3 Ways To Mitigate Food Fraud Vulnerability

By Laurel Maloy, contributing writer, Food Online

Economically Motivated Adulteration is on the rise, so the U.S. Pharmacoeial Conventions is providing assessment tools to combat it with its new guidance document

Economically Motivated Adulteration (EMA), or food fraud for economic gain, is being talked about like never before. Appendix XVII: Guidance on Food Fraud Mitigation was drafted by the The U.S. Pharmacopeial Convention’s (USP’s) Expert Panel on Food Ingredients Intentional Adulterants. The Food Ingredients Expert Committee requested the guidance with the intent to provide a framework by which the food industry and its regulators could implement preventative programs. This topic is also addressed in FSMA — regulation committed to prevention.

1. Mitigate vulnerabilities by re-examining relationships with suppliers and by being aware of suppliers’ history in regard to audits, quality, safety, and testing
   1. Supply Chain
      1. A low risk of EMA would be with a company who is vertically integrated and therefore fully cognizant of the sources within its supply chain
      2. A high risk for EMA would occur when your supplier, or theirs, is purchasing the product from the open market
   2. Testing
      1. A low risk is when you can confirm that every lot is independently tested and you can attest to selectivity and test specifications
      2. A high risk would be with a supplier lacking the proper Certification of  Analysis (COA) specific to the lot number or when no independent testing is accomplished
   3. Audits
      1. A low risk for EMA is present when robust, onsite audits with the purpose of detecting fraud are performed and can be verified
      2. A high risk for EMA should be assumed if a supplier performs no onsite audits
   4. Geography and Regional Distress
      1. A low risk exists when the ingredient is a single component from a single location with little or no geopolitical worries
      2. A high risk is when one or more of the raw components either originates from or is transported through any region(s) with more than one geopolitical upset

These are only a few of the considerations to be made when assessing the likelihood of opportunities being exploited for financial gain. Other red flags would include a history, rumor-mill or not, of fraud and broad economic anomalies — if the price is too good to be true-it probably is. USP cites the incident in 2007 of melamine-tainted wheat gluten that killed an estimated 2,000 to 7,000 pets in North America. A premium price was paid for the wheat gluten, due to a shortage at the time. Three different companies were contracted in the supply chain prior to the manufacturer receiving the tainted product. In the process, the adulterated wheat gluten was deliberately mislabeled in order to avoid mandatory Chinese inspection prior to its departure. USP maintains that if the glaring supply chain vulnerabilities had been assessed — supplier relationship, economic anomalies, and the susceptibility of quality assurance (QA) methods and specs — there would have been an early indication for the potential for EMA fraud.

2. Mitigate vulnerability by being knowledgeable of the raw product or ingredient

For example, whey protein ingredients are at high risk for EMA. The complex nature of the recipe allows for variables that can only be confirmed through highly-selective and specific testing. For example, the Kjeldahl nitrogen method for assessing proteins is not capable of identifying non-whey protein nitrogen, such as vegetable proteins or compounds high in nitrogen, such as cyanuric acid, melamine, and urea. Fruit juice concentrate is also highly suspect, especially when testing is limited to BRIX, pH, and visual inspection. The lowest vulnerability would be concentrate subjected to these three testing methodologies, as well as: sugar and sugar alcohol profiles, titratable acidity, organic acids and ratios, UV-visible spectrometry, amino acid and mineral acid profiles. The USP also recommends a pigment profile, a C¹³/C¹² ratio and an O¹⁸/O¹⁶ ratio to completely rule out EMA fraud in fruit juices. Olive oil and honey are two more of the most common products susceptible to EMA.

3. Mitigate vulnerability by assessing the potential impact on public health

Not all risks are created equal. Though all food ingredients can potentially be targeted for intentional EMA, it is up to your facility to decide which ingredients would have a substantial economic, public health, or regulatory impact. All aspects should be evaluated and a priority given to reassessing those that would have the most devastating impact in any category, though the public’s health should always be the primary concern. To further delineate the list, consider things that would multiply the effect, such as focused consumption or public confidence in your brand.

The USP has compiled the USP Food Fraud Database which lists adulterants, by ingredient, for not only documented fraud cases, but for those adulterants considered to be common and reported upon in literature. Once vulnerabilities are identified, you can tap trade associations or companies that have had experience with food fraud surrounding specific ingredients. The Grocery Manufacturers Association, the Technical Committee for Juice and Juice Products, and the Food Chemicals Codex (FCC) are all invaluable resources to aid in the development of your EMA vulnerability assessment. There are also a number of resources here.

The Appendix provides illustrative examples for numerous incidents of food fraud perpetrated within the last decade. You may be surprised at the lengths some will go to in order to fatten their bank account at the public’s expense.