Discover more from The Rotten Apple
Issue #32 2022-04-04
Two big food fraud concerns, what went wrong at Abbott Michigan and horizon scanning (what exactly is it?)
Two big food fraud concerns and one unusual supply chain development
What went wrong at Abbott’s Michigan facility?
What I mean when I talk about horizon scanning
Food fraud incidents and horizon scanning updates from the past week
To hear me read this issue out loud, click here.
Welcome to The Rotten Apple, an inside view of food integrity for professionals, policy-makers and purveyors. Subscribe for weekly insights, latest news and emerging trends in food safety, food authenticity and sustainable supply chains.
I can’t believe it’s April already. This month, The Rotten Apple will be 8 months old and it’s going from strength to strength. Thank you all for your wonderful feedback. Keep sharing it among your network, a wider readership will allow me to keep providing independent, ad-free reportage on the (food) stuff that matters.
This week I share some important developing food safety risks from food fraud, plus a new development from supply chain squeezes related to the Ukraine war. Also, as promised last week, I explain why the US FDA was so concerned about the water they found in the baby food factory at the centre of the deadly recall, and what the manufacturer could have done better.
Finally, a brief explanation of “horizon scanning” in the context of food.
This issue ends with a list of food fraud incidents and horizon scanning updates that we’ve added to our database in the past week.
Thanks for reading!
P.S. If you want to know why I created this newsletter, read this.
Food Fraud - Food Safety Risks
Allergens in cumin
Cumin that contains undeclared sesame has been detected in France and Spain. The sesame could be there as an accidental contaminant, or it could have been added during food fraud activities. Like all powdered spices, cumin is vulnerable to food fraud.
Sesame in cumin is a big deal because:
(a) Sesame is an important human food allergen and can cause deadly anaphylaxis. When it’s present as a contaminant in food it won’t be listed on the label, which poses a major risk to allergic consumers.
(b) Many spices like cumin come from supply chains that are hard to trace. So it can hard to pinpoint the source of adulterants like sesame.
(c ) It’s highly likely that other batches of cumin have also been contaminated or adulterated, due to the nature of spice powder supply chains.
If you use powdered cumin in your food products I recommend doing allergen tests urgently.
Allergens in counterfeit chocolate bars
A counterfeit chocolate bar is one that is made to resemble a well-known brand but was actually manufactured by an unauthorised entity.
Counterfeit Wonka chocolate bars have been found in the United Kingdom. Authorities allege that some of the bars contain undeclared allergens, presenting a serious food safety risk to allergic consumers.
If you see them, don’t eat them, and tell the Food Standards Agency where they are being sold.
Counterfeit products are more likely to be found at independent outlets like market stalls, independent corner stores, street stalls and online. Corporate outlets like big supermarket chains are much less likely to stock counterfeit items.
Supply chain development
In the United Kingdom you’re now allowed to swap rapeseed oil for sunflower oil, without having to change your product labels. This is because of the looming sunflower oil crisis due to the Ukraine war.
It can take months or years for food manufacturers to change food labels, and if they run out of sunflower oil, the time lag for label changes means they would have to stop selling affected food until they could get the new labels organised.
What went wrong at Abbott’s Michigan facility?
Last week I shared the inspection reports for the facility at the centre of the big baby formula recall.
As a reminder, the recall was initiated after babies got sick and died from consuming infant formula made at a facility in Michigan.
This week, I want to go a bit deeper into what went wrong inside the factory. The short answer is that tonnes of things went wrong and there are no excuses for much of what was done and not done by management of the facility.
I’m not here to blast big food. It’s hard to manufacture commercial quantities of food. Doing it safely and profitably is difficult. The raw materials are variable, the margins are tiny and the finished products are delicate, difficult to keep safe and easily degraded. Compare food manufacture to the making of any other consumer product such as mass-produced furniture, electronics – anything really – and you will find food manufacture more regulated, less profitable and has more supply chain challenges than any other segment.
People who work in food production generally want to do the right thing. We are all aware that we have a responsibility to make food that is safe. After all, we all eat, right?
