Food Defense - II

Adulteration

To further explain the potential public health threats from EMA, and to develop appropriate mitigation plan, it is important to discuss adulteration methods. There are 8 major adulteration types that are; dilution, substitution, artificial enhancement, mislabeling, trans-shipment and origin masking, counterfeiting, theft and resale, and intentional distribution of contaminated product. Dilution, substitution and artificial enhancement involve altering the food itself. The other five methods involve altering the exterior appearance, misrepresentation and/or violating commercial regulations. Following are method of adulterations with an example case available online.

Dilution

Dilution is achieved through the addition of a cheaper ingredient to increase the overall weight or volume of a product. For example, in the UK, curry sauces were found to contain peanuts, despite their claims of being peanut-free. Tests confirmed that more expensive almond powder, used as an ingredient in these sauces, was diluted with up to 50% of less expensive peanut powder. Three deaths linked to peanut allergies triggered the investigation.

Substitution

Substitution is the replacement of an authentic product with a fraudulent one. A common example is the substitution of lower quality fish for a premium species. Public health concerns come into play if a toxic fish species is surreptitiously substituted for another ingredient or a different fish. Two examples highlight the public health threat of substitution: 1) cheaper escolar, which can cause keriorrhea, a form of fish poisoning that causes oily diarrhea, has fraudulently been sold as tuna in restaurants in the United States; and 2) in the U.S., puffer fish has been substituted and labeled as monkfish, despite strict importation and sale restrictions. Improperly prepared puffer fish contains tetrodotoxin, which is potentially lethal at ingestion levels of less than 2 mg.

Artificial Enhancement

Artificial Enhancement enhances a product’s attributes by use of an unapproved additive. The most notorious case occurred in 2008 melamine was used to fraudulently boost the protein levels in diluted milk. Because melamine is high in nitrogen, adding it to milk makes it appear higher in protein and increases its value. The melamine adulteration of infant formula sickened thousands of infants in China and caused six deaths. Adulterated milk was also added to many different foods including baked products, chocolate and confections, and resulted in a massive recall spanning 47 countries. A more recent example occurred in 2015 when FDA India recovered 90 kg of rice granules, bran, lead chromate and Sudan dyes intended to be mixed with turmeric powder to increase the quantity and the color. Sudan dyes are known carcinogens and often used in industrial dyes and shoe polish. They are banned from being added to food products around the world. Lead chromate is also a carcinogen and known hazardous substance which can cause headaches, anemia, muscle cramps and brain damage. The factory where FDA India seized the products had been operating for 25 years without a license. As a result, it is unknown how long adulteration occurred.

Mislabeling

Mislabeling occurs when quality, harvesting, or processing techniques of a food product are misrepresented. Examples include selling a product as Kosher or Halal, organic or cage-free when it is not. Although these examples may not lead to public health harm, mislabeling involving food safety issues also occurs. For example, altering package expiration dates and reselling expired, mislabeled food creates public health risk. In 2010, a mislabeling EMA incident occurred when a shipment of imported, unpasteurized cheese was mislabeled as pasteurized. Because it had not been pasteurized, the cheese was contaminated with Staphylococcus aureus, which if ingested, can result in severe illness and even death. The mislabeling was detected and the importing company was ordered to destroy the cheese or send it back to its origin. However, the company tried to further defraud authorities by making a fake shipment of packages filled with waste water to imitate the weight of the cheese being returned.

Trans-shipment 

Transshipment moves goods through an intermediary country before shipping to its final destination thereby masking its true origin. Motivations that include differences in regulatory oversight, consumer perception and avoidance of tariffs lead to transshipment. Transshipment can be an in-country issue as well. For example, a food company specializing in shell eggs misled consumers into thinking its eggs originated from California, even though they came from other states. This misrepresentation could have caused significant public health harm, as consumers, believing their eggs were from California, would not have worried about a Salmonella outbreak in Idaho. Honey is often transshipped to avoid both tariffs and to mask the use of hive treatments allowed in the producing country but not allowed for public health reasons in the destination country.

