing of the carcasses.  Salmonella testing is a regulatory requirement in the United Kingdom.  In the wake of the investigations, operations at one plant were suspended for 2 weeks, while another was closed permanently.  In April, it was announced that another plant, in Scotland will be closed later this year.

This week, 2 Sisters reported losses of £38 million for the year, a figure that was reported to have ‘ballooned’ by 80% after the fraudulent practices were uncovered.

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Where’s my tricorder?

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

Supplement testing

 

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

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

Answer: I think you want a Star Trek Tricorder

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

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

Authenticity testing is not simple.

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

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

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

Reddit user: Karenconstable4

Want help with supplement authenticity?  Don’t know where to start?
Ask Karen

 

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Love and other illegal ingredients; food fraud news for November

Fish fraud decreasing?

Great news for Canadians, with a recent ‘citizen science’ survey finding very low levels of fish fraud at the retail level.  The study was organised by SeaChoice with the support of  the University of Guelph Centre for Biodiversity Genomics’ Life Scanner program.  Participants used DNA kits to sample fish from local grocery stores across the country.  In all, 501 samples from 49 retailers and representing 46 species were tested.  Just 1% were found to be fraudulently mis-labelled, while 7% were not labelled according to the proper names defined by Canadian regulations.  These numbers are lower than expected and – we hope – the start of a trend towards better traceability and less fraud in the seafood industry.

Gorgeous, but toxic ‘silver’ sweets

Intricately decorated festival sweets in India have been a well-known food fraud risk for many years; unfortunately they are frequently found to have been coloured with cheap and toxic textile dyes rather than approved food additives.  On the eve of the Diwali festival this year, Indian authorities tested sweets and found they contained non-food colours.  In addition, the beautiful silver gilding on some sweets was in fact made from dangerous aluminium, rather than from silver, which is inert and safe to ingest.

Hot dogs in peril

Hot dog sellers in Belgium are worrying about the price of mustard, after the world’s largest producer of mustard seeds, Canada, reported a very small harvest this year.  It is only half of the previous year and the lowest volumes in 11 years.  This is expected to effect supplies and prices of mustard which will increase the risk of food fraud.

Red, red wine

Chapitalization – the act of adding sugar to the wine making process to boost final alcohol content, is the subject of a recent crackdown by Spanish authorities. Chapitalization is not permitted in Spain, although it is allowed in some wine growing regions elsewhere.

 ¡Ay no: carne de caballo

Despite being one of the best known types of food fraud, we are still finding undeclared horse meat in beef, including recently in Mexico.  Horse meat is not illegal in Mexico, however it is not supposed to be present in beef meat.  A recent study found it at rates of around 10% of ‘beef’ products purchased from public markets, street stalls, butchers shops and taco stands.  Worse still, more than half of the meat samples that contained horse DNA also contained clenbuterol, an illegal growth enhancer.

US FDA: not loving love

The US FDA has ventured into philosophical territory by sending a pubic warning letter to the owners of a food manufacturer in Massachusetts for mis-branding their granola by declaring that it contains love.  According to the FDA, “Love is not a common or usual name of an ingredient, and is considered to be intervening material because it is not part of the common or usual name of the ingredient.” Oh FDA, you heart-breakers!

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Latest news in food fraud; tasty tapirs, ‘unripe’ honey and toxic eggs

Honey production increased by a phenomenal 88% in China between 2000 and 2014, despite an increase in the number of beehives by 21% during the same period.  This is said to be due to the harvesting of ‘unripe’ honey: the honey is removed from hives while still very watery, then it is artificially dried.   China is the world’s biggest honey producer and provides a significant proportion of Europe’s honey.

Meanwhile, a number of European countries have increased their honey exports at about the same rate as they have increased their imports from China, while there have been no increases in local production. It is alleged that the honey is being fraudulently re-labelled as European-grown honey when it originated in China. Read more about unripe honey and the European honey market here.

Contaminated eggs are being recalled and dumped by their millions in Europe and beyond

 

The biggest news in Europe in recent weeks has been the growing scandal around the discovery of a toxic pesticide in eggs.  The pesticide fipronil is commonly used to control lice and ticks on animals, however it is not allowed to be used in food production chains, including within poultry barns.  Eggs in more than 40 countries across Europe and beyond have been found to contain traces of the pesticide.  Millions of eggs have been recalled and dumped.  It is alleged that the source of the contamination can be traced back to a poultry barn cleaning company that used undeclared pesticide when treating barns in The Netherlands.  Two men from the company are being held on suspicion of endangering public health.  Read more about the egg scandal here.

Organic and eco-labelled foods are at very high risk of food fraud and as more cases of fraud in these sectors are uncovered there is a risk to consumer trust in sustainable foods according to Ecovia Intelligence.

Trust in sustainable foods is under threat from food fraud.

 

There has been depressing news from Canada this month, with undeclared meat species found in a wide selection of meat products.  Twenty percent of sampled products from the government-commissioned survey contained meat that wasn’t on the label, in quantities that could not be attributed to carry-over from product changeovers.  Seven of twenty seven beef sausages contained pork, one of thirty-eight pork sausages contained horse and one third of tested ‘turkey’ sausages contained nothing but chicken.

The citizens of Venezuela have been warned to be wary of meat from dubious sources, after zoo animals were stolen from Zulia Metropolitan Zoological Park in the city of Maracaibo. Ten species, including buffalo and tapirs, have gone missing from the zoo in recent weeks as the population suffers from serious food shortages.

Consumer trust in food producers and processed food is alarming low in the United Kingdom, reports NFU Mutual.  Almost three quarters of those surveyed believe food fraud is a widespread problem in the UK.

Want to learn more about food fraud?  Try our free training course.

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Trends and developments in food fraud 2017

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

Recent incidences of food fraud

 

Emerging trends in fraudulent activities

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

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

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

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

New responses to food fraud

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

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

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

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

Updates to food safety standards

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

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

GFSI standards have been updated to address hazards from food fraud

 

Regulatory changes

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

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