Food Quality Magazine ISSUE 03 | JULY 2016
Beginning in 2007 , thousands of pets in the U . S . experienced renal failure after consuming pet food containing melamine-adulterated wheat gluten . The pet food producer had made a one-time purchase of wheat gluten from a U . S . -based supplier during a period of short supply 8 . The U . S . - based supplier had imported the wheat gluten from a Chinese company that , in turn , contracted with a separate company in China to fulfill the contract . In this case , the supply chain was not vertically integrated or well-controlled , which left it vulnerable to fraud .
• Audit strategy : is there a robust , onsite audit strategy with anti-fraud measures , or a less mature audit strategy without targeted anti-fraud measures ? A fraud incident uncovered in 1990 in the U . S . involved the adulteration of unsweetened orange juice concentrate with beet sugar 9 . The producer went to great lengths to design the processing plants to conceal holding tanks and pipes for the sugar . This illustrates the importance of onsite audits that include measures designed specifically to address the potential for fraud .
• Supplier relationship : Is the supplier relationship established and trusted ? In the 1980s , extensive and lucrative fraud involving apple juice was uncovered in the U . S . An apple juice producer changed their supplier of apple juice concentrate , which was being offered by the new supplier at a cost substantially below market value 10 . The supplier was producing “ apple juice concentrate ” that consisted partly or entirely of water , sugars , flavorings , and colorings .
This incident demonstrates the importance of vetting suppliers and establishing strong and trustworthy relationships .
• History of regulatory , quality , or safety issues with a supplier : Have there been recurrent quality or food safety issues with the supplier for a particular ingredient ? The largescale Salmonella outbreak in the U . S . involving contaminated peanut products was due , in large part , to fraud on the part of executives at the company 11 , 12 . The company provided buyers with fraudulent certificates of analysis , laboratory results , and other fraudulent information . The resulting outbreak investigation revealed a history of supplier quality and safety issues identified by private audits and regulatory inspections . A history of quality or safety issues with a particular supplier should be taken into consideration as one aspect of food fraud vulnerability assessment .
• Susceptibility of quality assurance methods and specifications : Are quality assurance methods and specifications specific and effective for a range of potential adulterants ? Melamine adulteration of both milk products and wheat gluten was possible due to the non-specific nitrogen test commonly employed to determine protein content 13 . A food fraud vulnerability assessment should look critically at the methods and specifications in use to verify the quality of ingredients .
• Testing frequency : Is every lot tested by the buyer , is testing conducted intermittently , or is there reliance only on Certificates of Analysis ? As noted above , melamine adulterated wheat gluten that originated in China was not tested by the U . S . -based importer , who relied on certificates of analysis . This was one of the factors that left the ingredient vulnerable to fraud .
• Geopolitical considerations : Is the ingredient sourced from , or does it travel through , a geographic area with political , food safety , or food security concerns ? A slew of recalls in 2005 in the U . K . resulting from the detection of Sudan 1 ( an industrial dye not permitted in foods ) in multiple finished food products was ultimately caused by imported chili powder adulterated with the dye 14 . The chili powder was imported from a country with a documented history of the use of non-permitted coloring agents . The geographic origin of ingredients is another important consideration in food fraud vulnerability assessments .
• Fraud history : Is there a high volume of known and documented food fraud incidents in the ingredient ? An examination of media and literature sources reveals reports of spice adulteration with artificial colors as far back as the early 1900s 15 and reports of detection methods for melamine adulteration of protein-containing ingredients in the mid-1980s 16 . Historical reports are one of the best sources of information about potential future fraud risk . Media , regula-
8
U . S . v . Miller et al ., 2008 . Case # 4:08-cr-00023-DW . U . S . District Court , Western District of Missouri ( Kansas City )
9
Kurtzweil , Paula . Orange juice scheme gone sour . FDA Consumer : Vol . 29 , Jan . 1995 .
10
Wood , D . J . and Detwiler , A . Beech-Nut ‘ s Apple Juice . 2007 . Available at : https :// www . coursehero . com / file / 7851817 / Case-Beech-Nut-Apple-Juice-Case /
11
Schmit , J . 2009 . Broken links in food-safety chain hid peanut plants ‘ risks . USA Today . April 28 , 2009 .
12
Layton , L . 2009 . Nestle ‘ s Inspectors Saw Rat Droppings , Rejected Peanuts . The Washington Post . March 20 , 2009 .
13
Moore , J . C ., DeVries , J . W ., Lipp , M ., Griffiths , J . C . and Abernethy , D . R . ( 2010 ), Total Protein Methods and Their Potential Utility to Reduce the Risk of Food Protein Adulteration . Comprehensive Reviews in Food Science and Food Safety , 9 : 330 – 357 . doi : 10.1111 / j . 1541-4337.2010.00114 . x
14
Lawrence , F . and Dodd , V . 2005 . Sudan I alert spreads to 15 more countries . The Guardian , 24 February 2005 http :// www . theguardian . com / society / 2005 / feb / 24 / food . foodanddrink1
15
Blair , A . W . 1903 . Spices and Condiments . Report from the Florida agricultural experiment station , department of chemistry , food adulteration . Press Bulletin No . 42 . November 1 , 1903 . http :// ufdc . ufl . edu / UF00090429 / 00001 /
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