Example: Newsletter for Paying Subscribers
An example of what paying subscribers get each week
This example contains content from past issues. Special content for paying subscribers is at the end of the email (usually behind a paywall).
Cronobacter in baby formula: what the FDA found (it’s pretty bad!)
Saffron fraud 101
Shrimp-eye tea water (just for fun)
News and Resources Roundup
Food fraud incidents, updates and emerging issues
🎧 Listen now 🎧
Hi,
Last week the US FDA shared what they had seen at the facility accused of causing fatal food poisoning from infant formula. It’s not pretty.
Also this week, I briefly consider how new supply chain due diligence laws in Europe might impact global food supply chains. Plus an update on global saffron fraud from the experts at the Botanical Adulterants Prevention Program.
My favourite new food science discovery of the week was the fish-eye water temperature method. It’s so cool, I can’t believe I haven’t heard about it before.
As always, this issue ends with a round-up of food fraud incidents and horizon scanning news for paying subscribers at the end, plus an audio version, so you can catch up while on the go.
Please keep sharing this newsletter, and feel free to reply with feedback, I read every response.
Cheers!
Karen
P.S. Click the button below to share, I don’t use subscribers’ email addresses for anything else, and you don’t get added to any other list. Ever.
The Baby Formula Cronobacter Recall: What the FDA Found
Last month I wrote about the now-infamous Cronobacter baby formula recall and hypothesised that there were hygiene issues at the production facility.
Those suspicions were confirmed. Last week the US FDA shared what they saw when they inspected the production facility in February and March. It was their third inspection of that facility in two-and-a-half years.
The recall has now been linked to a second officially acknowledged death, with possibly more to come. The US Centers for Disease Control and Prevention (CDC) is currently investigating other cases to find out if they, too are linked to the same batches of infant formula. That’s not as easy as you might imagine: healthcare providers are not obliged to report Cronobacter illnesses to the authorities in the USA.
Last week’s report doesn’t include any final conclusions about actual regulatory violations, it just shares observations. And they are not pretty.
Pathogens in the facility
The FDA inspectors found Cronobacter sakazakii on a hopper that was being used to drop small plastic scoops into containers of formula. Once inside the containers, the scoops are directly in contact with the formula.
They also found C. sakazakii on the floor near a dryer and a door in a production area.
They also found it in a spot where debris had collected between duct tape on the floor and an adjacent wall. Duct tape on the floor is a big food safety no-no. Tape and other “temporary engineering solutions” can collect food debris. The food debris allows pathogens to evade cleaning regimes and proliferate in the food, meaning more pathogens in a facility.
It wasn’t just the FDA finding Cronobacter around the factory. The manufacturer had already found it on eight occasions in 2020 and 2021 and they found it twenty times in February 2022, including in ‘high care’ areas. High care areas are areas that are critical to hygiene, often places where there is open, exposed product.
Pathogens in the product
It’s one thing to find the pathogen in a factory, but was it getting into the product? Yes. The company’s own product testing records showed that two batches from 2019 and 2020 contained Cronobacter.
GMP failures
GMP stands for good manufacturing practices.
In addition to duct tape on the floor, there were numerous leaks, condensation and standing water in the factory. The FDA proposed that one of the dryers was not being properly dried after cleaning. The report also said there were cracks and pits in the main chamber of at least two of the facility’s milk/liquid dryers.
While formula was being produced, the FDA inspectors saw workers fail to sanitise their shoes correctly before they entered production areas. Some did not sanitise their shoes at all.
The company blamed the facility contamination on building contractors who were walking on the roof and who didn’t change or sanitise their shoes before coming inside again. However, the company’s own procedures should have prevented this from happening in the first place.
Failures in consumer complaint handling
The company did not follow their own procedures for investigating consumer complaints, which include the need to test retained samples for microbial pathogens. The FDA said they treated infant death and infant illness “the same”, I assume with respect to the degree of the seriousness of the complaint. The report says the company “Closed” a complaint investigation without performing testing on product from the batch in question.
Overall
The FDA summarised their observations as follows:
- There was no system of process controls to control biological hazards
- Food contact surfaces were not “maintained to protect infant formula from being contaminated”.
Wow.
Learnings
Next week I’ll explain the challenges that manufacturers face when attempting to keep pathogens like C. sakazakii out of infant formula. And unpack why the FDA inspectors were so concerned about the leaks, condensation and other water in the facility.
