164 | Food Fraud Special | Verification | Teams | Questions |

Verification, food fraud teams, underweight issues

This is The Rotten Apple, an inside view on food fraud and food safety for professionals, policy-makers and purveyors. Subscribe for insights, latest news and emerging trends straight to your inbox each Monday.

• Verification for food fraud prevention systems

• What does a food fraud team look like (and what to do if you can't get one)

• Food safety news and resources from around the globe

• Are underweight ingredients a food fraud issue?

• Food fraud news and incidents (Trump, salmon, turmeric and more)

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Hi,

"Thank you for a great newsletter- always such amazing content. now upgraded " said Sarah, a “fellow food-safety bod” when she became a paid subscriber recently. Awww, thanks! Also thank you to John who upgraded and to Mike, Gill, JV, Ronit, James, Benjamin and Anna for renewing your subscriptions.

Welcome to Issue 164 of The Rotten Apple, not boring food safety and food fraud news. If you’re new here, hello, I’m Karen, and my mission is to give you the most interesting food safety and food fraud news from around the globe every Monday.

This week’s issue is food fraud central. I unpack a new paper from a team of distinguished food fraud academics, so you don’t have to read the whole thing (you’re welcome!), talk food fraud teams and ask ‘Are underweight ingredients a food fraud issue?’

Plus, as always we’ve got food safety news for everyone and food fraud horizon scanning + incident reports for paying subscribers.

Thanks for being here,

Karen

P.S. If you haven’t become a paid subscriber yet, now’s the time, it’s almost the end of the year (gulp). Your subscription supports independent ad-free goodness (and it’s probably tax deductible for you too!)

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Food fraud verification systems - a deep dive

I was really looking forward to diving into the latest peer-reviewed food fraud paper by Professor Louise Manning and her colleagues for you guys this week. It wasn’t quite what I expected.

Click the link below to see what I discovered.

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What does a food fraud team look like?

(and what to do if you can't get one)

A food fraud prevention team is a group of employees in a food business that is responsible for creating, implementing and supervising food fraud prevention activities in the businesses.

Food fraud teams are ideally made of representatives from various departments of the food business, such as Food Safety, Quality Assurance, Procurement, Production, Marketing, Site Security, Legal, Warehousing and Laboratory.

Members should be trained in food fraud awareness.

Typically, a food fraud prevention team would meet on an as-needed basis as determined by the food fraud team leader or as directed by senior management, with at least one full meeting every 12 months.  Meetings should also be held in the event of a food fraud crisis or if there have been major changes to supply chains or operations.

Attendance and minutes of the meetings should be recorded and filed within the food fraud prevention section of the food safety management system.  Action items from each meeting should be noted in the minutes, and subsequent meetings should address action items from previous minutes.

Agenda items for food fraud team meetings

• Action items from the previous meeting - status of actions.

• Discussion/report on new products in development and/or launched since the last regular meeting, with respect to food fraud vulnerabilities. 

• Discussion/report on changes to raw materials, suppliers.

• Discussion/report on new raw materials, new suppliers and contract manufacturers.

• Review of current food fraud procedures - do they represent current best practice, are they being followed?

• Discussion/report on any food fraud incidents or new risks emerging in relevant supply chains.

• Review of the composition of the food fraud team; any changes needed?

• Discussion/report on changes or upcoming amendments to certification requirements or customer standards.

• Review of audit results (internal, external and customer audits), with respect to food fraud elements.  Improvement suggestions and/or status of corrective actions.

• Review of mitigation plans and/or testing results; any new mitigation activities needed, new tests available?

• Report to senior management re. food fraud vulnerabilities and status of mitigation activities, request for further resources if needed.

What to do if you can’t get a food fraud team

Handling food fraud prevention activities is a tough task - tougher than senior managers may realise. So if your company doesn’t have a food fraud team, it’s important to ask loudly, and often, for cross-disciplinary help with food fraud matters.

Food fraud poses financial and reputation risks to businesses, and a single person should not be expected to understand every vulnerability across the business. The consequences of missing a vulnerability can be severe, and this must be explained to senior managers when requesting resources for a food fraud team.

Even in a very small company, a food fraud team containing a senior manager/owner, food safety representative, purchasing officer and production manager is best practice. The cost of man-hours used by a food fraud team is far lower than the cost of any serious food fraud event.

However, if you are responsible for food fraud prevention and you haven’t succeeded in getting a food fraud team, there are a few things you can do to reduce the risks. Firstly, you can approach members of other departments informally and ask them for their thoughts about specific products, ingredients or processes. You can also engage the services of an external food safety consultant if the budget allows. They can bring a fresh perspective, new knowledge and may even be able to persuade senior management of the importance of forming a team.

