128 | Food Safety Roadmap | Insect Proteins: High Risk? |

Plus, photo competition winners, and dates for our next meetup

• Save the date: Meet-up on Thursday 14th March;

• Stay Ahead of the Curve: A Road Map for Implementing New Audit Standards;

• Insect-based Foods and Food Fraud;

• Food Safety News and Resources;

• Photo competition winners;

• Food fraud news, emerging issues and recent incidents

🎧 Listen 🎧

Insect-based foods are coming to wealthy countries in a big way, if the authors of a new paper are correct (I’m not so sure, if I’m honest!). Demand is forecast to increase dramatically in the coming years. And with increased demand comes more potential food fraud and food safety issues.

Welcome to Issue 128 of The Rotten Apple. Our March meetup is on Thursday the 14th, save the date. Everyone is welcome, so do come and say hi. In past meetups, the number of attendees has been quite manageable but in future, I might need to restrict attendance, so join us while you can.

This week’s issue has insect-based food fraud risks, plus a roadmap to help you navigate changes to auditing standards (and stay sane in the process). And I announce the winner of last week’s photo competition.

Have a wonderful week,

Karen

P.S. If you love this newsletter, please tell your friends and colleagues about it and help grow our community of global food safety champions.

Cover image: pvproductions on Freepik

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Save the date: Meetup 14th March, 2024

In 2024 we’re having monthly meetups. The next one is next Thursday 14th March. Everyone is welcome.

Get details here.

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Stay Ahead of the Curve: A Road Map for Implementing New Audit Standards

Food safety management systems standards are in a constant state of review and revision. Or at least that’s how it feels to most food safety professionals.

While standards owners may imagine they are making updates to reflect emerging food safety risks or align with new scientific breakthroughs, changes to standards often seem like nothing more than exercises designed to increase the workload for auditors and food business employees.

If you’re on the front line of food safety system management, it’s natural to feel frustrated and overwhelmed when the standards you are audited against are updated.

Later this month I’ll explore the new requirements in the latest version of FSSC 22000 (version 6) which has a fast-approaching implementation date.

Today, I’ll share a roadmap for implementing updates to food safety standards that will reduce overwhelm and prevent last-minute pre-audit panics.

Another update to the standards: more work for food safety managers and auditors. Image by wavebreakmedia_micro on Freepik

The roadmap: best practices for implementing management system updates

Step 1: Gap analysis

Start by performing a gap analysis to discover what’s changed in the new standard, what you’re already compliant with and what you are not yet compliant with.

What you need:

• The updated standard;

• List of changes - this can usually be obtained from the standard owner’s website;

• Enforcement dates and audit dates.

Step 2: List of actions

Next, create a list of changes you will need to make to your system compliant with the new standard. Add a target completion date for each change.

Add each action to your corrective and preventive actions register, creating a separate action for each item so you can action them separately.

Step 3: Work through the list

Work on the preventive actions by updating or adding programs as needed.

What you need:

• Your corrective/preventive actions register.

Step 4: Internal audit

For each element that has changed, conduct a formal internal audit, documenting the process and the findings.

Step 5: Meeting agenda updates

Update meeting agenda templates to include new elements. Meeting minutes can be used to show your auditor that changes have been communicated up and down the management chain.

Step 6: Extra resources?

Consider using an external consultant to verify the changes are compliant with the new standard, or assist with creating and implementing the new requirements.

Step 7: Celebrate success

Feel confident and prepared for the first audit to the updated standard, knowing that your business is compliant and all new requirements have been successfully implemented. Well done. ^🎉

Sources and further reading

• This post was inspired by FSSC 22000 Version 6 (webinar), Intertek Alchemy, January 2024

• Read more: 🍏 How to Make an Internal Audit Checklist 🍏

• Read more: How To Prepare For A BRC Audit (foodonline.com)

• Read more: What Are The 8 Major Steps to Prepare For An SQF Audit? - FoodReady

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Are Insect-based Foods Vulnerable to Food Fraud?

A new paper with the stated aim of exploring the food fraud and food safety risks of novel insect proteins makes a big claim about food fraud in insect-based human food supply chains.  Namely, novel insect proteins are at high risk of food fraud. 

Novel insect proteins are at high risk of food fraud, according to a newly published review

But are they really at high risk of fraud?

Within the peer-reviewed journal article where this “high risk” claim was published, the food fraud commentary was marked by contradictions. The authors also state that the food fraud vulnerability of insect foods “has not yet been reviewed” and say there is no evidence of fraud within edible insect industries.

So how was the “high risk” conclusion reached?

The information about food fraud risks in insect-based foods was sourced from interviews with four people from food companies and one entomophagy (eating-of-insects) researcher.