In short: 🍏 One more death and possibly more illnesses have been linked to the recalled formula 🍏 An intensive investigation at the production site found hygiene problems and poor practices 🍏 Cronobacter sakazakii was found at multiple sites in the facility, months after the first death was reported and more than 3 months after the FDA first raised concerns 🍏 The manufacturer did not test retention samples of the affected batch after receiving a compliant about an infant death for that batch 🍏
https://www.cdc.gov/cronobacter/outbreaks/infant-formula.html
The FDA report: https://www.fda.gov/media/157073/download
News and Resources
No algorithm, just dedication… our news and resources are a carefully handcrafted selection from around the globe, expertly curated😎 and free from filler, fluff and promotional junk.
This week’s news includes three unusual food safety recalls.
Click the preview box below to access it.
Saffron Fraud 101
The Botanical Adulterants Prevention Program has published a new bulletin on saffron and saffron extracts. Their aim is to provide timely information on issues of adulteration, including the occurrence of adulteration, the potential consequences and the overall saffron market situation.
Here’s what you need to know. A link to the full report is provided (as always) below.
Saffron the spice is the dried stigma, part of the flower, of saffron the plant (Crocus sativus). You can see the red stigmas in the pictures.
Genuine saffron is harvested by hand, highly prized for its colour and flavour and very expensive. In fact, it is the most expensive spice and costs between USD $1,100 to $11,000 per kg. The international saffron market was worth US $430 million in 2018.
Saffron trade is complicated. Saffron’s most important growing areas are in Iran, Greece, Morocco and India. Afghanistan and Spain are also important sources of saffron. Saffron labelled Spanish is mostly grown in other countries but packed in Spain. Iran accounts for most global production at 90% – 93% but only accounts for 40% of direct global exports, according to the report (confusing!), apparently because the Iranian saffron is resold by other countries.
With so much of its production in one country, and with a short harvesting season, saffron supply is extremely vulnerable to weather events. For example, there was a tripling of prices from 2006 to 2009 because of heavy frost in Iran in 2007. Climate change is a threat, with increased moisture in some areas leading to more fungal plant diseases, and drought in other areas limiting yields.
Saffron fraud
Saffron is one of the most frequently adulterated foods.
Powdered saffron is more at risk than whole saffron.
The biggest food safety issue with saffron fraud is probably the use of synthetic dyes to boost the colour of fraudulent whole saffron and saffron powder. Sudan I-IV and Rhodamine B dyes have been found in saffron and are considered potentially genotoxic and carcinogenic.
Adulterants in whole saffron
Here are some of the things that are added to saffron to fraudulently increase its value.
Parts of saffron flowers, including the yellow style and the white style.
Filaments from other plants, including corn fibres, safflower stigmas, calendula stigmas, pomegranate fruit fibres
Filaments from other sources including silk. Adulterant filaments may be dyed with plant dyes including beetroot, pomegranate, fruit peel.
Liquids that are added to increase weight, including oils, glycerin and honey
Dyes and aroma compounds as listed below
Adulterants in saffron powder
Here are some of the things that are added to saffron powder to fraudulently increase its value.
Turmeric powder
Paprika powder
Ground seeds of sweet fennel, or annatto
Dried marigold flowers
Gardenia (Cape Jasmine) extract, for their crocetin esters which are also in saffron
Natural dyes from flowers and roots
Artificial dyes including erythrosine, ponceau 4R, tartrazine, Sudan dyes, magenta III and rhodamine B
Safranal, which is a synthetic aroma compound
Also, there are historical reports of fillers added for increasing the product’s weight, including chalk, gypsum and heavy spar (barium sulfate)
Other types of fraud (non-adulteration-type fraud)
Selling Philippine saffron or “saffron flowers” as if they are real saffron (C. sativus). They are instead safflower or kasubha.
Exhausted saffron sold as whole saffron
Coloured paper shreds sold as saffron
Provenance fraud, in which the geographical origin of the saffron is misrepresented
Saffron testing
Testing is a challenge. Microscopic inspections can be done on powdered as well as whole saffron, but they are time-consuming and expensive. In addition, visual examinations won’t necessarily recognise adulteration with colourants or safranal.
Some DNA-based tests struggle to differentiate safflower from saffron, because they are closely related. DNA tests also don’t find safranal or dyes. Spectroscopic methods can be simple and quick but they are not very sensitive and won’t pick up all adulterants. There are many other authenticity test methods, each with its own challenges. It is recommended that a suite of complementary tests be used to cover all types of adulteration and fraud. Provenance testing has been successfully done using stable isotope methods.
Shrimp-Eye Tea Water (Just for Fun)
Oh I just love this!
