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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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Five things every food safety professional should know about food fraud

1. Food fraud is in the spotlight

Food fraud has been around for thousands of years but has become more prominent in the food safety and food certification industry in the last few years, following the European horse meat scandal of 2013.  Although no food safety problems arose during that incident, it was realised that similar incidences could have serious impacts on food safety.  For that reason, food fraud prevention requirements were introduced into all major food safety management system standards between 2017 and 2020.

2. New terminology

Definitions related to food fraud and food integrity have been refined in the last five years and there is now consensus on the four key terms below, although the term food security still causes confusion.

food fraud,defense,safety,security

  • Food safety relates to issues of unintentional contamination, with the aim of reducing exposure to naturally occurring hazards, errors and failures in food systems.
  • Food fraud was defined by  Spink and Moyer (2011) as “a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product for economic gain.”  More recently that definition has been updated to capture all types of food crime: Food fraud is deception, using food, for economic gain (Food Fraud Initiative, Michigan State University).  Within food fraud there are types of fraud that involve tampering with the food by adulterating or diluting the food.  This type of fraud is sometimes called ‘economically motivated adulteration’ (EMA).  Other types of fraud that do not involve adulteration are also deemed to be ‘food fraud’.  These include black market and grey market sales, theft, illegal importing, avoidance of tax and counterfeiting.
  • Food defence 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 is unrelated to food fraud but is instead an issue of food supply and food access for populations who are under threat from food shortages.

Other terms to know:

  • Vulnerability assessments are assessments of vulnerability to food fraud, either at the raw material, product or facility level.  Within the USA the term vulnerability assessment can also refer to a food facility’s vulnerability to malicious tampering of product on its site, either by its own employees or external forces.   Learn more about vulnerability assessments.
  • Horizon scanning is the act of looking for and analysing threats and opportunities that will emerge in the medium to long term.  Within the food industry, horizon scanning means the act of collecting information about current trends and predicted incidences that could increase the likelihood of food fraud for a particular food material.  For example, climate change is likely to reduce coffee production which could drive up prices and increase fraudulent activity in that sector.
Coffee,authentic,fraud,horizon scanning
Coffee harvests are being affected by climate change

 

3. Food safety standards have become more rigorous

Food fraud prevention and mitigation measures are now a requirement of all major food safety management system standards.  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 include BRC, FSSC 22000 and SQF.  Between 2015 and 2017, all GFSI food safety standards were updated to include requirements for food companies to perform a food fraud vulnerability assessment and have a food fraud mitigation plan in place.   Click here for the GFSI Food Fraud Position Paper.

The new requirements for vulnerability assessments and mitigation plans require more resources for most food businesses, particularly those with large numbers of raw materials and suppliers.

4. There are new regulatory requirements for food businesses

The Food Safety Modernization Act (FSMA) in the USA has been implemented for most food businesses in the previous few years.  Within the FSMA rules, food businesses are required to address hazards from adulterants introduced for the purposes of economic gain.  These must be included in food safety hazard analyses and if hazards are found, preventive controls must be implemented.  This means that economically motivated adulteration (EMA), a subset of food fraud, must be addressed under the new FSMA rules.

The Food Safety Modernization Act (FSMA) also includes specific requirements for ‘food defense’ which are aimed at preventing malicious adulteration and tampering as well as fraudulent adulteration.  This is known as the Intentional Adulteration (IA) rule.  The IA rule is being progressively implemented in the USA.  FSMA rules for IA will also be enforced internationally for all food facilities that manufacture food for export to America.  Click here for US FDA’s food defense guidance

food defense,vulnerability assessment,FSMA,
All American food companies will be required to have a food defense plan

 

5.  Detection of food fraud remains a challenge, despite new lab techniques

Our ability to detect food fraud has improved over the last few years, but challenges remain.  There are many technologies available, from traditional ‘wet’ chemical tests to spectroscopy and chromatography to modern forensic DNA methods.   Protein isoelectrofocusing (a type of electrophoresis) is a conventional test that provides information about the source of various milk proteins in a cheese and can be used to detect cows milk in “buffalo milk” mozzarella, for example.  PCR (polymerase chain reaction) techniques, in which a cow milk-specific gene is amplified and detected are being developed for cheese testing and they are claimed to be more specific.

Coffee variety testing has traditionally been done using Fourier transform infrared spectroscopy, a method that exploits the different amounts of chlorogenic acid and caffeine in robusta and arabica varieties.  However, a new method that exploits the different mitochondrial genetic markers in the two varieties will soon be able to achieve the same results quickly and easily in the field with ‘lab on a chip’ technology.

Researchers looking for fraudulent aloe vera can exploit its distinctive NMR (nuclear magnetic resonance) profile, due to the position of acetate groups within a key polysaccharide in the plant.  The NMR profile represents a ‘fingerprint’ for aloe vera.

Another type of ‘fingerprinting’ is based on the spectra created by different ratios of stable isotopes.  For example, it is possible to tell the difference between corn-fed and wheat-fed chicken, using stable isotope ratio mass spectrometry by comparison with databases of reference samples.  This method has also been used to check provenance claims for meat and wine products.

Authentic beef mince
What meat is that?

 

Despite the surge in technology surrounding food fraud detection, it remains difficult to detect fraudulent adulteration unless you know what you are looking for.  As an example, DNA testing can be used to determine if beef mince has been made from a cow but can’t tell me whether it has been adulterated with undeclared beef offal.  Olive oil that is suspected of having been adulterated with other edible oil can easily be tested for such adulteration in a lab test, but verifying its country of origin is more difficult.  Adulteration of ‘arabica’ coffee with the cheaper robusta variety can be detected with a simple test but that same test will not disclose whether ground coffee has been adulterated with cheaper fillers such as corn, soybean or wheat, a practice which is common in some markets.  There are now a number of ‘fingerprinting’ techniques that are designed to ‘flag’ any sample that is not authentic, no matter what the adulterant, however they can only be used if there is already an extensive database of authentic samples with which to compare the suspect sample.  Australian honey brand owners who were caught with supposedly inauthentic honey in an NMR-based fingerprint test claimed that the database used in the testing, which was done in Germany, was not suitable for testing Australian honeys.  Read more about the Australian honey scandal.

We have a lot of tools in our arsenal to answer questions about fraudulent food but those tools are only useful if we ask the right questions.

Need to learn more?  Want practical advice from expert food scientists? Click here for a free introductory consultation.