Food Fraud: Risks, Threats & Vulnerabilities
The Food Safety Conference 2016 was held at the Museum of London Docklands, which was a great location in an interesting part of London near to Canary Wharf and Canada Square. The event is described as a one-day, industry-led conference and networking event with over 120 delegates and promotors of food safety services attending. The break-out room for the promoting businesses was well suited for the purpose and a plentiful supply of refreshments was available. Here’s our roundup of the speakers we heard during the day…
Panel Session: Horizon Scanning & Industry Trends…
Scrutinizing emerging trends in recalls and outbreaks, and scanning the horizon to anticipate the next big issues to threaten our industry.
John Carter – Vice President of Quality & Sustainable Dairy – Worked at Kraft from 1988 to 2012 and was involved in the Cadbury integration, he has worked at Macro and is now working for Danone where he has been in post for the last 6 months.
John believes that the biggest challenge in the industry is changing culture and thinks the best way of making changes are:
- Engaging the entire company – gaining that senior management commitment
- General management engagement in each site
- No use of negative associative words in quality – they need to have that positive aspect
He stated, there needs to be that understanding of why culture change needs to happen. The changes need to make sense to all personnel at all levels of the business, and if there is any reasonable doubt or judgement of the change, then people should feel comfortable and be encouraged to be asking why the changes are being made, this is to ensure that the change is right. No corners should be cut on ensuring the compliance to the specification is 100%.
Nikos Mavroudis – Food Engineering & Separation of Actives, FoESA Lab, Department of Applied Sciences, Northumbria University – previously worked at Unilever in NPD of the chilled section for 10 years. He has been in his current post for 6 years.
When asked about culture change; Nikos stated that he thought, within the industry it is easier to engage the senior and even middle managers – it is the rest of the operation which is difficult. This is very often due to the cost to the business, but that although this is no excuse – the question of food safety should be non-negotiable. Price is always driven down by the buyers, which influences what can be spent on site.
The discussion then moved to food safety issues in raw materials which arrive at site. Food can be rejected at receipt by the manufacturer; but the big question is then, where does it go from there? It should go back to the supplier and be put to waste, but more often than not, it is put back into the food chain and sold elsewhere. The only time it is stopped is if it is tested by the site. An example of this is grain, which has had some recent legislation changes in 2015, however it may still remain in stock to be sold. So unless detected by the buying manufacturer, it could go unnoticed – even if that supplier is now producing grain within the new legislation guidelines.
Other upcoming risks are identified as food contact packaging, as tests are not always completed for altered environments of the products they are going to contain – such as low temperatures and increased moisture. It was felt that due to the suppliers not understanding the legislation and migration factors is the cause of this. Nikos believes that more stringent tests will happen as they are already known to be able to be performed, however, it is unknown whether these will trigger the legislation to change, but believes that the tests needed should have these tighter parameters.
Another emerging risk stated at the end of the session was Glyphosate, however I am unfamiliar with what this is and no explanation was given at the time – one to look up! http://www.glyphosate.eu/glyphosate-basics/what-glyphosate
One thing mentioned at the end of this panel session was that retailer reputation impact increased massively after 2013’s horsegate. The retailer’s reaction was to become more demanding with their standards and audits which has become prevalent in the industry as retailers are the businesses impacted the most when scandals like this happen, however it is the manufacturers who have to react and make those changes.
Throughout the day, the following speakers from various well-respected food manufacturing businesses and other food industry-related service suppliers gave their own experiences and insights into the risks, threat and vulnerabilities they have dealt with as well as what they think needs to be happening…There’s a lot to get through here but the stories are worth reading.
Paul Usherwood – Head of Quality & Technical at SHS drinks division – namely WKD, Shloer, Bottlegreen Cordial and Merrydown Cider which we have all heard of and maybe had a sip of one or two. For Paul the biggest risk in his business is glass, as obviously some of the drinks are in glass bottles…
In Paul’s opinion, food fraud has been growing, as I am sure we all agree! He defined food fraud as ‘an intentional act of intentional or unintentional harm’, whereas, an accidental manufacturing error causing a food safety issue is more ‘an unintentional act of unintentional harm’.
