192 | Melamine Adulteration Today |
Plus, the grain* that makes you lame and a toolbox talk on record-keeping
Photo competition winners
Melamine adulteration (still a thing)
The toxic pea that causes lameness
Food Safety News and Resources
Toolbox talk: Record-making 101
Food fraud news: recent incidents
Hello,
Welcome to another issue of The Rotten Apple. An extra special huge welcome to 👏👏Christine and Nicolás 👏👏 who upgraded their subscriptions last week, I’m thrilled to have your support in our community of food safety champions.
For this week’s issue, I investigated a US FDA database of import refusal notices, looking for evidence of melamine in food. Read on to find out what I discovered.
Also this week, I announce the winners of last week’s competition, explore the weird history of a survival crop that causes unusual symptoms and has links to the Nazis, and a tool box talk to share with your front line workers.
As always, this week’s issue finishes with a collection of food fraud updates for paying subscribers. Butter fraud seems to be happening more often now, and this week’s news includes a case in South America that involved both adulteration with vegetable oil and counterfeiting of other brands.
Karen
P.S. Got a burning food safety question you need answered? Or an interesting bit of news to share? Reply to this email, or write to me at therottenapple@substack.com and let me know. I love to hear from you.
*Technically, it’s a pulse, not a grain…
Photo Competition Winners
The winners of our photo competition are
Diana from Mexico and
Kaytlin from Canada.
Diana identified 15 non-conformities in the picture, including this one that gave me a chuckle:
“Ignoring the fact that the cellphone is backwards in a very boomer fashion (lol), you shouldn’t use cellphones on the kitchen because they are super dirty.”
Katylin won the caption comp with: Veggie Tales – Mayhem in the kitchen
I’ll be sharing a list of non-conformances and discussion points from the image as a downloadable food safety training exercise later this month.
Diana and Kaytlin, packs of stickers are on their way to you. Congratulations!
Melamine adulteration today
Last week I learned the USA is still flagging food imports for melamine adulteration on a regular basis.
Intrigued, I jumped into the FDA import refusals database to figure out what was going on.
Sure enough, last year, the US refused imports for 261 foods on suspicion of melamine adulteration. By comparison, the European Union’s food safety alert system (RASFF) flagged no foods for melamine adulteration.
Reminder: Melamine is an industrial chemical that contains significant quantities of nitrogen and can be purchased as a white-ish powder. It has been used as an adulterant by food fraud perpetrators to boost the apparent protein content of foods like milk and wheat gluten, most famously in the Chinese infant formula scandal of 2008 and the US pet food recalls of 2007.
The high nitrogen content in melamine allows it to ‘trick’ the laboratory test traditionally used to quantify the amount of protein in foods, the Kjeldahl method, which is based on the fact that most nitrogen in food is present in the form of protein.
Foods which are priced according to their protein content, such as milk, milk powder, gluten and other plant-based proteins like pea powder, are vulnerable to adulteration with melamine and other nitrogen-containing industrial chemicals.
Melamine doesn’t just present a food fraud risk: there are food safety implications for adulteration with melamine, due to its toxicity. The Chinese infant formula and pet food problems only came to light after significant numbers of infants and pets were afflicted with kidney damage caused by the adulteration - more than 300,000 infants in the case of the tainted milk powder.
With melamine being so well-known as a potential adulterant in fraud-affected foods, are food fraud perpetrators really still using it in food destined for the United States?
It seems so, although the true extent is murky.
Here’s what is on the public record.
In 2024 there were 261 foods refused entry to the USA by the FDA because they contained or “appeared to contain” melamine.
Specifically: “The article appears to bear or contain a food additive, namely melamine and/or a melamine analog, that is unsafe within the meaning of Section 409.”
Those foods were found within 81 shipments from 71 manufacturers, all from China.
Sixty-two foods were affected, including foods that could reasonably be imagined to contain melamine-like adulterants, such as fluid milk, dried milk, pet food, bakery products, rice protein, soybean flour/meal/powder, and vegetable proteins.
Other foods that were refused entry seem less likely to be vulnerable to melamine adulteration, including in-shell pecans, fruit-flavoured soft drinks, and black tea. I’m not sure why the FDA would flag such products for appearing to contain melamine.
Notably, most of the foods were refused entry without testing. Just 5 of the 261 foods refused for melamine violations had been tested at the time of the refusal. One item, described as MEAT/POULTRY/SEAFOOD FLAVORED FOODS, N.E.C., BAKED, was marked yes for “FDA Sample Analysis”, while just four other items, cakes and baked potato snacks, were marked “Yes” for “Private Lab Analysis”.
What gives?
The US FDA is allowed to refuse imports based on reasonable suspicion or preliminary evidence, including prior findings and documentation, without laboratory confirmation, and “Appears to be adulterated" is a legal threshold in the FDCA (21 U.S.C. § 381(a)).