Often in cooking, we need water to be at 100 degrees, which is fully boiling. (That’s 212 F for non-metric readers!) Except when we are steeping tea. Delicate green teas taste best when steeped at temperatures lower than boiling. So if you don’t want to use a thermometer every time you make tea, what should you do?
The Chinese are on to it.
Introducing the fisheye water temperature method. It has been used for almost a thousand years. Yep, one thousand. It was recorded in a Chinese book published in 1049. And it’s a doozy.
In this method, the bubbles in a pot of heating water are described by comparing their size to the eyes of sea creatures. So shrimp-eye sized bubbles are the little bubbles that form first on the bottom of a pot. Crab eyes form next, then fish eyes, which start to rise from the bottom of the pot. Next up is string of pearls, a steady stream of bubbles, then raging torrent.
🍏 Shrimp eyes occur at about 70 degrees (155 F). Use this temperature for steeping delicate and very fine-leafed green teas.
🍏 Crab eyes occur at 80 degrees (175 F). For delicate oolongs and white teas.
🍏 Fish eyes occur at 85 degrees (185 F). Use this temperature for oolong teas and some delicate black teas.
🍏 String of pearls temperatures are 90 – 95 degrees (200 F). This is perfect for aged teas and whole leaf black teas.
🍏 Raging torrent is fully boiling water, 100 degrees (212 F). Use it for strong black teas and herbal teas.
Thanks to @Botanygeek (James Wong), a science writer on Twitter for opening my eyes to the fish eye temperature method!
******* Paywalled Content Below This Line *******
Below for paying subscribers: Food fraud news, news of emerging issues and food fraud incident reports
«Example»
📌 Food Fraud News 📌
An Unusual Milk Fraud Has Been Discovered
A fraudulent milk supply operation was uncovered after an inspector found a second hidden tank in a milk transport truck. The second tank allowed for the milk to be diluted with extra water, by remote control, after it passed quality inspections but prior to its unloading at the customer’s site - Italy 18/02/2022
Horizon Scanning (News of Emerging Risks)
Sustainability and Ethical Claims
Ethical and sustainable practices in global supply chains will be impacted by a new supply chain due diligence law in Germany. The law requires German companies of a certain size to investigate their supply chains and take adequate measures to prevent or mitigate human rights risks and environmental risks. This new law could motivate suppliers to become less transparent and more clandestine about unethical practices in order to protect their business with German companies. Child labour, which is important to some food-producing communities in developing countries, is one area where local and international rules may disagree – Global 08/08/2021 https://www.jonesday.com/en/insights/2021/08/the-impact-of-french-and-german-esg-due-diligence-laws-on-business
Sunflower oil
Sunflower oil is at heightened risk of food fraud due to supply constraints and very high prices. These have been caused by the Ukraine war. Ukraine is the world’s largest exporter of sunflower oil. India is one market that will be affected, being a net importer of edible oils, with sunflower making about 10% of all oils consumed in India.
Food Fraud Incidents in Brief
Pickled turnips from Lebanon have been found to contain the unauthorised colourant rhodamine B by Germany - Europe 17/03/2022
https://webgate.ec.europa.eu/rasff-window/screen/notification/538025
A large criminal network that was making counterfeit wines and spirits of brands Penfolds, Hennessy, Martell and GreatWall was uncovered after a consumer complained about the poor quality of a bottle of Penfolds they purchased. The brand owner investigated and found it was a ‘fake’ that had been purchased from an unlicensed retail outlet – China 27/03/2022
A factory making fake or adulterated honey containing sugar, molasses and syrup was discovered by authorities – Cameroon 29/03/2022
Illegal chicken raising and egg trading was uncovered and eggs were seized (16,720). The activities were in contravention of avian flu control measures and the eggs were untraceable – Italy 04/03/2022
https://www.antennasud.com/influenza-aviaria-sequestri-nas-galline-uova-lecce/
Sumac spice adulterated with the unauthorised and carcinogenic colourant Sudan IV has been reported by Germany 10/03/2022
https://webgate.ec.europa.eu/rasff-window/screen/notification/536362
Tea powder alleged to be coloured with unauthorised substances including Persian blue, Bismarck brown or indigo colour has been reported in media - India 11/03/2022
https://www.daijiworld.com/news/newsDisplay?newsID=935595
Paying subscribers can access a searchable list of food fraud incidents. Any incident we list here in the weekly email is also copied into the searchable list.
🍏 That’s all for this week,
I’m off to boil some shrimp for dinner. Hope, I don’t get myself into hot water. Bye!
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