So let’s take a look at what you would need to do, as a manufacturer, to keep Cronobacter out of infant formula.
First, infant formula does contain viable bacteria. Most bacteria are not harmful. In fact, of the 30,000 known species of bacteria, less than one percent of them are known to cause food-borne illness.
With infants being more vulnerable to illness than healthy adults you might think that infant formula should be completely sterile, just like many other foods. For example, canned tuna is sterile*, why not baby formula?
Canned tuna is sterile because it’s been heated to a very high temperature to kill all the microorganisms inside the can. We heat tuna to make it sterile for two reasons: (a) because fish can contain pathogens and canning the tuna kills the pathogens (b) to give the tuna a long shelf life. If you kill all the germs inside a tin of food, it will be safe to eat for many years.
Powdered infant formula is not heated up the same way as canned tuna. It already has a long shelf life because of its very low moisture content. With no moisture, bacteria can’t reproduce, so the formula does not spoil.
But what about pathogens? Why don’t we blast baby formula with heat to kill the pathogens in it, the way we do for – say – canned tuna?
Because heat-blasting powdered infant formula turns it into a lump of caramel. And also destroys some of the important nutrients too.
So instead, we control for pathogens in dried infant formula using other methods.
The primary controls are, “rigorous hygienic precautions coupled with monitoring of the process environment and finished product by the manufacturer.” [NSW Food Authority]. When these controls break down, pathogens like Cronobacter sakazakii can get into the formula.
How much Cronobacter has to be in formula to make babies sick?
We don’t know for sure, but we think that even very low numbers are risky. When a parent mixes formula with water to feed their baby, C. sakazakii reproduces rapidly. Researchers who tested this discovered that if a formula powder contained 1 bacterium per gram and was reconstituted and held at 35 degrees Celsius, then after 4.5 hours it contained enough Cronobacter to make babies sick. If there were more bacteria in the powder to start with, then the bacteria got to “danger” levels much faster (the source, as always, is below).
In short, it’s safest to have no Cronobacter at all in powdered baby formula.
How does Cronobacter get into powdered formula?
At the Abbott facility, Cronobacter was found in places like the floor of the production areas. We don’t know for sure how bacteria gets from floors into product, but food scientists think that airborne droplets of moisture are an important vector.
That’s why the FDA was so concerned with the water they found inside the dryer and in other areas of the facility. It’s possible that C. sakazakii was growing in the water that was left inside the dryer between cleaning and the next production run. The bacteria could have perhaps escaped the cleaning process by “hiding” in the pits and cracks inside the dryers.
In that scenario you can imagine that the first few containers of formula packed off from the first part of the production run might have contained many bacteria, while the later tins from the same production run might have contained none.
What could have been done better?
- No water in production areas while product is being made;
- no water inside dryers after cleaning; and
- internal surfaces of dryers being free from cracks, pits and damage, so that bacteria have nowhere to harbour during cleaning.
Also: better boot washing so that less bacteria were coming into the factory to begin with.
You can learn more about hygiene controls for formula production here: https://www.canada.ca/content/dam/hc-sc/migration/hc-sc/fn-an/alt_formats/hpfb-dgpsa/pdf/legislation/infant_formula_gmp-eng.pdf
In short: 🍏 Powdered baby formula is not sterile 🍏 Keeping pathogens like Cronobacter sakazakii out of baby formula is done by implementing strict hygiene controls and monitoring in factories 🍏 The US FDA observed multiple failures at the factory where recalled baby formula was made 🍏 Water in production areas, moisture in milk dryer chambers and damaged surfaces in dryer chambers can result in contamination of powdered baby formula 🍏 Small amounts of contamination can multiply to dangerous levels when powdered formula is reconstituted 🍏
*okay, food micro pedants, canned tuna is “commercially sterile” not completely sterile… sorry, not sorry!
What exactly is horizon scanning?
If you’re a food fraud nerd (like me!) you’ll know what I mean when I use the term horizon scanning. But I thought I better explain it if you are new to The Rotten Apple or new to the food fraud space.
