Issue #13 2021-11-08
Failures in ethical certifications for cocoa and alien corn
Cannabis edibles follow up
Ethical certifications: ineffective for cocoa?
Preventive controls for arsenic in baby food
Just for fun; mouldy corn that looks like a tumour, but - apparently? - tastes great
Food fraud incidents and horizon scanning updates from the past week
Hi,
Welcome to Issue 13 of The Rotten Apple, it’s wonderful to have so many of you signing up to stay on top of food integrity news in less than five minutes per week.
This week: how do ethical certification schemes make sure cocoa farmers comply with their standards… (the answer is disappointing). Plus, why is the USA’s preventive controls rule not working for chemical hazards in baby food? And mouldy corn that’s (supposedly) super-tasty.
Also, food fraud incidents and horizon scanning updates.
Thanks for reading, and for sharing with your network.
Karen
Food Safety
Cannabis edibles; authorities take the risk seriously
In a brief follow up to my piece last week about the risk of cannabis edibles that look like ordinary confectionery….
Irish authorities seized thousands of (illegal) chocolate bars containing psychoactive cannabis compounds just before Halloween. Nice one.
Read more:
Ethical Supply Chains
Can you trust ethical certifications?
Hershey and the Rainforest Alliance have been sued for false advertising in the US, because of the prevalence of child labour in the supply chain and the fact that the certification scheme doesn’t seem to prevent it.
Certification schemes like Rainforest Alliance and FairTrade are supposed to give assurance of ethical work practices in the production of the certified foods. Seems like they are not working.
Part of the problem is that certification schemes don’t include widespread auditing of cocoa farms – the very places where slavery, forced labour and child labour is happening.
I worked for many years in a certification business so I’m familiar with the challenges of auditing multiple sites. It would be commercially unviable to have expert external auditors visit each of the (tens of?) thousands of cocoa farms all over Ghana, Cote d'Ivoire that are covered by their schemes.
I always wondered how certification schemes like the Rainforest Alliance and Fair Trade verify that the cocoa farmers meet their anti-slavery standards. Turns out they (mostly) don’t, at least according to a 2018 report (source, as always below). Researchers for that report spoke to workers on certified cocoa farms in Ghana who reported appalling forced labour work conditions.
Some farmers were aware that certification schemes require them to meet more stringent labour standards, but reported that the extra premium they receive per bag of beans was not enough to cover the costs of meeting the standards. So they just didn’t bother. Other farmers didn’t understand the difference between certified and un-certified beans at all.
At least one certifier who was interviewed for the report said “‘We are working with around 11,800 cocoa farmers, so we have not been able to visit any farms as of now”. They relied on workers from the farmers’ cooperative to verify the working standards at the farms. It is the cooperatives that are certified, which creates a serious conflict of interest. The cooperatives receive a premium for certified cocoa, compared to uncertified cocoa. And they self-report that their farmers comply with standards for certification. Not good.
What does this mean for food brands? It means there are easy-to-find instances of forced labour, child labour and other modern slavery practices in their cocoa supply chains, even if they purchase only certified cocoa.
What’s the answer? I wish I knew. The consumer group that is behind the most recent litigation (and there have been many similar lawsuits over the years), says that cocoa and confectionery companies need to pay more for cocoa… which might help but wouldn’t necessarily result in farmers treating their workers better, or not hiring children. Meanwhile, big confectionery makers remain vulnerable to being accused of ‘false advertising’.
In short: 🍏A chocolate company has been sued for having child labour in its supply chain 🍏 The certification scheme that is supposed to ensure that labour practices are ethical is accused of failing 🍏 Investigators report appalling work conditions in major cocoa-growing countries 🍏 Big confectionery brands are vulnerable to accusations of forced labour 🍏 There are no easy answers 🍏
Sources:
Food Safety… Baby Food Again….
Part 3: Are preventive controls enough?
In the past two weeks I have written about the on-going problem of arsenic and other metals in baby foods. The US House of Reps has called for the FDA to require finished product testing of baby foods. But that shouldn’t be needed if the preventive controls rules of the Food Safety Modernisation Act (FSMA) rules are working. What’s going on?
