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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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Supplements, the last frontier?

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

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

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

 

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Authentic glaze, fake ice and false positives

It’s not exactly food fraud, in fact, it’s a fabulous case of mistaken identity for a genuine American delicacy; Krispy Kreme donuts.  These tasty treats caused plenty of trouble for Florida man Daniel Rushing after a police officer discovered flakes of donut glaze on the floor of his car after pulling him over for a minor traffic offence.  Unfortunately, the officer mistook the pieces of glaze for crystal meth.

The Orlando Sentinel reports that Rushing man spent ten hours in jail after the officer performed two roadside drug tests on the sugary substances, which returned positive results for methamphetamine.  A state drug lab has since confirmed that it was a case of mistaken identity.  Rushing reported that although he had nothing to hide, he would “never let anyone search my car again”.

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Vulnerability assessments are a waste of time according to this investigator

Vulnerability assessments are a hot topic in food safety at the moment, with Global Food Safety Initiative (GFSI) food safety standards set to include requirements for documented food fraud vulnerability assessments in the near future.  Most food safety and food integrity experts believe that vulnerability assessments are an important first step towards preventing fraudulent foods from reaching consumers.   However, in an interview with Food Safety News, Mitchell Weinberg, food fraud investigator and CEO of Inscatech describes food fraud vulnerability assessments as “frankly… a little bit of a waste of time.”  Mr Weinberg says that a food fraud vulnerability assessment is essentially about recording what you already know.  He explains that if a business is sourcing a food ingredient from a developing country, they should already know that it is more likely to be affected by fraud than if sourced locally.  Likewise, high value and high volume materials are more attractive to fraudsters.  Weinberg tells the interviewer:

“Just use common sense, figure out where the problem is, check it out… trust but verify.“

Weinberg is right; creating documented risk assessments of any kind is simply an exercise in writing down what we already know.  And common sense should be at the core of any risk assessment.  So is there any value in a documented vulnerability assessment?  

Absolutely!

  • A documented assessment is a record of who thought of what and when they thought of it.  It is evidence that fraud has been considered; it can be used to check that common sense was used in that consideration.  It can be audited, reviewed and updated.  It can be shared.
  • The process of creating a documented assessment can serve as a prompt to identify gaps in knowledge and provide an incentive to ‘fill in the gaps’.
  • A documented vulnerability assessment can be used to transfer knowledge.  Weinberg says creating a written assessment is making a record of what you already know; that is exactly what is needed when the person who made the assessment changes jobs or has to explain supply chain risks to a stubborn Purchasing Manager.
  • Most food businesses manufacture hundreds of food products and many more hundreds of ingredients; comparing the vulnerability assessments of different products and materials is an effective way to prioritise fraud prevention actions.  While the ultimate aim is for no product to be compromised ever, we all have to start somewhere.

Read more about Vulnerability Assessments here.

To view the interview with Mitchell Weinberg, click here.