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Food FraudKaren Everstine, PhD MPH
Senior Manager, Scientific AffairsDecernis, LLCRockville, MD
Outline
• Background and context• Food fraud incident examples and lessons learned• Food Fraud Database project• Future trends• Where do we go from here?
Salmonella Wandsworth outbreak in Veggie Booty (2007)
(Photo source: wayfaringchocolate.com)
Food protection
Source: GFSI
Recent (mostly) incidents and lessons learned
Recent (mostly) incidents and lessons learned
Recent (mostly) incidents and lessons learned
Recent (mostly) incidents and lessons learned
Recent (mostly) incidents and lessons learned
Recent (mostly) incidents and lessons learned
FDA FSMA requirements
“The hazard analysis must consider hazards that may be present in thefood because they occur naturally, are unintentionally introduced, or areintentionally introduced for purposes of economic gain."
"We continue to believe that hazards that may be intentionally introducedfor economic gain will need preventive controls in rare circumstances,usually in cases where there has been a pattern of economicallymotivated adulteration in the past."
Federal Register Volume 80, Number 180 (Thursday, September 17, 2015)Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food; Final Rule
What is adulterated food?A food shall be deemed to be adulterated—
(a)POISONOUS, INSANITARY, ETC., INGREDIENTS
…
(b)ABSENCE, SUBSTITUTION, OR ADDITION OF CONSTITUENTS
(1)If any valuable constituent has been in whole or in part omitted or abstracted therefrom; or
(2) if any substance has been substituted wholly or in part therefor; or (3) if damage or inferiority has been concealed in any manner; or (4) if any substance has been added thereto or mixed or packed therewith so as to increase its bulk or weight, or reduce its quality or strength, or make it appear better or of greater value than it is.
21 CFR § 342
GFSI food fraud requirements
“…any plans and activities to mitigate, prevent or even understand the risks associated with food fraud should consider an entire company’s activities, including some that may not be within the traditional food safety or even HACCP scope, applying methods closer to criminal investigation.”
“GFSI is aware that the harmonization and best practices are just now being developed and refined. A new system that is less than a year old in implementation cannot be expected to be as robust, thorough, or detailed as a system such as HACCP that has been implemented for more than 25 years. The most important step for the food industry is to start addressing food fraud, and for auditors to start asking the basic questions on how vulnerabilities were assessed and identified, and a strong mitigation plan thought through.
Source: http://www.mygfsi.com/files/Technical_Documents/BR_V7.2/Benchmarking_Requirements_v7-2_Part4.pdf
GFSI: Tackling Food Fraud Through Food Safety Management Systems
Decernis
The Food Fraud Database
The Food Fraud Database
Dashboard
Faceted Search
Data Analytics
Hazard Identification
Report Generator
Global distribution of food fraud incidents
How does fraud happen?
How does fraud happen?
How does fraud happen?
How does fraud happen?
How does fraud happen?
How does fraud happen?
The Food Fraud Database
Data current as of 3/28/19
3,419REFERENCES
37INGREDIENT
GROUPS
4,404FOOD
INGREDIENTS
1,723ADULTERANTS
9,485ADULTERATION
RECORDS1,607 scholarly1,569 media
128 regulatory63 judicial
…
1,262 incident3,227 inference648 surveillance4,348 method
Top Ingredients
0 50 100 150 200 250
Coffee (Arabica)
Virgin Olive Oil
Chili Powder
Orange Juice
Milk Powder
Olive Oil
Beef Meat
Honey
Extra Virgin Olive Oil
Milk (Fluid, Cow)
No. Records
DISCLAIMER
Top Ingredient Groups
0 100 200 300 400 500 600
Beverages (Non-Alcoholic)
Vegetable Oils
Beverages (Alcoholic)
Honey
Herbs/Spices/Seasonings
Olive Oil
Milk/Cream
Meat/Poultry
Seafood
Dairy Ingredients
No. Records
DISCLAIMER
How does fraud happen?