An interesting fact for the day which was raised more than once by Paul and also Mike Bromley from Genon Laboratories, is that in fact, Frederick Accum produced a publication called ‘Culinary Poisons’ in 1820, the contents of which was all about the adulteration of food. You can see the extract of this text here: https://library.missouri.edu/exhibits/food/accum.html
So this shows, food fraud is not something new, its been around for a while, but it only seems to have triggered us to take action since the horsegate incident. However, action is being taken by retailers and BRC version 7 was also issued in July 2015 including a new section (5.4) on raw material threat and vulnerability, which meant systems must be implemented to prevent food fraud.
In the drinks industry you can see some changes happening to the way the bottles are being sealed to prevent adulteration or dilution. New style bottle seals such as foil caps and label seals are now being used. However, this is a costly change for those manufacturers.
Paul then spoke about how it is necessary to have visibility throughout the whole supply chain which was echoed by many speakers throughout the day, from primary production to consumption the visibility should be clear at all points. Implementation of a system he believes, should be centralised for all sites with clear visibility of the supply chain mapping.
Another interesting fact I learned was that the food and beverage industry is actually the second most trusted industry, the first being technology.
Andy Moorling – Head of Food Crime at the National Food Crime Unit of the FSA – Food Standards Agency…
Andy’s definition of food fraud – was ‘Serious dishonesty that impacts detrimentally on either the safety or authenticity of food’.
His view was that perhaps there is not so much organised crime as first thought, more often than not, it is good businesses going bad. And why does this happen? Cost. A lot of the time it is due to the costs being driven down, or an easier way of doing something to cut costs and once one small step is made on the wrong path of food fraud, the next time it becomes easier and then easier again.
Why has it happened? Andy believes that the punishment has not been set at a high enough bar – if offenders were dealt with at a more serious level, then it may have a preventive response. However, we are moving onto heavier sentences and hefty fines, which when published, becomes a greater fear for those offenders. After all, it is fraud.
Andy explained the type of food fraud offenders. The largest group is in the category called ‘regulatory non-compliance’, which are those not intending fraud, it happens meaning non-compliance to specification. Then the food fraudsters themselves, then food crime, then organised crime groups. Who are these people? They were described to us as one of the following:
- The controlling mind of the business – senior management
- An insider
- Noble cause actor – thinks they are doing the right thing to get the job done
- External actor – such as logistics, storage and distribution
- Criminally minded
Andy went on to tell us all about a Food Crime confidential hotline that has been set up for the industry with contact details as follows: Call 0207 276 8787 or email email@example.com This is for anyone who feels they want to report suspicion of food fraud within their supply chain and then action can be taken which is confidential.
Mike Bromley from Geno Laboratories, his talk was on Metagenomics for food safety…
Mike gave examples of many of the adulterations that have been made in the industry so far – one being durum wheat in pasta, which 65.4% was not found in the pasta when labelled on pack. Other high ranking adulterations were coffee, tea with bamboo which was found to have dianthus chinesis which can be very harmful, oregano and also fish which came up a lot during the day. In fact, 15% to 30% of fish is not as it is described.
He stated that it costs a great deal to enforce new parameters for checking raw materials when arriving at your manufacturing sites. The technology and capabilities need to be available as a resource to find what it is you are looking for! Some tests you are able to carry out, you have to specify what it is you want to find, which is fine, however, how do you know what this is when you are unaware of what the raw material may have been adulterated with in the first place? So it is good to hear that there is a DNA test which can test for multiples species simultaneously, in one single sample. A good step in the right direction.
Paul Dobson from Premier Foods, Quality Safety & Environment Director…
I enjoyed Paul’s presentation content due to the fact it was practical and actually detailed what a food manufacturing business could implement to achieve a robust system for horizon scanning, assessing the threats and documenting and reviewing on an ongoing basis.
The horizon scanning strategies I found interesting were to look for the raw materials which were most at risk. How does Paul do this? By asking the following questions:
- Could you tell the difference of the raw material visually if it was adulterated? The example used was a peppercorn is whole and distinguishable, whereas if the raw material is pepper in powder format, you couldn’t tell if it was adulterated.