Counterfeiting

Counterfeiting refers to the mimicking of one food by replicating it out of different ingredients which can be committed by fraudulently using a brand-name label on an inauthentic product, thus selling one product as a different—often more valuable—product. In 2005, for example, Turkish officials recalled millions of counterfeit raki bottles, a traditional anise-flavored distilled alcohol, after 23 deaths and numerous illnesses were reported. The counterfeit bottles contained over 200 times the legal limit of methyl alcohol. Approximately 500,000 genuine “Yeni Raki” brand labels, including the tax hologram, had been stolen from a bottling facility and then used to place counterfeit raki on the market.

Theft and Resale

This method comprises theft of food products and their resale through unapproved channels. In 2011 and 2012, approximately 6 million pounds of maple syrup, worth approximately $18 million, was stolen from the Global Strategic Maple Syrup Reserve in Quebec, Canada to be sold on the black market. The missing syrup was discovered as a result of a routine inventory check in July 2012. Only a quarter of the maple syrup was recovered. Public health concerns arise from theft and resale for a variety of reasons, as it is a loss of supply chain control. The perpetrator may insert a harmful adulterant, resell spoiled product with altered sell-by or expiration dates, or fail to maintain temperature control thus allowing microbial growth and toxin production.

Intentional Distribution of Contaminated Product 

Intentionally distributing a contaminated product is another form of EMA. The deliberate distribution of Salmonella-contaminated peanut products in 2008 and 2009 by the Peanut Corporation of America (PCA) is the prominent example. PCA shipped product before microbiological testing results had been received, and then did not notify customers or recall the products when these tests came back positive for Salmonella. In addition, many of the products were shipped with fake certificates of analysis. The incident resulted in Salmonella Typhimurium infections in 46 states and nine deaths. The U.S. Centers for Disease Control and Prevention estimated that as many as 20,000 people may have been sickened by the contaminated peanut products.

Food Defense and Food Safety

The food industry most commonly integrates a food defense into an existing food safety system of the company. Food defense involves documentation and written procedures of an already existing food safety system. This refers to the documentation of the food safety system, traceability, documentation and records of the management system, corrective and preventive measures, internal audits, employee training, etc. The GFSI food safety program covers most of FDA’s ‘‘Food Safety Modernization Act’’ (FSMA) requirements but the issue of the program’s intentional adulteration still needs to be addressed. The concepts are very similar whereby the threat and vulnerability of the systems and facilities must be evaluated using the HACCP concepts in order to guard against intentional adulteration.

The GFSI has defined the following two concepts: VACCP (vulnerability/food fraud) and TACCP (threat/food defense). The GFSI has defined the Food Safety Management as an ‘‘umbrella’’ that includes HACCP (hazard/Food Safety), TACCP (threat/Food Defense) and VACCP (vulnerability/Food Fraud). These three separate scopes should be addressed individually. From the perspective of food companies, the main initiators of the food defense implementation are the retail chains; who compliance the producer’s certifications in accordance with one of the system standards in food safety. The same conditions also apply in case of a cooperation between various business partners who participate in the food supply chain, such as retail chains, outsourcing or logistics services. Standards supported by the GFSI Initiative are the prerequisite for business cooperation. These include globally recognized certification schemes such as IFS, BRC, SQF, HACCP, GLOBAL GAP, FSSC 22000, NSF, etc.

Food defense is a concern in almost all business areas in the food industry, where intentional contamination and food fraud can pose a serious threat to the consumers’ and public health as well as damage company business (BSI 2014). The food industry implements food defense mainly in agricultural production, processing, storage and transport, wholesale and retail distribution and tracing systems and recalls (traceability being one of the obligatory requirements). Depending on the size of a food company, food defense can be implemented on the level of its management, human resources, purchasing department, receipt and storage of raw materials, production, quality control, packaging and labelling, storage of finished products, transport and distribution (BSI 2014; USDA 2014). Regardless of the food safety standards, they all imply that it is necessary to implement corrective measures in accordance with the assessments of related risks. If a food company has partnership agreements or exports products to certain countries, it is obliged to apply the requirements for food defense defined by the food safety standards and the legislation of certain countries.