0 100 200 300 400 500 600 700 800
Artificial enhancement (other)
Use of unapproved biocides
Other
Dilution/Substitution (varietal origin)
Dilution/Substitution (geographic origin)
Fraudulent labeling claims
Artificial enhancement (unapproved color)
Artificial enhancement (apparent protein)
Dilution/Substitution (substance not approved for use in food)
Dilution/Substitution (animal origin)
Dilution/Substitution (botanical origin)
Dilution/Substitution (other)
Potentially Hazardous Adulterants
Illness or deathsSafety-related
regulatory action/allergen
Potential to cause illness
Lack of safety information
Permitted in certain regions or
excipients
May, by law, be used in foods
Foods or food ingredients
Potentially hazardous
Unlikely to be hazardous
Source: Everstine, K., E. Abt, D. McColl, B. Popping, S. Morrison-Rowe, R.W. Lane, J. Scimeca, C. Winter, A. Ebert, J.C. Moore, and H.B. Chin. Development of a Hazard Classification Scheme for Substances Used in the Fraudulent Adulteration of Foods. J. Food Prot. 2018 Jan; 81(1):31-36.
47% of records associated with a potentially hazardous adulterant (N=3939)
Spices
• High value• Long, complex supply chains• Shelf-stable• Physical form – ground• Quality attributes (color)
Everstine, K. Supply Chain Complexity and Economically Motivated Adulteration. In: Food Protection and Security - Preventing and Mitigating Contamination during Food Processing and Production. Shaun Kennedy (Ed.) Woodhead Publishing: 26th October 2016.
Spices
Courtesy: Tom Tarantelli, Retired (New York State Department of Agriculture & Markets Food Laboratory)
Spices
Courtesy: Tom Tarantelli, Retired (New York State Department of Agriculture & Markets Food Laboratory)
Spices
Courtesy: Tom Tarantelli, Retired (New York State Department of Agriculture & Markets Food Laboratory)
Spices
“…turmeric containing excessive concentrations of lead is available for purchase in US grocery stores and that childhood lead-poisoning cases attributable to consumption of contaminated turmeric have occurred in the United States.”
Food fraud mitigation
“Universe”of ingredients
Ingredients withpotential
vulnerability
Ingredients withgreatest
vulnerability
“Short list” of ingredients
Food fraud mitigation
Source: USP Food Fraud Mitigation Guidance
Pan-Canadian Survey on Perceptions and Concerns of the Agro-Food Industry Facing the Challenges of Food Fraud
• 77% of survey respondents indicated the frequency with which food fraud detection technologies are implemented as “never to rarely”
• 88% of respondents rated their level of knowledge in food fraud detection technologies as moderate or low
• 72% currently implement a supply chain traceability system to address food fraud
https://www.cirano.qc.ca/en/summaries/2018RP-22
Future trends
• Food fraud is rarely novel• Trends in eating among millennials*
• Sustainability• Convenience• High Protein• Organic, “Local”
*Source: https://www.washingtonpost.com/lifestyle/wellness/9-ways-millennials-are-changing-the-way-we-eat/2018/02/20/6bb2fe60-11eb-11e8-8ea1-c1d91fcec3fe_story.html?utm_term=.a6620c91bbf7
Where do we go from here?
Horizon scanning
Blockchain
Artificial intelligence
Nontargetedmethods
Resources• Decernis Food Fraud Database: https://foodfraud.org/
• SSAFE/PwC Food Fraud Tool: https://www.pwc.nl/en/industries/agrifood/ssafe-food-fraud-tool.html
• USP Food Fraud Mitigation Guidance: https://www.usp.org/ffmg-form
• Food Fraud Advisors: https://www.foodfraudadvisors.com/
• Michigan State Food Fraud Initiative Online Courses: http://foodfraud.msu.edu
Consumers
“Authentic food is a social good that benefits consumers. Ensuring that the food supply is authentic is good governance. The pursuit of a food system that is authentic, as well as healthy and sustainable, should and can be achieved...”
Roberts, Michael T. and W. Turk. White Paper: The Pursuit of Food Authenticity – Recommended Legal & Policy Strategies to Eradicate Economically Motivated Adulteration (Food Fraud). 2017. Available at: https://law.ucla.edu/centers/social-policy/resnick-program-for-food-law-and-policy/publications/food-fraud-white-paper/