food fraud - amazon s32019/... · agro-food industry facing the challenges of food fraud • 77% of...

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/

keverstine@Decernis.com@Decernis

@crediblechow

decernis.comfoodfraud.org

Thank you