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The Implications of Food Fraud
by Karen Everstine, PhD, MPH, Amy Kircher, DRPH, and Elizabeth Cunningham
As we write this, there are more news reports every day of new products that have been found to contain horse meat in the European horse meat scandal. Horse meat substitution is unfortunately only the most recent example of food fraud, and horse isn’t the only meat being substituted. According to the Daily Mail on February 25, seven in 10 lamb kabobs sold in British takeout restaurants were bulked up with cheaper meats. Food Manufacture reported on March 14 that pork DNA had been found in a school’s halal chicken sausages. Yahoo! News reported that 90 percent of South African kudu (antelope) jerky was actually horse, pork, beef, giraffe, kangaroo—or even endangered mountain zebra.
Food comprises a globally distributed infrastructure, with the U.S. both importing from and exporting to more countries in food and agriculture than in any other sector. Importing large quantities of food products from other countries makes us reliant upon the food safety systems of those countries. Regulatory or quality assurance deficiencies in any part of the food supply chain can leave us vulnerable to contamination or adulteration. Increased prices can also leave the food supply vulnerable to adulteration since they can result in changes to the supply chain structure. Ensuring food safety requires identifying and mitigating potential risks along the supply chain. Food safety demands that these risks be identified and they can only be addressed if there is a good understanding of the supply chain and the product is authentic. Furthermore, the need for food defense is heightened by the globalized supply chain, and the possibility of deliberate contamination and adulteration—either with the intent to cause harm or generate extra profit. Since we cannot have complete food safety without effective food defense, food quality cannot be assured without a comprehensive food protection program that addresses both food safety and food defense.
Food fraud, or what the FDA calls economically motivated adulteration (EMA), is the intentional sale of food products that are not up to recognized standards for economic gain. This includes the addition of inferior or foreign substances to a food, dilution with water, or the intentional mislabeling of food products. Food fraud may be receiving heightened media attention in recent months, but it is an old problem that was addressed by U.S. food laws as far back as 1784. While usually harmless, some food fraud incidents have resulted in serious public health consequences, and they illustrate vulnerabilities in regulatory and quality assurance systems that could be exploited for intentional harm.
In today’s environment, there is a strong financial motivation for food fraud. In the ongoing case involving six companies accused of conspiring to illegally import honey, the defendants allegedly avoided almost $80 million in anti-dumping duties by falsely declaring the country of origin. The Grocery Manufacturers Association estimates that adulterated food products cost industry 10 to 15 billion dollars a year and the problem is thought to be widespread. The Food Standards Agency of the U.K. has estimated 10 percent of the food we buy on the shelf may be adulterated. In most cases, the adulteration doesn’t pose a health risk since the motivation is not intended to cause harm. Unfortunately, by not understanding their actions, perpetrators have created risks to human and animal health.
Understanding the Scope of the Problem
Since the perpetrators of food fraud do not intend to cause health harm and know how to get around quality assurance testing methodologies, food fraud incidents frequently evade detection. This makes it challenging to know the true scope of fraud in the food supply. The National Center for Food Protection and Defense (NCFPD) has conducted an extensive literature and media search for documented incidents of food fraud since 1980. This search has resulted in over 200 isolated incidents of food fraud in many categories of products, including seafood, oils, wine, dairy products, and fruit juices (see chart above). The U.S. Pharmacopeial Convention has also compiled a food fraud database, using a different methodology (www.foodfraud.org). Both databases contribute valuable information about what is known about the history of food fraud. However, what is represented in the databases is almost certainly only the tip of the iceberg when it comes to the true scope of food fraud.
The adulteration of beef products with horse meat has fortunately not resulted in public health consequences; however, EMA is not always benign. Melamine adulteration of wheat gluten in 2007 caused illnesses and deaths in thousands of pets in the U.S., and melamine-tainted feed entered the supply chain for animals intended for human consumption. A year later, melamine adulteration of dairy products in China resulted in hundreds of thousands of illnesses and at least six infant deaths. In 1981, industrial-grade rapeseed oil that was sold as olive oil in Spain caused more than 20,000 illnesses and at least 300 deaths.
How Do Incidents Go Undetected?
EMA incidents are challenging for industry and regulators to prevent because the adulterants are usually innocuous and the adulteration is designed specifically not to be detected. Often, the most successful adulterants are novel; therefore, quality assurance testing methodologies are not designed to detect them. For example, in the mid-1980s, sweet white dessert wines in Austria were adulterated with diethylene glycol (an industrial solvent) because it improved the body and sweetness of the wines. At the time, there was no reason to test for the presence of diethylene glycol in wines because it was not an expected adulterant. Since there were no short-term health effects, the adulteration could have continued if a tax inspector hadn’t uncovered the fraud by investigating tax refunds claimed by a wine producer for large quantities of diethylene glycol. Testing methodologies for more commonly adulterated products, such as honey and olive oil, are continually evolving to keep up with advances in adulteration methods. However, analytical methods for food products can be expensive, and it is not practical or feasible to test all food products for every possible adulterant.
Getting Ahead of the Problem
Identification of EMA events must come sooner to mitigate human health consequences and economic loss. Better detection methods are important, but they are not the only solution. Early warning analysis that takes advantage of multiple data sources has the potential to alert us to elevated risk of EMA in certain food products for relatively few resources. Inspection, laboratory testing, and other crucial and cost-prohibitive resources can then be targeted towards the riskiest food products.
Individual industry members and regulatory agencies have much of the information and food system knowledge that could help early identification an adverse food event, but it is not currently compiled for real-time analysis. Collaboration and information sharing between public and private interests are also essential to ensure that the food supply remains well protected and resilient.
The development of data management technologies in which the food and agriculture stakeholders can regularly and proactively share real-time information across the globe is key to identifying risks and initiating the appropriate response to mitigate adverse consequences. Various data sources, compiled and analyzed to detect a signal, can serve as a trigger for decision makers to take action. Using data sources such as weather information, global trade data, pricing indexes, policy changes, and indications of political and civil unrest, we can build algorithms that can assist in identifying the environments where food fraud is likely to occur or may already be in the system.
The NCFPD has initiated research and development of technology solutions, known as the FIDES and EMA projects, which support data fusion, analytics, and dissemination within and across organizations to help identify and warn of food threats such as EMA, provide risk management assessments, and provide decision makers tools to make informed assessments and decisions.
Increased awareness of and research on food fraud provides an opportunity to improve testing methodologies and develop new capabilities for rapidly identifying adulteration in the system prior to seeing adverse health and economic consequences. These dedicated efforts will serve as a deterrent to those seeking to adulterate our food supply.
Dr. Everstine, email@example.com, is research fellow at National Center for Food Protection and Defense (NCFPD). Dr. Kircher, firstname.lastname@example.org, is acting director for NCFPD. And Cunningham, email@example.com, is the communications manager for NCFPD.
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