The BRC Food Safety Americas 2019 Conference was held in San Diego, May 21-22, 2019. Clare Winkel had the pleasure of being a guest speaker. Here is a summary of Clare’s presentation.
What is food fraud?
Food fraud is intentional adulteration of raw ingredients for financial gain. It is Economically Motivated Adulteration. It is Not: HACCP hazards: prevention of unintentional/accidental food safety adulterationand it is Not: TACCP: Food Defence threats: prevention of intentional adulteration/ ideologically motivated i.e. bioterrorism and It is Not new, as records on food fraud exist from Roman times at least.
As listed by the EU, 2013 products at High risk from food fraud are:
- Olive oil
- Organic foods
- Honey and maple syrup
- Coffee and tea
- Spices (saffron and chilli)
- Fruit juices
A Closer look at few of these examples
In 2014 a hostile bacteria — Xylella fastidiosa — was seen in Europe for the first time, destroying centuries-old olive trees & millions of tonnes of Italian olives. While Spain’s harvest was affected because of hot and dry conditions. Italy reported a 57% drop in production, Greece and Portugal a drop of 35% and 15% respectively.
In 2018 Global production dipped by over 5% due to bad weather and disease. Italy, Greece, Turkey, Palestine, Argentina, Portugal and Tunisia saw the biggest drops. California had a rough year too.
When the harvest is poor, retail prices skyrocket. This resulted in bottlers paying up to 40% more for their oil.
Italy’s crackdown on the illegal olive oil trade has resulted in another major seizure of 200 tonnes of oil falsely labelled as coming from the Tuscany region. Nearly 50 individuals and organisations — including millers, bottlers & traders— have been detained as part of the investigation by the Ministry of Agriculture’s inspectorate for the protection, quality and the repression of fraud in agriculture and food (ICQRF) & Italy’s forestry department. The ploy was discovered thanks to DNA testing of the oil, which revealed a complex scam involving a large number of actors in the olive oil supply chain.
Producers cut the pure olive oil with cheaper oils like palm, sunflower or canola to stretch it further. There is a direct correlation – When the harvest is been poor, rates of adulteration rise!
One of the reasons the Italian Govt has allocated so many resources to fighting food fraud, is part of a larger fight against organized crime.
A shipment of 36 million pounds of soybeans sailed in 2016 from Ukraine to Turkey to California. The cargo began as ordinary soybeans, they were fumigated with a pesticide – tablets of aluminium phosphide, a pesticide prohibited under organic regulations. When they arrived in California, the soybeans had been labelled “organic,” according to receipts, invoices and shipping recordswhich boosted their value by approximately $4 million. And about 21 million lbs of the soybeans have already been distributed.
But where did all this big production come from? Where are these organic farmers?
Here are some facts: between 2014 & 2016, the amount of organic corn arriving into the USA, from Turkey rose from 15,000 to more than 399 000 tons and the amount of organic soybeans coming from Turkey rose from 14,000 to 165,000 tons.
Under USDA rules, a company importing an organic product must verify that it has come from a supplier that has a “USDA Organic” certificate. It must keep receipts and invoices, but need not trace the product back to the farm.
Some of the soybeans originated from ADM Ukraine, a company that does not produce or trade organic soybeans and did not sell or label them as such.
Australia’s biggest listed honey company and some of the country’s largest supermarket chains face accusations of unwittingly selling “fake” honey. Capilano strongly denied any issues with its products and criticized the type of test — known as Nuclear Magnetic Resonance (NMR) — used to detect the impurities, pointing out that it differed from the official Australian test. Germany’s Quality Services International (QSI) lab was commissioned by a law firm on behalf of horticulturalist Robert Costa to conduct 2 types of tests of the sampled honey (NMR & C4).
This appears at first to be an open and shut case of fraud but in fact the law firm organizing the lab tests was involved in a hostile takeover bid of the honey company. The honey company has now changed hands. Follow the money and find out who is creating the fraud- its not always obvious.
Regions at High risk from food fraud:
- The usual suspects: China, Subcontinent (India/Pakistan) & Turkey.
