Mitigating the Risk of ‘Fake’ Food

The food business is as competitive as ever. Food manufacturers are under tremendous pressure to formulate new products while meeting emerging regulatory requirements, reducing costs, and protecting their brands. Food manufacturing companies are increasing the attention paid to food fraud, which can greatly impact a brand if adulterated food ends up on customers’ plates. Food safety concerns stemming from food fraud are a risk to consumers in our globalized food system. Food companies are keenly aware of the consumer’s desire for safe, high-quality foods. The rise in consumer awareness drives companies to continually strengthen their food safety and quality programs.

Food Fraud Yesterday and Today: Little (And A Lot) Has Changed

Food fraud issues are not new. Frederick Accum’s “A Treatise on Adulterations of Food and Culinary Poisons” from 1820 and Dr. Harvey W. Wiley’s Poison Squad of 1902 demonstrate the long-standing concern with adulterated foods and undeclared additives. What has changed is that the health risk due to food fraud (a.k.a. economically-motivated adulteration, or EMA) has become a widely-publicized issue with corresponding increases in regulatory and certification program requirements. What has also changed is the sophistication with which fraudsters adulterate food and the speed of evolution of analytical detection methods.

Food fraud is complex and includes the dilution or substitution of ingredients with an alternate ingredient (this could be an ingredient of lesser quality or even one that is not intended for use in food), the artificial enhancement of perceived quality (such as fraudulently increasing the apparent protein content and “improving” the color with undeclared color additives), the use of unapproved antibiotics and preservatives, misrepresentation of nutritional content, and fraudulent labeling claims (such as organic, cage-free, etc.).

New Requirements: Focus on FSMA and GFSI

Both the U.S. FDA and the Global Food Safety Initiative (GFSI) have recognized the threat of food fraud in the food supply. As a result, new FDA regulatory requirements and GFSI requirements have been established to ensure that food manufacturing and distribution facilities address food fraud vulnerabilities in their food safety and quality management systems.

The FDA’s focus is on EMA that can result in food safety issues, and it requires facilities to identify potential hazards (including those resulting from EMA) during their documented hazard analysis process. When raw materials with relevant potential hazards are identified, appropriate controls should be put in place. Given the nature of EMA, these will most likely be supply chain controls.

Facilities certified under GFSI programs such as British Retail Consortium (BRC), Food Safety System Certification (FSSC) 22000, and Safe Quality Food (SQF) must consider food fraud in terms of both food quality and safety. For companies that will be certified under SQF Edition 8 and FSSC 22000 Version 4—both of which will become effective in January 2018, food fraud vulnerability assessments and mitigation plans will be new requirements of those certification programs.

Risk Mitigation: Tools and Guidance

In contrast with unintended contamination with microbiological, viral, or other agents which may be present in animals or the food production environment, food fraud includes the added challenge of being both intentional and economically motivated. This makes risk assessment a more difficult task. Food fraud is generally addressed from the perspective of vulnerability—in other words, which ingredients in a portfolio may be more vulnerable to fraud due to various specific factors. These include things such as the strength of the supplier relationship, the audit strategy, the effectiveness of the analytical methods, and the known history of fraud for a given ingredient.

The U.S. Pharmacopeial Convention (USP) Food Fraud Mitigation Guidance (www.foodfraud.org) is a publicly-available framework that guides users through an evaluation of nine contributing factors to food fraud vulnerability. It also guides users through the process of considering potential impacts of food fraud, both economic- and health-related, and putting a mitigation plan in place to reduce vulnerabilities. Food fraud history is specifically cited as an important component of vulnerability assessments. USP has developed a tool, the Food Fraud Database, for quickly searching and identifying relevant historical records for food fraud along with published analytical detection methods. USP also publishes the Food Chemicals Codex that describes the form, function, and specifications for more than 1,200 food ingredients, along with analytical methods and corresponding reference materials that can be used to ensure their quality and purity and further establish the identity of food ingredients. Use of public standards can be an important component of a food fraud control plan in addition to being useful in an overall food quality control program.

Documenting Vulnerability Assessments and Control Strategies

There are three primary steps to effective food fraud prevention programs:

1. Raw Material Vulnerability Assessment;
2. Food Fraud Mitigation Plan; and
3. Food Fraud Program Sustainment.

The first step in creating a food fraud prevention program is to conduct a vulnerability assessment of all raw materials or groups of raw materials. As part of this assessment, food producers must identify the source of their ingredients to determine whether they come from potentially high-risk geographic areas or suppliers. Other considerations include whether ingredients have a known history of adulteration and whether there are economic considerations that would increase the incentive for fraud. Raw materials can then be categorized as low, moderate, or high vulnerability.