Issue #15 2021-11-22

An important warning on a new food fraud risk. Plus should we be worried about the new auditor benchmarking scheme from GFSI?

  • FDA publishes new food fraud info

  • Salmonella on the loose in USA and UK (how does it get inside whole fresh onions?)

  • New auditor benchmarks set by GFSI: should we be worried?

  • A potentially deadly emerging food fraud risk: take heed!

  • Food fraud incidents and horizon scanning updates from the past week


Welcome to Issue 15 of The Rotten Apple, food integrity news for busy people.

When the world’s leading food fraud guy warns us about a new food fraud risk, we’d better sit up and pay attention. Professor Chris Elliott of Queens University Belfast has published a warning about a ‘new’, potentially deadly fraud type. Sadly, it’s happened before, but no one was warning us about it back in 2007… This time, we have no excuses. Read on for the low-down.

Also this week; I explain how whole raw onions can cause a massive Salmonellosis outbreak and examine the new GFSI rules for auditors. I read the whole four-part, hundreds-page-long GFSI benchmarking requirements, so you don’t have to (you’re welcome!)

As always, this issue ends with a list of food fraud incidents from the past week.

Thanks for reading,


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Food Fraud

New US FDA resources

The US FDA has published a new resources and guidance page for food fraud.

It includes examples of food fraud, links to research papers and instructions for how to report food fraud crimes in the USA.

See it: 🍏 🍏

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Food Safety

Raw onions and pork snacks cause big Salmonella outbreaks (but how, exactly?)

Five months after the first illness, a raw onion Salmonella outbreak in the USA is still going.  Almost 900 people from 38 states have been infected with the outbreak strain of Salmonella oranienburg. 

The food source is fresh, whole onions that were imported from Mexico during July and August.  The CDC investigation notes say the first illness was 31st May, which is a full month before the affected imports.  Odd!

People are still coming forward with illnesses and more than 180 have been hospitalised in the onion outbreak so far. This is no doubt in part due to the long shelf life of fresh onions. Recalls began in mid-October.

How does Salmonella get into onions?

Salmonella’s presence in terrestrial foods is generally attributed to contamination from poor hygiene practices. It can be found in human and animal faeces as well as wastewater, sewerage and run-off from fields where animals have been grazing. Fruit and vegetables can become contaminated with Salmonella through contact with contaminated water, both before and after harvest.

Sources of pre-harvest exposure are contaminated irrigation water, flood water or run-off from local farms or feedlots. Some plants, including onions, can ‘internalize’ Salmonella after being exposed to contaminated water while growing in the fields.  

Raw onions have been associated with Salmonella illnesses before, however, it is rare for raw onions to contain enough Salmonella to make people sick.

Pork snacks break records (not in a good way)

On the other side of the Atlantic, another large Salmonella outbreak is being investigated.  This time it’s Salmonella infantis in pork scratchings (a cooked pig rind snack). With more than 500 people sickened, this is thought to be the largest European outbreak of S. infantis on record. 

As with the onions, the pork snacks have a long shelf life which could have contributed to the long duration of the outbreak; the first illness was reported in September 2020 but most people were sickened after June 2021.  The recall commenced in August 2021.  

Investigators think the Salmonella might have been present on the pork rind.  As pork scratchings are cooked, it might be that the products were re-contaminated after cooking, perhaps from surfaces or people that had contacted raw ingredients.  

In short: 🍏 Two unrelated large outbreaks caused by Salmonellae species are underway in USA and UK 🍏 The food sources are a bit different than usual 🍏 Both foods have long shelf lives 🍏

Main sources:

Sources re Salmonella internalization and previous Salmonella onion outbreak:

Food Safety Industry

GFSI Benchmarking for auditor recognition… should we be worried?

What is it?

The new GFSI benchmarking scheme is designed to harmonise standards for auditors across the food industry, and – GFSI says – encourage more people to take up the profession.

How will it work?

GFSI says they will use this scheme to make food safety auditing a career that is accessible, attainable and desirable.

Should we be worried?

Concerningly, GFSI says in its press release that requirements are currently too “stringent and specific”, which it says “narrows the field of potential recruits”.  It sounds like they want to relax the requirements so the industry can get more (cheap!) auditors.  While that is not a bad thing in itself, the broad set of food safety and food science skills needed for good auditing is not something that can be attained quickly or easily.

Auditing to a checklist is (mostly) easy.  Except the important part, which is hard.

At the core of all food safety systems is a plan built on the principles of HACCP.  An effective food safety audit includes a review of that plan.  The review doesn’t (shouldn’t) just check that the plan is being followed.  The auditor must check that the plan has been constructed effectively, with all pertinent hazards included and appropriately controlled.  It takes ‘stringent and specific’ skills to do that.  And it is bloody hard.  So, yes, if auditor rules are relaxed and less expert auditors review food safety plans, we should be worried: get a HACCP plan wrong and people will die.

What are the new requirements?  

