Issue #65 | But What About Prions? (Cultured Chicken Declared 'Safe') | Not Funny Vid| Europol on Food Fraud |
2022-11-21
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Big questions after the US FDA declares cultured chicken safe
Europol’s latest food fraud roundup
Food service worker on TikTok, your blood may boil
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Food fraud incidents, updates and emerging issues
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Hi there, fellow food champions,
Welcome to Issue #65 of The Rotten Apple. Just a reminder that we have ‘scholarships’ (freebie subscriptions) available for students and academic professionals, thanks to the generosity of our latest Good Apple subscribers. Write to me at therottenapple@substack.com or reply to this email if you would like one.
So I went on a deep-nerd voyage into cultured meat production processes over the weekend, coming up only briefly for coffee refills. The voyage was one of discovery, and like all voyages, it included a few ‘uh oh’ moments.
My voyage was inspired by the news that the US FDA has (sort of) approved the safety of a cultured chicken manufacturing process. As part of their ‘approval’ notice, they published a document which made for some juicy reading and raised a few big questions for me. Hopefully I have done a good job of answering the first biggie this week, with more to follow in the coming weeks.
Also this week, Europol’s latest food fraud operation results are out. They shared an eery video with no voice-over of unlabelled footage of - presumably - food seizures and inspections in progress: worth a watch.
Finally, a Not-For-Fun piece about a fast food worker who fakes temperature records, and recommendations for food businesses who want to avoid such shenanigans.
There are plenty of food fraud updates for paying subscribers this week, including a new one for me: manure fraud in the organic supply chain. Yep, manure fraud is a thing.
Have a thankful 🦃, grateful week, all. Thank you for being a part of this community,
Karen
P.S. Thank you for continuing to share this newsletter with your friends and colleagues. More shares helps fund this high-quality, ad-free food safety content for our international community.
Opson XI - Europol Fights Food Fraud
Every year Europol coordinates a multi-country, anti-food-fraud operation in which local enforcement authorities such as police and customs officials work to find and shut down illegal food and beverage operations.
Opson XI is the latest such operation, and the report has just been released. Opson XI ran from Dec 2021 to May 2022 and included operations in 26 countries in which almost 27 000 tonnes of fraud-affected food and almost 15 million litres of alcoholic beverages were seized.
The products seized included (listed in order of quantity) alcoholic beverages, cereals, grains and grain-derived products, fruits/veg/legumes, food supplements or additives, sugar and sweet products, meat and meat products, seafood, dairy products and poultry products.
Examples of successful enforcement activities included the dismantling of a criminal network that was selling modified gardenia flower parts as saffron; the shutting down of illegal slaughterhouses and the seizure of an entire Italian winery where the owners had been making inauthentic wine by adding aromas, sugar, water, mis-declaring the alcohol content and misrepresenting the quality of the wine.
Source (Europol’s press release): https://www.europol.europa.eu/media-press/newsroom/news/food-fraud-about-27-000-tonnes-shelves
🍏 A link to Europol’s slightly eery and voiceless 3-minute video of seized foods and drinks is below 🍏
What’s interesting about this video is that while many of the illegal operations look super-dodgy, there are also a few that look legitimate and hygienic, like the dairy foods processing plant in the final 15 seconds.
Cultured Chicken Meat is Safe, Says FDA (Sort Of)
But I have questions...
Last week the US Food and Drug Administration (FDA) issued a memo saying that they “have no questions” about the safety of a process for making cultured chicken meat. The ‘no more questions’ memo (sort of) means that the FDA agrees with the manufacturer’s assertion that their process results in material that is as safe as chicken meat from conventional sources*.
This isn’t the same as regulatory approval. The FDA safety memo is specific to a particular production process used by a single manufacturer, Upside Foods, which was identified in FDA documents as process CCC 000002. The manufacturer still needs to get regulatory approval from the US Department of Agriculture (USDA) on the actual chicken product(s) before they can sell them.
Juicy Details About the Manufacturing Process
The FDA published the company’s premarket notice to the FDA on their website. A premarket notice is intended to show that a novel food is safe. And that document, all 104 pages of it, explains in detail how Upside Food makes their cultured cell chicken.
