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.