(FSMA: Protection Against Intentional Adulteration)
In keeping up the same theme as my last couple of blogs, I wanted to talk about another upcoming FSMA rule—focused mitigation strategies to protect against intentional adulteration. A very common example of intentional adulteration is food fraud. This proposed rule (which is in its final development stages) will require that both domestic and foreign facilities address vulnerable processes in their operations to prevent harmful acts to the supply chain. In other words, a food safety system will need to address intentional hazards from sources such as bioterrorism, acts by disgruntled employees, consumers, competitors and organizations or people out for economic gain.
You may be wondering, what exactly does food fraud entail? There are a number of definitions to be found out there but it really comes down to the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging. It can include false or misleading statements about a product for economic gain. Most food fraud that we see tends to be relatively harmless from a human health aspect—like the horsemeat scandal or cutting extra virgin olive oil with other cheaper oils. However, some have proven deadly, like melamine added to milk to boost the apparent protein content and adulterated liquor incidents.
Here are the most common foods associated with food fraud:
- Olive Oil: the most adulterated food – found to be cut by hazelnut oil usually, but could also include other oils (corn, sunflower, peanut, vegetable, soy, palm or walnut)
- Milk: sometimes found to include milk from a different animal than listed (i.e. sheep’s milk found in cow’s milk) or adulterated with other materials (oil, urea, detergent, caustic soda, sugar, salt, milk powder)
- Honey: could also include sugar or corn syrup, fructose, glucose, HFCS, beet sugar, or even be laced with illegal Chinese antibiotics or heavy metals
- Spices (saffron, black pepper): various spices has been found to be cut with both natural and artificial/chemical additives, including sawdust
- Juices (apple, orange): has been found to contain illegal fungicides, and sometimes other unlisted juices and sweeteners/colorants
- Brewed Beverages (coffee, tea): sometimes found with different grains (corn, barley, cereals), ground parchment, starch, malt and even figs
- Fish: most examples included intentionally mislabeling fish as a different species
So as a member of the food industry, you may now want to understand what you can do to help prevent or mitigate food fraud, or other intentional adulteration activities.
Food Defense Plan
You need to start by implementing a comprehensive food defense plan. The FDA has provided specific steps which you can take to ensure risk from intentional adulteration is identified, assessed and addressed. As you may note from the figure below, the steps are quite similar to other risk/hazard analysis and control plans.
Listen to my podcast for more details on how to build an effective food defense plan:
(Or listen to the podcast here)
Food Fraud Exchange
If data is king and communication is key then it is becomes apparent that sharing food fraud and other intentional adulteration events with industry and regulatory partners is vital. By communicating and collaborating with everyone that can be affected by food fraud, you are providing valuable information to help others avoid similar situations.
- Detection: identify potential sources/hazards, monitor your control and test measures, and identify acts of intentional adulteration
- Reporting: it is important that you report any suspicious or confirmed food fraud activity in order for the proper authorities to investigate and take action against anyone engaged in such practices.
- US Pharmcopeial Convention: a searchable online database developed by USP as a repository for food ingredient fraud reports and associated analytical detection methods.
- Food Standards Agency: Food Fraud Branch—UK food fraud database (firstname.lastname@example.org)
- Collaboration: it is critical that we view food fraud as an industry-wide problem and we make every effort to share any food fraud experiences with others in the Food and Beverage industry. Reporting through a food fraud database is just one way to share. You should also be engaging with your network at conferences, through industry associations and with your local regulatory agencies.
Supply Chain Management
Lastly, managing your external partners and any incoming raw material will be key to ensuring that adulterated products are caught prior to entering your supply chain cycle. Look at your entire supply chain from farm to fork to ensure that all steps along the way have been assessed for hazards related to intentional adulteration.
In summary, as our food supply continues to become more complex and global, we need to look beyond the traditional risks and hazards to how someone can intentionally engage in harmful food safety practices. We need to include vulnerability assessments when managing risk throughout the supply chain.
For more information on this topic, please listen to the podcast where we will talk more about the Food Defense Plan. Check out our webinar on Dec 2, 2015: FSMA Is Upon Us: How to Prepare for the FSVP Rule.