- Are the supply chains complex and long? This is always a risk as the more times the raw materials change hands of responsibility, the larger the risk. But this doesn’t mean you should dismiss the short supply chains, especially if you believe there may be a suspicion.
- Is there some kind of provenance claim or claim on pack?
- Is there a short supply?
- Is the opportunity to buy too good to be true? He mentioned here that to get your procurement team thinking that way is the right way forward instead of them getting a pat on the back for achieving such a great deal which could actually be adulterated food!
- Has there been changes in the regulations for that raw material? If so, what if there is stock piled food under old regulations – where is it being used?
- Are the raw materials coming from desperate businesses such as those in some European countries?
Resources Paul used and gave examples of for assessing the risk were:
- Trade associations FDF
- FSA / FDA
- Procurement team
- US Pharmacopeia
- Audit Teams
In addition to the above, Paul revealed a new network, which shows how the industry is starting to work together on tackling food fraud. Currently there are 21 core members. It is going to be made available for further members in the industry. The way it works is that each member has to share information food fraud issues which have been identified in their business and the testing which has been carried out to try and prevent it on raw materials. This has to be reported on a quarterly basis, if the members do not complete the reporting, they are kicked out as there will be no benefit to other members if they do not comply. The objectives and overall aim is ‘to share intelligence and to divert, detect, deter and disrupt food fraud’
What is it called? Fiin: Food Industry Intelligence Network
So far the results have been very interesting. This is where the results of reporting are helping to shape and guide testing regimes to focus on areas of potential concern. From published data looking at adulteration in the US (National Centre for Food Protection and Defence), fish is the number one adulterated or substituted food, followed by dairy then oils and fats.
Dr John O’Brien from Nestle, his role is Deputy Head of Nestle Research Centre, Leader of Nestle Food Safety & Integrity Research Programme. His topic: tools and techniques to map your supply chain and ensure authenticity of your raw materials…
John’s definition of integrity: ‘Integrity is ensuring there is no deviation from the specification’
John started with the reasons why tackling food fraud is important, which I think we all understand is for consumer safety and trust. John then went on to say that our aim is to have that consumer focused attitude towards our businesses. Having visibility of the standard of quality management in our entire supply chains is key to doing this.
His insight into top fraudulent foods reiterated fish once again, stating that a great deal were caught illegally, that fish stocks were depleting and a lot of fish were from non-target catches. Other foods included oils, milk, honey, tea, coffee, spice and saffron.
John pointed out that we need to think about the type and number of processing points of our raw materials and supply chain complexity, as increased processing and increased international supply increases vulnerability.
At this point, another advancement in research was brought up by an audience member. She revealed that she had been completing research into a test which can be completed in real time, which is relatively low-cost and tests against its specification. This sounds to me like it will be a revolutionary tool which can be used throughout the industry. If or when this happens, complete consumer confidence can be guaranteed! Clearly something to look out for!
Salvatore Ranchetti from Ferrero, Group Quality Director…
A very strong Italian accent, so I had to listen carefully!
The biggest risk to Ferrero? Nuts! They are the largest user of Hazelnuts and have to have a multiple supply base to enable them to facilitate this.
Salvatore went on to tell us all about the excellent quality controls which have been adopted within Ferrero. He was asked how this was achieved, and he stated it was due to a massive recall they’d had to perform, which sounds a little bizarre, however he went on to explain how a recall was good for driving quality.
By using all of the information and facts gathered from that recall he scheduled a meeting with Mr Ferrero himself and explained how investment in quality would drive the excellence the brand is known for and regain the consumer confidence in the brand. Needless to say, he gained the financial investment needed for quality throughout all of their sites worldwide.
He went on to use the details of the recall as examples of what can happen when things go wrong when dealing with site personnel. He was asked by an audience member ‘what was his key strategy to improving quality across the group?’ His answer was straight, having key people in the right places. He used quality ambassadors for the company to work for each site for a set number of years. They work to raise the standards to the company benchmark and bring everything in-line and the personnel used were more often than not from an auditor background.