Food Defense

What is Food Defense? 

Food defense is executing measures in place that will reduce the chances of the food supply from becoming intentionally contaminated using a variety of chemicals, biological agents or other harmful substances by people who want to harm others, where such agents could include materials that are not naturally-occurring or substances not routinely tested for in food products. A terrorist’s goal might be to kill people, disrupt any country’s economy, or ruin someone’s business. Intentional acts generally occur infrequently, can be difficult to detect, and are hard to predict. There are four types of food protection risks that include food safety, which is based on unintentional or environmental contamination that can cause harm; food fraud, which is based on intentional deception for economic gain; and food quality, which may also be affected by profit-driven behaviour but without intention to cause harm. There are three types of food defense events that can happen in an unfortunate place which could be carried out by a disgruntled employee, sophisticated insider, or intelligent adversary with a specific goal in mind. This goal in return may be to impact the public, brand, company or the psycho-social stability of a group of people depending on the type. However an event may contain aspects of more than one category.

However, Food defense is not same as food safety, since food safety addresses the accidental contamination of food products during storage and transportation which focuses on biological, chemical or physical hazards. The main types of food safety hazards are microbes, chemicals and foreign objects. Products can become contaminated through negligence and contamination can occur during storage and transportation. 

What is the relationship between Food Defense, Food Safety, and Food Security?

In order to prevent, protect against, mitigate, respond to, and recover from threats and hazards of greatest risk to the food supply, it is important that preparedness efforts encompass food safety, food defense, and food security. While there are distinct differences between these three concepts, a comprehensive approach that addresses food safety, food defense, and food security considerations improves resilience and protects public health.

Food Defense - the protection of food products from contamination or adulteration intended to cause public health harm or economic disruption which can be further explained as procedures adopted to assure the security of food and drink and their supply chains from malicious and ideologically motivated attack leading to contamination or supply disruption.

Food Safety - the protection of food products from unintentional contamination.

Food Security - when all people, at all times, have both physical, social, and economic access to sufficient, safe, and nutritious food to meet their dietary needs and food preferences for an active and healthy life (Food and Agriculture Organization, 2014). The term technically refers to the confidence with which communities see food being available to them in the future except in the limited sense that a successful attack may affect the availability of food.

Food protection – it is the umbrella term encompassing both food defense and food safety. Along with protecting the food system, food defense also deals with prevention, protection, mitigation, response and recovery from intentional acts of adulteration. Food defense is the protection of food products from contamination or adulteration intended to cause public health harm or economic disruption.

Types of Threats

Considering the protection of food from deliberate misuse to risk human health, following threats are considered as most common types which are further segregated to understand them before act on them. The safety of the food are at risk at more than ever due to the globalization and development of communication technologies.

Food Fraud

Food fraud committed when food is deliberately placed on the market, for financial gain, with the intention of deceiving the consumer. Although there are many kinds of food fraud the two main types are:  

The sale of food which is unfit and potentially harmful, such as recycling of animal by-products back into the food chain; packing and selling of beef and poultry with an unknown origin; knowingly selling goods which are past their ‘use by’ date.

The deliberate misdescription of food, such as products substituted with a cheaper alternative, for example, farmed salmon sold as wild, and Basmati rice adulterated with cheaper varieties; making false statements about the source of ingredients, i.e. their geographic, plant or animal origin.

Food fraud may also involve the sale of meat from animals that have been stolen and/or illegally slaughtered, as well as wild game animals like deer that may have been poached.