The insect supply chain in EU is very complex. Source:  Traynor et al (2024)

Based on the interviews, a number of vulnerabilities were inferred and are described in the paper. I have summarised them below.

Factors which are likely to make insect proteins vulnerable to food fraud:

• The global sourcing of insects, which results in complex supply chains. For example, most European insect companies import whole insects for processing, rather than raising them in the EU.

• Forecast increases of 400% in EU consumption of insects by 2030, with the rapid expansion of the industry leading to vulnerabilities related to regulatory gaps and a lack of guidance for food businesses for novel protein foods.

• The high cost of insect proteins compared to other protein sources.  For example, cricket protein powder is 30%  more expensive than whey and more than double the price of pea isolate and soy protein isolate.

• The form of finely powdered insect proteins lends itself to easy adulteration and dilution.

• A test-related factor: the Kjeldahl method for protein overestimates the protein in insect products due to the non-protein nitrogen in insect exoskeletons. 

Potential fraud activities in insect-based food supply chains include:

• Misrepresentation of geographical origin.

• Misrepresentation of nutritional composition.

• Misrepresentation of processing/production methods.

• Misrepresentation of species. This could cause major food safety risks, as some insect species are more likely to cause severe allergic reactions than others, particularly for consumers who have a crustacean allergy.

• Document fraud such as fraudulent traceability or false documentation about feed substrates.

• Adulteration with chemicals such as melamine to boost the apparent protein content. This would cause major food safety risks.

• Dilution with fillers such as sawdust or lower-cost proteins such as soya – also a major food safety risk from allergens.

• Undeclared biocides, pesticides or veterinary medicines.

• Counterfeiting: unauthorised use of trusted brand names on insect-based foods or ingredients.

• Processing to incorporate groud insects into familiar foods (insects as adulterants)

Food fraud mitigations for insect-based materials

In Europe, there is a stringent process for the authorisation of edible insect products for sale as human foods, and novel foods require company-specific authorisations in the EU.  This may act as a protection against food fraud in insect foods in Europe.

Takeaways for food professionals

While there are no reported cases of food fraud in insect-based food ingredients or products, it could occur.

Insect-based protein powders could be adulterated with nitrogen-containing chemicals such as melamine to increase the apparent protein content or diluted with cheaper plant-based proteins (which pose allergen risks) or non-nutritive fillers such as sawdust.

Insect-based foods present risks to crustacean-allergic consumers due to allergen cross-reactivities, with the risk profile varying between insect species.  Therefore deliberate or accidental swapping of species could create serious risks to allergic consumers.

In short: 🍏 Insect-based ingredients and products have complex supply chains and this could make them vulnerable to food fraud 🍏 Other vulnerabilities are related to their high price, high protein content, powdered forms and increasing demand 🍏 Dilution and substitution-type fraud in insect-based foods poses serious food safety risks due to the possible use of allergenic diluents or substitution with insect species that are more allergenic than the labelled species 🍏 Adulteration-type fraud in insect-based protein powders poses serious food safety risks if melamine-like substances are used as adulterants 🍏 Insect powders could be used as adulterants in other foods, and could give false high protein readings because of the presence of non-protein nitrogen in insect exoskeletons 🍏

Source:

Traynor, A., Burns, D.T., Wu, D., Karoonuthaisiri, N., Petchkongkaew, A. and Elliott, C.T. (2024). An analysis of emerging food safety and fraud risks of novel insect proteins within complex supply chains. npj Science of Food, [online] 8(1), p.7. doi: https://doi.org/10.1038/s41538-023-00241-y .

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Food Safety News and Resources

Our news and resources section has not-boring food safety news plus links to free webinars and guidance documents: no ads, no sponsored content, only resources that I believe will be genuinely helpful for you.

This week’s head-scratcher: the maker of raw milk cheese linked to multiple serious foodborne illnesses cancels its recall

Click the preview below to access it.

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Photo Competition Winners

The winner of our photo competition is Heather D from the United States. Heather and her team identified a whopping twenty-three non-conformities in the photo. Wow!

Heather, a pack of stickers is on its way to you, congratulations.

I’ll be sharing all the non-conformances and discussion points in the photograph as a downloadable food safety training exercise later this month.

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Below for paying subscribers: Food fraud news, horizon scanning and incident reports

📌 Food Fraud News 📌

In this week’s food fraud news:

📌 Suspected cat and dog meat seized;
📌 Mislabelling in sushi and sashimi;
📌 Paprika analysis, glyphosate in tea;
📌 Dog food brands accused of misleading pet owners;

📌 McDonalds accused of fraud over cheese analogues.

A person has been arrested on suspicion of serving dog and cat meat in an unlicensed restaurant