Although the FDA publishes a record of each refused food (here), there is little information about the reason for the refusals. Each record contains information about the shipment, manufacturer, date, and whether testing was done, plus the food type and violation code, for example ‘MELAMINE’, accompanied by the charge statement. The description of the charge is generic (“appears to bear or contain a food additive, namely melamine and/or a melamine analog”) and doesn’t reveal how this conclusion was reached.
While some might be tempted to blame the current political climate in the US for import refusals of Chinese foods, the data I interrogated was from 2024, which pre-dates the present administration.
Conclusions
At least 5 of the 261 foods from China refused import to the US in 2024 on the basis of possible melamine adulteration were tested by the FDA or private laboratories. One assumes they tested positive for the presence of melamine or a melamine analog but details are not published.
There were 62 types of foods among those refused entry, including bakery products, snack foods, beverages, fluid milk, dried milk, ice cream, yoghurt, breakfast cereals, pecan nuts, pet food, rice protein, soybean flour/meal/powder/protein powder, and other vegetable proteins.
If your company purchases any of these foods or ingredients from China, be alert to potential adulteration with melamine or melamine-like chemicals, as this is a reasonably foreseeable hazard in such foods from that country.
In short: 🍏 Melamine has been used as an adulterant by food fraud perpetrators for boosting the apparent protein content in certain foods 🍏 Melamine adulteration poses food safety risks 🍏 The USA refused imports of 261 foods because they potentially contained melamine or melamine analogs in 2024 🍏 All were from China 🍏 Few of the refused foods were tested prior to refusal 🍏 Reasons for import refusals are not included in the public record (beyond “appears to contain”) 🍏 Purchasers of bakery products, snack foods, beverages, fluid milk, dried milk, ice cream, yoghurt, breakfast cereals, pecan nuts, pet food, rice protein, soybean flour/meal/powder/protein powder or other vegetable proteins from China should be aware of possible adulteration with melamine and melamine analogs 🍏
Source:
The data in this article was obtained by interrogating a database downloaded from the US FDA (here). If you would like to jump into my analyses or dive into individual records, you can download my Excel file by clicking the ‘download’ button below.
From survival crop to health hazard: the weird history of a toxic pea that causes lameness
Last month, the Department of Health of the Indian city of Ludhiana seized a consignment of khesari dal, a curious food that is banned for sale in India due to its neurotoxic effects.
Khesari dal (Lathyrus sativus), also known as grass pea, is a legume cultivated for human food and animal feed in parts of South Asia, including India and Bangladesh, and East Africa.
It also features in the regional cuisine of certain cities in Europe, including Florence, Italy; La Mancha, Spain; and Alvaiazere in Portugal and may have been one of the first crops cultivated in Europe.
It is a high yielding crop that is drought and salt-tolerant, allowing it to grow in soils and conditions that do not support other crops, making it a popular choice for farmers in marginal growing areas.
The peas contain 31% protein, significantly more than other legumes, are cheap and require less fuel to cook than other legumes as well.
It sounds like a miracle food.
That is, until you learn that it also contains a neurotoxin, β-N-oxalyl-l-α,β-diaminopropionic acid (β-ODAP) which can cause irreversible paralysis of the lower limbs, leading to lameness and paralysis in humans and animals.
Not fun fact: During World War II, the Nazis fed grass pea to prisoners in a camp in Romania, possibly as a deliberate experiment. The grass pea had been used as horse fodder by the Soviet army and was left behind when they retreated from Romania.
Within months, up to 800 prisoners were affected by the neurotoxin in the grass pea and could no longer walk, instead using crutches or crawling. The symptoms and doses were meticulously recorded by a physician-prisoner.
India banned the sale and consumption of the legume in 1955, but enforcement is patchy, with sales still allowed in some states. Cultivation for animal feed or own consumption is still allowed.
Food Fraud Fact
Khesari dal is said to be used as an undeclared addition (adulterant or diluent) in more expensive pulse flours such as chickpea flour, creating safety risks due to its toxicity
In recent years, efforts have been made to develop and promote new low-toxin varieties of khesari dal that are considered safe for human consumption and there have been calls from Indian government officials and scientists to lift the ban if these varieties prove safe.
Food Safety News and Resources
Our food safety news and resources roundups are expertly curated and never boring.
This week’s most unusual news: possible radionucleotide hazards in fats and oils?
Click the preview box below to access it.
Toolbox talk: Record-making 101
This toolbox talk video about record-keeping is concise, clear and perfect for frontline workers. It captures so many of the problems auditors encounter when reviewing handwritten records in a food facility: love it!
Note, although Alex uses the term ‘documentation’ in this video, I prefer the term ‘record-keeping’.
For me, ‘documents’ are processes, policies and the like - that is, fixed written materials that are updated rarely and through a controlled system, while ‘records’ are completed forms which hold information such as monitoring measurements, and therefore look different from day to day.
What about you? Documents or records: do you make a distinction?
Below for paying subscribers: Food fraud news and incident reports
📌 Food Fraud News 📌
In this week’s food fraud news:
📌 Fake butter;
📌 Fake olive oil;
📌 False welfare claims for beef cattle;
📌 Forged certificates of origin and more…