A quote that Salvatore used which I liked was: ‘Quality is never an accident, it is always a result of intelligent effort’ John Ruskin 1894.
Nikos Mavroudis – Food Engineering & Separation of Actives, FoESA Lab, Department of Applied Sciences, Northumbria University…
Beyond measurement and towards the removal of contaminants: Can advance separation processes offer a credible remedy to both acute and long term harmful components of food?
Nikos wanted to share a story of research progression and how this is going to help us in the future to ensure our food is safe. It was very interesting to learn of the Cassava root vegetable, grown in developing countries. When grown, some varieties contain cyanogenic glycosides taken from the air which make it toxic. This is good on one hand as the animals do not eat the crops leaving them for human consumption. However, even though farmers prefer this variety, the toxins need to be removed to eat it. Safe preparation of the Cassava removes the toxin, but also removes the nutrients, meaning the source of food for the natives is not as beneficial.
A research experiment was carried out which removed the toxin from within the plant when grown, which when trialled resulted in the animals eating the crops – a failed result for the experiment! What this did reveal however, was that a single element of food is able to be removed. This can ensure food is safer as other food elements can be removed too, such as micro toxins or acid from fruit juices to make it healthier. Another step in the right direction for safer, healthier food.
Tisa Causevic, Business & International Food Law
Tisa has been involved in setting up a Food News Monitoring System which she described as a one-stop-shop for information on food legislation, change in legislation announcements, scientific research and data, business industry news to name just a few of the resources. It will be a centralized database which will be maintained, validated and verified on an ongoing basis. This would be a very useful tool for food businesses when it is launched as we all know it is a challenge to find one really good source of information to ensure we are complying 100% of the time …. Something else to look out for!
Nick Martin is the Head of Group Technical from Tayto Group Ltd, they are the third largest snack manufacturer in the UK. The most well-known products they produce are probably Golden Wonder and Mr Porky.
Nick’s talk was another useful and practical demonstration of a real manufacturer with real issues and how they solved them in this case – Allergens.
He spoke of how they audit all suppliers against all allergens they handle on site, what their methods of control are, do they guarantee the raw material being supplied is free from the allergens required and if not, they get put on an improvement plan to ensure they can guarantee, or they cease supply. They also ensure they are assessing the allergens handled in their suppliers site. This in my mind is how it should be done.
In any doubt on their supplier’s controls, Nick would visit the suppliers site and audit it himself. Once, when completing an audit on a maize site, the controls were so poor he questioned them. The supplier said, ‘this is just how maize is made’. Still in doubt, Nick visited two other maize suppliers whose controls were excellent, ceasing the other supplier immediately. This shows that we should not take things at face value, we should investigate further, research more and don’t let lower standards become acceptable.
Nick shared an allergen case study with us which was very interesting and something you may want to question yourself…
Tayto produce prawn crackers, and due to a complaint, the customer had completed an allergen test for egg. It came back positive, however the tests completed on site for the same batch had shown the absence of egg. Ensuring compliance, it was checked that all laboratories used were UKAS standard along with the allergen egg tests, and they were. Tayto had to investigate further, and appointed the service of another external lab, who was also UKAS accredited, to complete the test again to verify results. Once again the result came back stating egg was not present, they reported this result to their customer and a further lab was also appointed by the customer and further tests done on more of the product which also turned up positive for egg. This was mystifying for all involved and all of the test results were scrutinised further.
It became apparent that the test bringing up the negative result could only test for raw egg when the egg in the finished product of the prawn cracker was cooked, therefore deeming the initial tests ineffective. The cooking process denatures the egg protein meaning the test completed by some of the labs, was not the right test for sourcing cooked egg protein. The moral of this story is, even though your lab is UKAS, you must ensure the test they are performing on your product is the right one!
He finished to say that in Tayto, there are actually CCP’s for allergen management against ‘recipe processing’ and ‘labelling’. He has been questioned about this at many audits, however, since these have been adopted there have been no incidents with allergens. Some may argue that allergen management is a prerequisite and not a CCP, however bringing the importance of these processes to operatives has had a successful outcome in this instance.