Issue #95 | 3 Cases of Document Fraud | How to be a Good Auditor | How Bakers Yeast is Made |
2023-07-03
3 Real-World Examples of Food Document Fraud
What Makes a Good Food Safety Auditor?
Suggestion Box! - Your Feedback is Needed
How Bakers Yeast is Made
Food Safety News and Resources RoundUp
Food Fraud News, Emerging Risks and Recent Incidents
Hi there!
Welcome to Issue 95 of The Rotten Apple, and happy Independence Day for tomorrow if you are in the USA.
In this week’s issue you’ll find three real-world examples of document fraud in food systems, so you can see what it looks like, and learn to identify it for yourself. Also this week, what it takes to be a good food safety auditor and how industrial yeast is ‘made’ in 2023.
Your suggestions are needed! I’m getting ready to celebrate 🥂🎈 100 issues 🎈🥂 of this newsletter next month (woohoo!) and want to know what you would like more of, less of, and everything in between. Please take a moment to visit my suggestion box during the next three weeks.
In food safety news this week there’s news of an emerging gastrointestinal pathogen, 3 recalls for frozen fruit (not norovirus this time), and one linked to the chemical patulin, an apple-associated mycotoxin.
As always, food fraud news is at the end for paying subscribers (who are excellent humans!), including a truffle industry scandal, elderberry extract frauds and an alert about undeclared pharmaceuticals in tea products.
If you like this newsletter, please take a moment to tell your friends and colleagues about it. Your shares make a genuine contribution to the continued viability of this publication (thank you.)
Have a fabulous, independent week.
Karen
Document (Food) Fraud in the Real World
Document fraud in food systems is a thing. And awareness is growing. If you’ve been following me for a while you know I mention it often and featured it in my top 5 Food Fraud Trends to Look Out For in 2023.
Food document fraud can be categorised into three different types, according to how it presents in a food fraud incident, and how risky it is in terms of food safety.
Category A food document fraud is document fraud that accompanies other fraud activities. You can find document fraud in almost all business-to-business food fraud transactions.
As an example, let’s consider a hypothetical case in which a manufacturer of ‘unsweetened’ orange juice concentrate adds undeclared sugars to their product. The main fraud is the adulteration, the addition of sugar. However, when the manufacturer sells the concentrate they also supply documents that are fraud-affected.
The invoice, the product specification and certificates of analysis for the concentrate, which say ‘Unsweetened orange juice concentrate’ would now also contain false information in this case and those documents are now examples of document fraud.
Category B food document frauds are those in which falsified document(s) are the main driver of the fraud. For example, when a fraudster attempts to pass off a shipment of conventionally grown soybeans as organic soybeans on import documents it is the document itself which represents the ‘main’ fraud, there is no adulteration or tampering with the actual food.
Category C food document frauds are fraudulent documents related to food-safety claims. Falsified microbiological results or faked expiry dates are examples of this type of document fraud. They are the most concerning type of document (food) fraud because they can make unsafe foods seem safe. And the consequences can be deadly.
3 Real World Cases
I’m indebted to Janette Hughes, of Melbourne Quality Assurance (MQA) for the three examples listed below, which she has personally experienced in her work with small to medium-sized food manufacturers.
(1) Faked lab report. A supplier provided a laboratory report for micro and allergens for dehydrated garlic from China. Because China is on MQA’s ‘high-risk’ list, Janette contacted the issuing laboratory to make sure the report was legitimate. She does this as a matter of course for all documents received from China. The lab report was completely fake.
(2) Certificate of conformance tampering. A supplier provided certificates of conformance for an ingredient, but had removed all the company logos from the certificate. This makes the certificate of conformance impossible to verify and the material impossible to trace in the event of a problem.
Suppliers sometimes remove identifying information in a misguided attempt to prevent a customer from bypassing them and purchasing direct from the manufacturer. However, it’s not as much of a risk as they might imagine; most small and medium food companies prefer to purchase from middle-level suppliers who can supply smaller quantities, and most ingredient manufacturers, will not supply smaller food companies.
(3) A forged product information form (PIF). A product information form is a standardised information-sharing system for food ingredients and products which covers regulatory and industry requirements for Australia and New Zealand. In this case, the PIF for one ingredient had been copied and pasted into the PIF for another.
Janette happened to have the correct PIF from the manufacturer in her files. She compared it to the forged PIF and discovered that all of the ‘may contain’ allergen statements had been removed. This meant that the purchasing food company was getting incorrect information about the possibility of allergens in the ingredient. The outcome could have been extremely serious for allergic consumers of the finished product.
When allergen information is falsified, people can die.