Finally, you could borrow the food safety hive mind in a forum or professional group to assist with tasks such as identifying or prioritising vulnerabilities. Try the forums of the International Food Safety and Quality Network (IFSQN) which are free and can be used anonymously, LinkedIn groups or professional food science associations such as IFST (UK), IFT (USA) or AIFST (Australia).

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This week’s food safety roundup

This week’s food safety roundup includes a list of mystery outbreaks in the USA and updates on the USDA’s actions in the bird-flu-in-cow’s-milk saga.

Check it out by clicking the preview box below.

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Are underweight ingredients a food fraud issue?

Speaking of the IFSQN, this question about underweight ingredients was inspired by a post in their forum earlier this year. The post was by a person from a food company in the United States.

He wrote: “If we receive raw ingredients that are underweight, would that be considered food fraud? For example, a truckload of cane sugar is 850 bags of 50 pound bags of sugar (42,500 lbs total). In a recent shipment, we discovered the bags weighed out to be 47.5 lbs, not 50 lbs. So we had paid for 2,000 pounds of sugar we didn't get. Could that be considered food fraud or just a supply chain problem?” 

I was asked the same question by representatives of a US industry association recently. They claimed that certain players in their industry were consistently underfilling bottles, thereby cheating their customers and consumers. They wanted to know if that counted as food fraud.

To answer these questions we first need to define food fraud. For me, and in most legal conventions for fraud more generally, fraud requires intent. That is, an action must be deliberate to be counted as fraud. Conversely, if someone makes an honest mistake, the outcome is not considered to be fraud.

Food fraud occurs when there is an intention to deceive or mislead a customer, consumer, enforcement agency or government.

Food fraud is deception, using food for economic gain (Spink, et al 2016)

In the sugar scenario, it’s possible that whoever bagged the sugar made a mistake when they entered the set weight into the bagging machine. Many of the respondents on the forum claimed this would be the likely explanation.

A consultant who responded to the question described a situation he discovered while performing inspections at a chain of retail stores. A manager told him that a certain ice supplier was consistently shorting their 10 pound bags of ice by 1/2 pound, affecting millions of bags of ice cubes and every location.

He says a root cause analysis determined it was operator error. But then, they would say that, wouldn’t they?

Honestly, even if it was ‘just’ an operator error, and not food fraud, paying for 1 ton of sugar that you didn’t get is a pretty big deal. Even without financial considerations, at the very least the missing material would make mass balance exercises and recalls impossible because of the unexplained (apparent) disappearance of 2,000 pounds of material.

Financially, the purchasing company missed out on 5% of the shipment and, based on the stated price of the sugar - $0.65 per pound - lost $1,300.

If the underweights affected every shipment and the supplier was shipping ten consignments per week they could be making an extra $650,000 per year by shorting each bag by just 5%. That sort of money is enough to make a real difference to a company’s bottom line and could provide a strong motivation for the company’s owners to behave dishonestly.

In the other case I mentioned, the companies that were consistently selling underweight bottles of product weren’t just cheating customers, they were also putting honest companies in the same industry at a disadvantage. It’s hard to compete with a company that has the same costs as you but gains an extra 2 to 5% profit on every bottle they sell.

So is this a food fraud issue? Absolutely, if the short-weighting and underfilling is not accidental.

How do we know it’s not the result of an accident or error? For the underfilled bottles, the industry association had performed their own assessment and discovered that the fill volume was less than the amount declared on pack for close to 100% of samples. Genuine filling errors should result in both over-filled and under-filled packs, so consistent under-filling is an indication of deliberate actions, not errors.

In the sugar scenario we can’t know whether the short-weighting was deliberate. But, based on the fact that all the sugar bags were exactly underweight by 5%, and because there are significant financial benefits to be gained by consistently short-weighting, I’d say it probably was. And that makes it food fraud.

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

In this week’s food fraud news:

• 📌What Trump’s win could mean for food fraud - 3 perspectives and one developing threat

• 📌New information for food fraud in salmon and turmeric

• 📌Disambiguation re. plant-based “steak” rules, Europe

• 📌Food fraud resilience tool updated

• 📌Children’s vitamins; man arrested for producing counterfeit copies for 20 years

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📌 Food Fraud News 📌

What Trump’s win means for food supply chains

When food supply chains are disrupted, new drivers of food fraud can emerge. For example, if prices change, the profits available to fraudsters can increase, providing more motivation for fraud. If supply patterns change, new opportunities to commit fraud, perhaps through new means of accessing food, can arise.

With large changes predicted for international food trading patterns and US domestic labour supply, after Trump takes office in January 2025, the likelihood of food fraud occurrence in certain commodities will also change. Read on for three perspectives on how a Trump presidency will affect food fraud risks.