The company explains that their process occurs in two main stages. In stage one they find and choose the chicken cells that will be used to make the food. Stage two is making the food by replicating those cells in big tanks or vessels.
Stage one is called cell banking by Upside Foods. In the cell banking stage, the company prepares ‘banks’ of animal cells. The cells are isolated from healthy chickens and chicken embryos, then screened, genetically engineered (optional), tested and ‘prepared’. Hold up a minute, genetically engineered?! Yup, more on that next week.
Stage two is meat production. The company starts by making ‘media’ which is the liquid in which they grow the cells. They cultivate the cells from the cell ‘bank’ by repeating multiple generations of cultivation in the liquid media until they have enough cell mass to start turning it into muscle tissue.
At that point, the cells are moved to a tissue cultivation vessel, where the cells transform from identical cells into actual tissue, in that they differentiate to form the different cells that make the structure of a piece of muscle. The document doesn’t really explain exactly how they encourage the cells to switch from replicating mode to tissue-making mode. One assumes it has something to do with the components of the media in the tissue cultivation vessel.
When enough muscle tissue has been grown it is filtered out of the liquid and washed off, ‘de-wetted’, tested and made into food.
Food safety considerations
The company’s original premarket notification document and their subsequent answers to the FDA’s questions, which are attached to the end of the premarket notification in the online version, explain how they identified food safety hazards and how they control such hazards.
It’s all very much as you would expect for obvious chicken hazards like Salmonella and Campylobacter and avian-human viruses. And, as you would expect, any chemical hazards from growth media and cultivation vessels are both obvious and (seemingly) easy to control. Except for prions.
Big Question: What about prions?!!!!!
Prions could be in the growth media or in the animal cells themselves.
Reminder: prions are proteins that have ‘gone rogue’ and start behaving like viruses for reasons that science doesn’t fully understand. The rogue behaviour is contagious, which means that if a rogue protein from an infected animal comes into contact with a normal protein from another animal, it can turn that protein rogue as well. The rogue behaviour spreads, and this results in illness and death for the infected animal. The ‘bad’ proteins are known as prions.
Prions are very heat stable, unlike viruses, which means that even cooked animal products can be infective. Worse still there are no analytical tests for prions.
Prions are believed to cause the human diseases Kuru and Creutzfeldt-Jakob Disease (CJD) which cause fatal brain degradation. A small number of CJD cases have been caused by eating contaminated beef products from cattle that carry the disease Bovine Spongiform Encephalopathy (BSE) (‘mad cow’). It is thought that blood components, like animal serum, may act as vectors for transmitting prions.
Animal serum is used in cultured meat processes. Serum is animal blood that is absent of cells and clotting factors - the “acellular liquid fraction derived from whole blood”.
Serum could be risky. In fact, a scientific paper on the safety of cultured meat (2021) says “The most apparent safety issues may arise from the use of animal serum in the culture medium” and “cultured meat grown in fetal bovine serum-based media can be exposed to viruses or infectious prion”.
Upside Foods say they are trying to phase out the use of whole animal serum and serum constituents during the meat production stage of their process.
Potential hazards associated with the use of animal serum, according to Upside Foods, include possible contamination with mycoplasma, viruses, endotoxins, veterinary drugs, and prions (p98 of the premarket notification).
Controls for prions in serum used in cultured meat production
The company says they control hazards in serum by testing for microorganisms (but this does not include prions), filter-sterilizing the serum (which probably does not remove prions, being relatively small molecules) and that they only source bovine serum from countries that are a negligible risk for Bovine Spongiform Encephalopathy (BSE).
According to the USDA, “the risk mitigation strategies [for prions in meat and meat products] rely mainly on the elimination of tissues and organs known to harbor BSE infectivity in infected animals”. Essentially, the only way to be sure you don’t have prions in your food is to avoid sourcing from BSE-infected animals.
Controls for prions in cell banking processes in cultured meat production
The company does not include tests for prions in their cell line bank testing, even though they test for pathogens and zoonotic viruses. As a reminder, prions can’t be tested for. The good news is – and weirdly Upside Foods doesn’t mention this in their document - is that chickens seem to be resistant to forming prions, and spontaneous prion diseases don’t occur – to our knowledge - in chickens. This is good. Perhaps it is the reason why they have focussed on chicken rather than beef?