This week: why are these known hazards not being dealt with using preventive controls?
To recap, baby food in the US has been repeatedly found to contain unsafe levels of toxic heavy metals. According to a House of Representatives Report, some food manufacturer’s ingredient and product testing systems are lax or non-existent. Recent testing by Alaskan authorities led to recalls of some products, however, not all the ‘dangerous’ products they identified were recalled.
Inorganic arsenic, the main metal of concern in these recent cases, occurs naturally in rice which is a common (or main) ingredient in many baby foods. Just to be clear, there are no accusations of deliberate adulteration.
What are preventive controls?
Preventive controls – outside the US we more commonly call it HACCP* – is a system whereby you identify hazards that might occur in the food you are making; you then decide whether those hazards present a significant risk to consumers; and then you control the hazards that present a significant risk. The controls – ‘preventive controls’ - are actions that you take as a food company to reduce or eliminate the hazard while you are making the food. A common ‘control’ is cooking food to reduce microbial hazards that are present in the raw ingredients. The cooking reduces the risk to consumers.
Preventive control systems are a legal requirement for food manufacturers in the USA (and pretty much everywhere else in the world, under different names).
Do preventive controls work?
Yes. Which is why systems based on prevention, including preventive controls and HACCP are used and mandated everywhere.
So why arsenic in baby food?
I like to believe that food manufacturers who use rice as an ingredient in baby food are aware that arsenic can be found in rice, and that this, in food safety parlance, is a chemical hazard.
If a high level of arsenic is present, there is a risk to consumers. A properly designed and operated preventive controls program would recognise this risk and set up procedures to control the hazard so that it is not present in hazardous levels in the finished product.
Preventive controls and HACCP systems are intended to negate the need for every-batch finished product testing.
For naturally occurring hazards like arsenic in rice, the usual preventive control would be for the food company to set limits for incoming ingredients, test those ingredients often and have procedures for managing ingredients with higher concentrations of the hazard.
If the limits and procedures are set correctly, then the finished products will always be safe. However, according to the US House of Representatives report, at least one company is using procedures that “grossly underestimate” the heavy metal concentrations in the finished products100% of the time, by between 28% and 93% percent. At that company at least – and it is named in the report - something is going very, very wrong.
The report complains that the practice of testing incoming ingredients is not working and that companies should also be doing finished product testing.
However, this goes against the whole intention of the FSMA preventive control rules.
What should be happening?
Preventive controls systems (HACCP-like systems*) do work when done properly. The failures in the baby food preventive controls systems – and by law every baby food manufacturer should have such a system – could be due to a whole suite of problems, and different or each non-compliant manufacturer.
Problems I’ve seen in food safety systems include a lack of expertise in setting limits for hazards in incoming raw materials; inadequate procedures for managing raw materials with high concentrations of chemical hazards; validation of processes being done incorrectly (or not at all); problems not being picked up due to a lack of inspection and auditing; insufficient raw material testing due to the high cost of testing.
More worryingly, there have been cases of food companies that knowingly ‘fiddle’ with laboratory test results so that they can ship products that are non-conforming (Peanut Company of America is an example).
Unfortunately, many of these failures can ultimately be traced to low prices paid by big food retailers and the financial pressures felt by food manufacturers.
Every manufacturer who has had a high level in their finished goods needs a complete re-do of their preventive controls for chemical hazards in incoming ingredients. They need a competent team of expert internal and external food safety professionals to: (1) re-assess acceptable limits for incoming materials (2) recalculate ‘worst case’ finished product concentrations based on actual batch/run sizes (3) add margins of error (4) calibrate internal test results with accredited labs (5) check that test methods are appropriate and the same as those used by enforcement authorities (6) validate the new procedures under ‘worst case’ conditions (7) repeat until finished product concentrations are acceptable.
Next week: What are acceptable limits for heavy metals in baby food?
* HACCP nerds: I’ve oversimplified, sorry (not sorry!)