The GFSI benchmarking requirements need to be met by Professional Recognition Bodies.  These are certification bodies that certify auditors as qualified and competent.  They are not training organisations and they must be ‘impartial’ with respect to other food certification activities.  

The requirements are quite intense, both for the professional recognition bodies and for the individual auditors themselves.

I’d say the new auditor requirements appear at least as stringent and difficult as the current requirements – at least those I am familiar with.  I would be surprised if they result in auditing becoming more accessible or attainable as a career, as hoped by the GFSI. In addition, the benchmarking process is likely to add to the cost of running a professional recognition body; costs which will no doubt be passed to their customers, the auditors. And that might further reduce the accessibility for would-be auditors.

When will the new benchmarking requirements affect me and/or my auditors?

The GFSI has not yet published any dates for implementation, saying instead that the new auditor system is in consultation about transition processes.  It is also not clear whether benchmarking will become mandatory.  My guess is that any concrete changes are at least 2 years away.

In short: 🍏 New auditor benchmarking requirments have been released by the GFSI 🍏 The new requirements seem relatively stringent and seem unlikely to reduce auditor competence in most countries 🍏 No implementation dates have been published 🍏 It is unclear if benchmarking will be mandatory 🍏

Get access to the benchmarking requirements here:

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Food Fraud

A new risk for plant-based foods?

You’ve all heard of the melamine in baby milk scandal, right? Three hundred thousand babies had their kidneys injured in China because greedy people added melamine to the milk powder used by the baby formula companies.

Why melamine?  Because it is rich in nitrogen, and the nitrogen content of milk is used to estimate its protein content.  More nitrogen = more “protein” = higher prices: the melamine increased the selling price of the milk.

Most people don’t know that there was a deadly precedent.  The year before the baby milk scandal, American investigators discovered melamine in plant proteins after thousands of pets died from eating contaminated pet foods.  Wheat gluten and rice proteins from China used in cat and dog foods had been adulterated with melamine.  Why?  To boost their apparent protein content.

So, by the time the baby milk problems came to light, it was already known that toxic melamine was an adulterant for ‘tricking’ protein tests.  If only someone had warned the world about protein-melamine fraud before all those babies got sick*!  What a horrible, horribly-preventable tragedy. 

But who was there at the time to make the warnings?  And would anyone have listened anyway?

Now the marvellous Chris Elliott, granddaddy of modern food fraud prevention initiatives, writer of the highly regarded Elliott report on the European horsemeat scandal and founder of the world-leading Institute for Global Food Security at Queen's University Belfast has issued a new warning: Melamine-like substances in plant proteins are an emerging food fraud (and food safety) risk.

Elliott says the risk can be attributed to:

(a) the ‘soaring’ prices of plant proteins due to increasing demand for plant-based foods and supply shortfalls from crop failures

(b) the form of the proteins when sold to plant-based-protein-food manufacturers: pale-coloured powders (uh oh!)

(c) the purchasing criteria: protein content is a key driver of price. 

There are tests for melamine.  Unfortunately, Professor Elliott says there are more than 60 other widely-available, low-cost materials that could be used to fraudulently increase the nitrogen content of plant powders. Sixty other materials that could evade the melamine tests.  He also suggests that the supply chains of alternative proteins are alarmingly opaque.

This is not good news.

When Chris Elliott warns the food industry about a looming food fraud risk, we’d better sit up and pay attention.  The risk is credible, the consequences are potentially deadly.  If you work with plant proteins or plant-based foods, beware!

In short: 🍏 Professor Chris Elliott has warned about a new food fraud risk for plant proteins and plant powders 🍏 The risk is adulteration with unauthorised nitrogen-containing industrial chemicals to boost protein content 🍏 The risk is credible and the consequences could be severe 🍏 If you work with plant proteins or plant-based foods, take heed 🍏



Food Fraud Incidents and Horizon Scanning

Food fraud incidents added to Food Fraud Risk Information Database in the past week

The licensee of a wholesale company has been fined for illegally importing fresh and processed fruit and vegetables without proper permits – Singapore  17/11/2021

Horse meat from unauthorised slaughterhouses has been sold by an alleged crime group to an estimated 60 percent of hamburger establishments and restaurants in a city in Southern Brazil. The operation is estimated to have involved the sale of 800 kg of meat each week for up to seven months – Brazil  20/11/2021

An importer of can lids has been accused of fraud by authorities that claim they mislabelled the lids as “other articles of iron or steel’ to avoid an import levy on metal can lids from Europe.  The alleged tariff fraud is said to have been perpetrated on 543 shipments worth over $51m over a five year period – USA  18/11/2021

Food fraud horizon scanning (other updates to the Food Fraud Risk Information Database in the past week)

A highly regarded food fraud expert has warned of a deadly new emerging food fraud risk. The risk is that plant proteins and powders will be fraudulently adulterated with nitrogen-rich non-food materials to boost their apparent protein content.   17/11/2021.  More details above.