Beyond cultured chicken, what about beef?
If chicken proteins appear to be resistant to prion formation, beef products are not resistant, they are susceptible.
During cultured meat production, a single cow cell is multiplied millions of times to make human food. What if such a cell carried hidden prions? The results could be catastrophic…. unlikely to happen, but catastrophic.
Before we all freak out about prions in cultured beef, it’s worth remembering that in the past, prion diseases seem to have only been passed through food when people have eaten nerve tissue such as brain and spinal cord, or beef products contaminated with such tissue.
As far as we know, ‘pure’, uncontaminated muscle meat is much lower risk for prions than nerve tissue. But that’s not to say the risk is non-existent. This scientific paper says that the proteins that turn rogue to become prions are mostly present in nerve tissue in adult animals, but they can also be found in the intestines, heart, pancreas and liver of adult animals, and that cow embryos also contain those proteins.
With prions being impossible to test for, and resistant to, ‘normal’ controls like cooking, the fact that prions could perhaps end up in cultured beef is definitely food for thought!
Next week(s), more questions
… about:
- genetic engineering to make immortal chicken cells;
- culture media residues in cultured meat;
- does serum for cultured meat production come from foetuses; and
- the presence of bovine (cow) growth factors (‘hormones’) in chicken meat…
*the fine print: Here is the exact statement from the FDA’s Scientific Memo “Based on the data and information presented in CCC 000002, we have no questions at this time about UPSIDE’s conclusion that foods comprised of or containing cultured chicken cell material resulting from the production process defined in CCC 000002 are as safe as comparable foods produced by other methods. Furthermore, at this time we have not identified any information indicating that the production process as described in CCC 000002 would be expected to result in food that bears or contains any substance or microorganism that would adulterate the food.”
Main sources: https://www.fda.gov/media/163261/download and https://www.fda.gov/media/163262/download
Academic references (also linked above in the body of the text):
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8230205/
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6277184/
https://pubmed.ncbi.nlm.nih.gov/22674901/
🍏 Is Cultured Meat Actually Sustainable? This CNBC article from 2019 discusses 🍏
News and Resources
This selection of food safety news is handcrafted by me and free from filler, fluff and promotional junk. Click the preview box below to access it.
Not for Fun
Food safety experts, be warned, this might make your blood boil!
A young TikTok-er posted a video of herself working in a food service outlet with the caption ‘Never have gaf’ (never have given a fig?!)
The selfie video shows her describing how she just makes up food temperature records for the company’s food safety plan. Other TikTok users chimed in with similar stories:
- “I just write down a 2 degree difference from the previous temp checks”
- “I used to choose different numbers within the range,”
- “I just copied yesterdays shift lmaoooo.”
Yep, it happens. And, as anyone who has done auditing would know, it’s usually pretty easy to identify faked records, especially if they are paper records.
To stop this sort of thing from happening, food safety culture and training experts generally recommend that workers be given very frequent short micro-trainings that focus on the ‘Why’, something like this:
Why do we record temperatures? Because we need to know if food is too warm or has not been fully cooked.
Why does that matter? Because if food is too warm, or not properly cooked, dangerous bacteria can grow in the food. And that can make people sick. Food-borne illness can cause mild symptoms like diarrhoea but it can also cause serious problems like miscarriages, organ damage (like kidney failure) and death.
…. so, we record food temperatures so that we don’t accidentally sicken or kill our customers and ourselves.
…. And, we could be shut down by the authorities if it was discovered we were not recording temperatures properly.
Focussing on the ‘why’ in food safety training helps food service workers to make better decisions about whether or not to complete their tasks properly.
Source: https://www.dailydot.com/irl/panda-express-fake-temps/
Below for paying subscribers: Food fraud news, incident reports, and emerging issues, plus an 🎧 audio version 🎧 so you can catch up while on the go
📌 Food Fraud News 📌
Alert: Frozen Beef and Pork (USA)
Entire trailers full of frozen beef and pork were stolen from meat packing plants in a targeted, large-scale operation that resulted in at least 45 thefts across six states. At least one of the thefts occurred ‘this (USA) summer’, so the frozen meat, which was worth approximately $9 million, could still be available for sale in grey markets, or may have been diverted into legitimate supply chains.
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