Industrial Sabotage

These events include intentional contamination by a disgruntled employee, insider (Individual within or associated with an organization and with access to its assets but who may misuse that access and present a threat to its operations) or competitor with the intention of damaging the brand of the company, causing financial problems from a widespread recall or sabotage, but not necessarily with the goal of causing widespread illness or public harm. These internal actors often know what procedures are followed in the plant, and how to bypass checkpoints and security controls.

Terrorism

The reach and complexity of the food system has caused concern for its potential as a terrorist target, i.e. the first and largest food attack in the US is the 1984 Rajneeshee bioterror attack.

Economically Motivated Adulteration (EMA)

The motivation of EMA is financial, to gain an increased income from selling a foodstuff in a way which deceives customers and consumers. This may be by either passing off a cheaper material as a more expensive one, or it may be that a less expensive ingredient is used to replace or extend the more expensive one. The avoidance of loss may also be an incentive for adulteration. Limited supply of a key material may encourage a producer to improvise to complete an order rather than declare short delivery to the customer. The intention of EMA is not to cause illness or death, but that may be the result. This was the case in 2008 when melamine was used as a nitrogen source to fraudulently increase the measured protein content of milk, resulting in more than 50,000 babies hospitalized and six deaths after having consumed contaminated infant formula.

The common factor in many cases of EMA is that the adulterant is neither a food safety hazard, nor readily identified, as this would defeat the aim of the attacker. Common adulterants include water and sugar; ingredients that may be properly used and declared but improper use is food fraud. EMA is likely to be more effective for an attacker, and therefore present a greater threat to a food business, upstream on the food supply chain close to manufacture of primary ingredients. A successful adulteration (from the point of view of the attacker) continues without detection. EMA may need an insider but could be revealed by audit, for example: from purchases which are unexplained by recipes, such as sudan dyes which have no place in spice manufacture; or where there are differences between quantities sold and quantities purchased, such as beef mince sold and bovine meat purchased, with horsemeat to make up the difference.

Malicious Contamination

Materials which could be used by an attacker to gain publicity, or to extort money, are more readily found than those needed to cause widespread harm. In 2007, a bakery found piles of peanuts in the factory, where the company withdrew product and closed for a week long deep clean to re-establish its nut-free status. The case of allergens shows the harm, impact and cost that can be caused to a business with little risk to the attacker. Contamination close to point of consumption or sale, as it is more likely to cause harm to health than an attack on crops or primary ingredients.

Extortion

The motivation for extortion by either an individual or group is financial, to obtain money from the victim organization. Such activity is attractive to the criminal mind when the product like baby food, which is sensitive or where a company is seen as rich. A small number of samples can be used to show the company that the attacker has the capability and is enough to cause public concern and media interest.

Espionage

The primary motivation of espionage is for competitors seeking commercial advantage to access intellectual property. They may infiltrate using insiders to report, or may attack remotely through information technology systems. Alternatively, organizations may try to entice executives to reveal confidential information or use covert recording to capture such material, or they may simply steal the material.

Counterfeiting

The motivation for counterfeiting is financial gain, by fraudulently passing off inferior goods as established and reputable brands. Both organized and petty crime can cause companies financial loss and harm to their reputation. The former, for example, can use sophisticated printing technologies to produce product labels that are indistinguishable from the genuine ones. The latter can steal genuine packs or even refill single use containers for resale. Organized criminals may try to mimic the food contents closely to delay detection and investigation. Petty criminals may be tempted by a ‘quick killing’ and be less concerned about the safety of the food.

Cyber Crime

Modern information and communications technologies provide new opportunities for malpractice. In the UK for the year to February 2013, Action Fraud received 58 662 cyber-enabled frauds and 9 898 computer misuse crime reports representing 41% of all of its reports, with an average loss of £ 3,689.16. It is common for the attacker to try and exploit individual ignorance of the technologies involved. Identity theft is perhaps more familiar to the public, but organizations may be aware of their identity being stolen to enable procurement fraud, in which goods are ordered in their name but diverted to the fraudsters premises leaving it to carry the cost and litigation.