Horizon scanning is the act of trying to anticipate threats that might develop in future, in the medium-term or the long-term. It’s used in all sorts of fields and industries. For example, in health care you might do horizon scanning to anticipate the next pandemic, in cybersecurity you might be keeping an eye on the impact that quantum computing will have on encryption systems when it becomes more widely available.
In food fraud, and food supply chains in general, horizon scanning is the act of trying to anticipate or predict how future situations might cause problems in supply chains or affect the likelihood of food fraud occurring.
This month I’ve been struck by how much mainstream media reporting is actually food-supply horizon scanning in disguise. I’ve never seen so much before. Every major news outlet is talking about how the Ukraine war will affect food security globally. By the way, food security means availability of food for people, nothing to do with food fraud.
So, the main stream media is talking about things like upcoming shortages of fertiliser, predictions for increased food retail prices, changes to food trading patterns and even shrinkflation - which is when packages of food get smaller but prices stay the same.
Food fraud horizon scanning is a big part of my work. We add horizon scanning information to our food fraud database (the Trello board) almost every week. We choose items that might increase the likelihood of food fraud occurring for various commodities. So, for example, if there is pressure on poultry supplies in a certain region due to bird flu, we’ll add a note about that to the poultry card on the Trello board.
You won’t find links to sources in the Trello board, due to space limitations. However, you can get links from The Rotten Apple. For older sources in the Trello board you can write to us to request sources. I have a database of every single source from the past 7 years, and we can track and find sources using the dates that accompany every item.
This week’s horizon scanning news can be found at the end of this email.
In short: 🍏 Horizon scanning is the act of trying to anticipate threats that might develop in future 🍏 Food fraud horizon scanning is the act of trying to anticipate or predict how future situations might increase food fraud vulnerabilities 🍏
Food Fraud Incidents and Horizon Scanning
Food fraud incidents added to Food Fraud Risk Information Database in the past week
We added many food fraud incidents to the database today and in the past week. Many of these are incidents that occurred in February 2022, some from March 2022.
Cumin that contains undeclared sesame, an important human food allergen has been detected in France and Spain
Significant quantities of bulk wine and bottled wine has been seized by authorities who claim that the wine was or was going to be labelled with false claims regarding its origin – Italy
Ration rice meant for poor people was illegally obtained, stockpiled and sold to migrant workers for much higher prices by a man. The quantity was 4800 kg – India
Argentinian authorities have intercepted illegal shipments of corn, soybeans and fish that were being exported or smuggled illegally within Argentina and between Argentina and Brazil and Argentina and Bolivia – South America
Milk prepared with unhygienic powder, detergent and cooking oil was seized by authorities – Pakistan
Liquor intended to be smuggled into an alcohol-free state was seized by authorities; illicit liquor was seized from shops and manufacturing sites during a crackdown by authorities; A fake liquor manufacturing unit was shut down. There were bottles, bottle caps, counterfeit labels, holograms, chemicals and spirit; unauthorised liquor makers and sellers have been arrested in large numbers – India
Authorities found smuggled bottles of liquor hidden in a shipment – Oman
Two of ten olive oil samples were labelled extra-virgin but only met the criteria for virgin – Switzerland
Manufacturers of adulterated butter were shut down, after authorities found various brands of “butter” to contain undeclared vegetable fats and oils including palm oil – Ukraine
Urea fertiliser and wheat was seized from smugglers by authorities; Authorities prevented wheat from being illegally shipped out of a province – Pakistan
Products including fresh fruit, vegetables, mushrooms and honey have shown rates of up to 30% “anomalies” in the way the origin of the food is declared. In this case non-France-grown food declared as French – France.