In short: 🍏 Baby foods in the USA contain too much naturally occurring heavy metals, including arsenic 🍏 The government is calling for the FDA to mandate finished product testing 🍏 When preventive controls systems work properly, every-batch finished product testing should not be needed 🍏 Manufacturers with problematic finished products need to overhaul their preventive controls (and HACCP) systems 🍏
Source (Peanut Company of America):
https://en.wikipedia.org/wiki/Peanut_Corporation_of_America
Source (US Government report):
Weird Food of the Week
Looks like a tumour, tastes great!
Huitlacoche is a Mexican delicacy. It’s a food that is formed from an infection of corn by the fungus Ustilago maydis which causes individual corn kernels to expand.
Huitlacoche s said to taste earthy with a hint of sweetness. It’s eaten as a filling in quesadillas and other tortilla-based foods, and in soups.
Learn more: http://www.aquiestexcoco.com/what-is-huitlacoche/
Food Fraud Incidents and Horizon Scanning
Food fraud incidents added to Food Fraud Risk Information Database in the past week
Restaurants have been fined for selling 'substandard' food with authorities checking for unauthorised colourants and problematic paneer, vegetable oil and khowa ahead of a major festival - India 03/11/2021 https://www.telegraphindia.com/jharkhand/diwali-food-raids-in-ranchi-see-10-eateries-fined-rs-1-65-lakh/cid/1837129
Counterfeit Nescafe Instant coffee has been discovered at small retail outlets and markets in Germany and The Netherlands. The products are in a no-longer-available shaped jar and may contain dangerous plastic or glass contaminants - Europe 1/11/2021 https://www.securingindustry.com/food-and-beverage/counterfeit-nescafe-gold-coffee-found-in-germany/s104/a13946/
Fish labelled 'swordfish' from open air markets and fish markets has been found to shark meat in 9% of cases. The shark species are vulnerable and/or endangered - Chile 15/10/2021 https://www.sciencedirect.com/science/article/abs/pii/S0956713521007453
Colourants for dyeing textiles and that are not safe to eat continue to be found in sweets in India. This type of adulteration is included in the 18% of foods that authorities found to be substandard in recent testing (n = 1,882) - India 2/11/2021 https://www.tribuneindia.com/news/punjab/18-of-food-items-tested-in-punjab-in-3-months-adulterated-333538
A spice wholesaler has been arrested after tests showed he was selling cumin seeds adulterated with sulfa seeds. Sulfa seeds are cheap and unsuitable for human consumption - India 29/10/2021 https://www.telegraphindia.com/my-kolkata/news/trader-arrested-from-burrabazar-on-cumin-adulteration-charges/cid/1836396
Food fraud horizon scanning (other updates to the Food Fraud Risk Information Database in the past week)
There are more and more reports that grains are being more often contaminated with mycotoxins. It is said to be due to climate change, which is making some areas wetter and more humid, which predisposes crops in those areas to moulds. The reported increase is possibly also be related to increased surveillance and more sensitive testing. Fraud risks include forged laboratory reports and faked import/export paperwork. 03/11/2021 https://www.tandfonline.com/doi/full/10.1080/10408398.2019.1658570
The Food and Agriculture Organisation’s Food Price Index is up again and at its highest in 10 years. This has been driven by high prices for all major cereals, particularly wheat, and the vegetable oil index hitting an all-time. Increasing prices can lead to increased likelihood of food fraud. 4/11/2021 https://news.un.org/en/story/2021/11/1104962
Here’s what you missed in previous issues…
Highlights of Issue #7
Hairy crabs: Hairy crabs are a prized seasonal delicacy. The high price and limited supplies of the ‘best’ hairy crabs make them vulnerable to food fraud. A bar-code-based fraud prevention system for Yangcheng Lake crabs was counterfeited by food fraud criminals in 2016. This year there are claims that hairy crab gift vouchers (coupons) are affected by fraud 🍏
‘Space-age’ food production: New research reveals that using solar as the input for high-tech single cell protein production is more energy efficient than growing conventional crops. Land use efficiencies are (unsurprisingly) also better 🍏