- But basically everywhere: Italy, Spain, EU, USA, ANZ……
Consider climate change (causing shortages/price rises), trade wars (artificial shortages/price rises/falls) and political instability (i.e. Syria, Venezuela…) as any of these will contribute to food fraud risks.
So what DO YOU really have to do about it?
- Read your BRCGS standard.
- Know the regulations in the countries you produce food AND where you sell your food.
- Read the fine print of your customers standards.
- Understand what risk there really is to your business in the real world.
BRCGS Food Safety requirements issue 8
- 220.127.116.11 Documented risk assessment of each raw material that must consider substitution or fraud.
- 5.4.2 Documented assessment of the vulnerability of the raw material supply chain.
- 5.4.3 Where raw material are identified at risk then control measures/mitigation measures be put in place.
- 9.1.1 Documented risk assessment of each raw material that must consider adulteration or fraud.
BRCGS Storage & Distribution requirements issue 3.
- 10.1.1 Supplier risk assessment to include the potential for adulteration or fraud.
- 10.2.1 A documented vulnerability assessment taking into account historical evidence of substitution or adulteration.
- 10.2.2 Where products are identified as at risk, appropriate assurance/testing methods shall be in place.
BRCGS Agents & Brokers issue 2
- 4.3.1 The company shall assess the potential risks to the security of the products from any attempt to inflict contamination or damage during subcontracted transportation and storage…
Join the BRC Professional courses in October to learn more https://integritycompliance.com.au/product-category/brc/
What does a Food Fraud Vulnerability Assessment look like? – the weapons you need to fight food fraud.
With vulnerability assessment, severity is not a particularly useful measureas (at the very least) the resultant product will always be illegal and therefore the consequences are always severe, regardless of whether there is an associated food safety issue or not.
Furthermore, most adulteration cases do not have a food safety concern associated with them and the inclusion of severity may, if not handled correctly, lead to an under estimation of the importance of any identified risks. BRCGS Understanding Vulnerability Assessment section 3.2.
Become an expert in VACCP: Raw material assessments https://integritycompliance.com.au/product/vaccp-online-module-4-how-to-guide/
Summary of VACCP process steps:
- List all raw materials.
- Collect information on every single raw material: List all raw materials, their country of origin, their suppliers (importers/agent/brokers), source manufacturers, pricing trends & all known testing & sampling activities.
- Particularly make sure you have all current certification information on all brokers/agents you buy off & in turn all source manufacturers that actually make the raw materials.
- To get the information on certification READ CARTONS& look for GFSI stds logos, go to companies websites to see what stds they may have implemented. Cross check that information back to the GFSI stds databases or ask the certification body listed.
- Risk evaluation: ranking of suppliers and raw materials. The more accurate information is used within the assessment the more accurate answer/ranking will be available to the user.
- Evidence of past issues of fraud for that product must be assessedfor each raw material.
- Price changes and availability of the raw material must also be collected as this will have a large bearing on future fraud likelihood.
- Some raw materials can be grouped if they are derived from the same plant/animal in the same country of origin (i.e. cinnamon from Sri Lanka) or if they are processed by the same source manufacturer (i.e. same factory) and they have provided you with all test methods and all current certifications.
- Understand which stds require VACCP assessment as mandatory auditable requirements i.e. BRC Food, SQF vs 8, FSSC 22 000 vs 4.1, but not 3rd party HACCP or any ISO stds.
- Control Measures
- After all raw materials have been ranked between 1 – 125, the VACCP team members will have to make a decision on at what score will additional control measures be allocated. This number will indicate the level of significance.
- Implement additional control measures as required based on your documented risk assessments of both suppliers supply chains and raw materials.
- Record keeping
- Document procedures and keep recordsfor each assessment and references.
- Horizon scanning for emerging issues (trigger points for action) and review regularly. https://integritycompliance.com.au/horizon-scan/
- Keep records of the review.
Feel Free to contact Clare Winkel at ICS if you need expert advice email@example.com