Fish harvested from off-season/closed fishing grounds was intercepted by authorities on their way to markets in other areas – Mozambique
A fake honey operation was shut down by authorities. The “honey” was being made with sugar syrup, glucose, non-food grade artificial colours, harmful chemicals – Pakistan
A fraudulent milk supply operation was uncovered after an inspector found a second hidden tank in a milk transport truck. The second tank allowed for the milk to be diluted with extra water, by remote control, after it passed quality inspections but prior to its unloading at the customer’s site - Italy
Twenty two percent of samples of spelt grains (Triticum spelta) and products made from spelt flour (n = 133) were found to contain levels of soft wheat that exceed acceptable contamination tolerances of 10%, with the presence thought to indicate fraudulent addition of soft wheat. Products made from spelt flour, including bread, pastries, biscuits and pasta were more often affected than whole grains of spelt – Germany
Bottles of liquor claimed to be “Italian” but in fact made in other countries were seized by authorities. Questions were raised after customs officials noticed tankers of the “Italian” product being imported from Holland – Italy
Fish fillets were mislabelled with respect to species in 33% of cases (n = 54) in a survey of products purchased from supermarkets. The worst affected products were those labelled Atlantic salmon. Products that had scientific names of species on their labels were less likely to have the incorrect species in the pack – Thailand
A massive fake wine manufacturing operation has been shut down in China. The wine was sold online, with the sellers diverting internet traffic to their sites. The wine was a counterfeit version of Moutai brand possibly worth 100 million yuan. The fraudsters are alleged to have copied anti-counterfeit features on the wine – China
Fruit juice concentrates and fruit vinegars are alleged to have been fraudulently adulterated with invert syrup made from sugar cane by authorities who discovered quantities of the syrup at an establishment where it should not be needed – Brazil
A survey of frozen fish fillets in Malaysia found 11% (n = 47) to be mislabelled with respect to species. Of fish labelled as dory, cod and flatfish, 60% was in fact Pangasianodon hypophthalmus – Malaysia
Counterfeit chocolate bars of a famous brand have been found in the United Kingdom. Some bars are alleged to contain undeclared allergens, presenting a serious food safety risk to allergic consumers – United Kingdom 28/03/2022
Roast corn snacks that contained the unauthorised colourant Sudan Blue II dye were reported – Malta
Massive quantities of beverages that are counterfeits of multinational brands, plus chemicals, filling machines, packaging materials were seized by authorities during a crackdown – Pakistan
Milk packages from a premium brand were being tampered with by a man who was removing milk from the packets and filling them with unhygienic water before, supposedly refilling them – India
Food fraud horizon scanning (other updates to the Food Fraud Risk Information Database in the past week)
Chicken and Eggs
Bird flu is at its worst since 2015 on the USA East Coast and millions of birds have been culled. This will have impacts on the poultry and egg supply chains of USA, with free-range eggs at risk of fraudulent misrepresentation – USA 24/03/2022
Sunflower oil replaced with rapeseed oil
The United Kingdom has permitted food companies to use rapeseed oil in the place of sunflower oil without declaring it on the label as sunflower oil shortages affect food manufacturing supply chains 24/03/2022
Fish is already at high risk of misrepresentation of origin and the Ukraine war may increase this risk further. Russia produces more than 40% of white fish globally, accounting for large proportions of the world’s supply of Alaskan pollock, Atlantic cod and haddock. Fish caught in Russian waters may be fraudulently declared as being from China, Norway, Poland, Germany – Global 28/03/2022
The Ukraine war is expected to affect supplies of pulses and other legumes, chickpeas, peas and lupins because Ukraine and Russia are both important global exporters of these. With plant protein powders already at risk (see Issue #15), supply and price issues could increase the risk of fraud. Possible frauds include misrepresentation of geographical origin or organic status, incorrect information about species and sources and – importantly – the presence of undeclared allergens, such as lupins and peas. Plant powders may also be adulterated with nitrogen-containing chemical adulterants to artificially boost their apparent protein content. Possible adulterants include melamine and related compounds. 28/03/2022
The Ukraine war is affecting prices of corn and global supplies, because Ukraine is an important global supplier of corn (maize). This increases the risk of food fraud, including for organic corn, non-GMO corn. Mycotoxin contamination is more likely, and older mould-affected shipments might be used to 'bulk' out fresh shipments. Forged laboratory reports and import/export paperwork are possible - Europe, The Middle East and Africa 28/03/2022
Here’s what you missed last month
See you next week!
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