A ’mismatch’ in allergen information like this was blamed for the death of a woman with a severe milk allergy in the United Kingdom in 2017. A pre-inquest hearing heard that the supplier of a supposedly dairy-free dressing allegedly knew it could have contained traces of milk, but the ‘May Contains’ statements about the allergen did not end up on the final food package.
Without the ‘May contain’ statement on the pack, the allergic consumer did not know it was potentially deadly. She ate it and died from a severe allergic reaction.
People who falsify food documents are often not aware they could cause serious harm. Such frauds are usually perpetrated to save money or to attempt to satisfy customer requirements that would otherwise be difficult or costly to meet.
Luckily, Janette’s false PIF case had a happy ending. The supplier of the forged document was educated about the risks and downgraded from the main supplier of that ingredient to the backup supplier. Special conditions were also added to their vendor approval so similar problems can be easily detected in future.
Best of all, the food company has increased their appreciation and trust for the thorough checking done by Janette. She literally could have saved them from having to appear before the coroner.
Janette says:
“I am finding LOTS of these documents [CoC, CoA or CoQ] to be fraudulent or misleading. Make sure you study these records as part of your ingredient risk assessment, VACCP, and Approved Supplier Program. And yes, challenge the data in them.”
Find Janette on LinkedIn.
What Makes a Good Food Safety Auditor?
Anyone can claim to be an auditor but, for a certification scheme to have real credibility, it is essential that it employs good auditors. What attributes does a good auditor need? And what qualities should they demonstrate during an audit?
A good auditor must have appropriate training and qualifications. The BRC for example, will only certify auditors to audit the types of food operations for which they have demonstrated robust experience and knowledge. For food safety auditors it is a good idea if they have degree level qualification in food technology or a similar scientific discipline.
Be prepared. Learn as much about the operation you are going to audit as you can. A detailed knowledge of the standard you are auditing is also vital otherwise how can you assess whether the operation being audited is compliant or not?
Experience. It helps if you have "the insider's view" as an auditor. In other words, you are much more likely to be an effective auditor of an operation if you have previous experience of having worked in a similar type of operation yourself.
The right mindset and more than a modicum of self-confidence! Audits are not really about factories and equipment; they are about people. Therefore, an auditor must have good inter-personal skills: they must be a good listener and a keen observer; they must be dogged in pursuit of the truth and not be easily satisfied with "off-the-cuff" answers. They must be firm and self-confident as they are often faced with people whose overriding objective is to rush through the audit as quickly as possible or to obstruct the auditor in their work.
Be able to take a "big picture" view. Too often auditing gets bogged down in the small stuff; for example, is it 6 or 7 minor non-conformances? Ultimately the auditor must remember their overall objective: if it's a food safety audit, can the operation consistently produce safe food or not? A little alchemy is involved as this can be a combination of non-conformance numbers and expert instincts.
Be organised. Auditing is a difficult and complicated process. During an audit you are likely to meet many people and see and hear many things. You need to simultaneously record your findings unless you are lucky enough to have a photographic memory! This is where it is advisable to have an audit checklist as an aide-memoire and sufficient spare pens so that you don't run out.
Be collaborative. A good audit needs to be thorough and rigorous, but a successful audit is not about point-scoring and demoralizing the auditee. If it results in an A-grade then both parties should feel happy.
If the site you are auditing commissioned the audit themselves you will soon know whether you have done a good job or not since a bad audit will result in your not being invited back to re-audit them next year!
🍏 David Worthington is a graduate food tech with 33 years' industry experience, 17 as a freelance food safety consultant and 10 years spent working directly for a variety of multiple retailers. His professional mission is to help food manufacturers, importers and brokers win private label contracts by getting their factories client-approved and food safety approved. 🍏
How Yeast is Made
Wine, beer, bread…. some of the yummiest foods rely on yeast. Yeasts are microorganisms that ferment sugar and other carbohydrates to produce gasses and other chemicals. In the process, they transform raw agricultural materials into delicious foods and drinks.
Commercial bakeries, wineries and breweries don’t grow their own yeast; they purchase it from specialist suppliers. Different strains of yeast have different characteristics and are chosen by food and beverage makers for their production efficiencies and flavour-producing abilities.
A good commercial yeast product must be pure and free from other microbes which could cause spoilage or food safety concerns. Yeast manufacturers grow specialised strains in large fermentation tanks to produce liquid yeast, solid yeast and dried yeast products.
This informative video, by a European yeast producer, shows exactly how they make yeast for bakeries, breweries and other industrial customers. (2:38 mins). Enjoy!
Food Safety News and Resources
No ads, no sponsored content: our weekly roundup of global food safety news is carefully curated and only top-quality information makes the cut.
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