Issue #33 2022-04-11
Unhappy Easter chocolates, milk fraud done differently, and the surprising CBD food list
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.
The Future of Food Safety (an FAO report)
A surprising way to address illegal CBD foods
Chocolate and Salmonella (how, why?)
Just for fun (hide a virtual Easter egg)
Food fraud incidents and horizon scanning updates from the past week
To hear me read this issue out loud, click here
Welcome to Issue 33. Thank you for loving The Rotten Apple. It’s great to receive so much positive feedback every week.
The new audio feature has been popular. (By the way, if adding audio seems like a lot of effort for a free newsletter then yup, it sure is! Next month I will be introducing some features to help financially support The Rotten Apple, stay tuned.)
This week I talk about the surprising way one country has chosen to approach ‘illegal’ cannabidiol-containing foods. Then I take a deep dive into Salmonella in chocolate, inspired by the big recall of children’s confectionery that’s happening right now.
An unusual milk fraud incident caught my eye last week, so I discuss that in more detail this week too.
Finally, this issue has a fun activity and two long reads for those of you who have holidays for Easter. And, as always, food fraud incidents are listed at the end.
Thanks for reading!
P.S. If you know someone who’d enjoy this newsletter, please share it with them. Your shares will help me keep making independent, ad-free goodness each week.
The Future of Food Safety as Imagined by the FAO
The Food and Agriculture Organization of the United Nations (FAO) published Thinking About The Future of Food Safety (A foresight report) last month.
It has chapters on the food safety implications of changing consumer preferences, technical innovations, urban agriculture and food fraud, among other topics.
For a food safety professional, it's full of "duh" moments. By that I mean it’s mostly stuff you already know, like climate change will impact food supply chains (no kidding).
The good news is that there’s no need for you to read it, ‘coz I did. A summary of the most pertinent and non-duh ideas will be appearing in The Rotten Apple in a future issue. But there are way too many other important and timely things to discuss today.
🍏 The report: https://www.fao.org/documents/card/en/c/cb8667en 🍏
CBD Foods: A Surprising Approach
A list of CBD-containing (cannabidiol-containing) foods is big news in the UK this week. For the rest of the world, the list and the way it has been created by the United Kingdom Food Standards Agency (FSA) might be used as a model for new regulatory approaches.
The list tells the public which unauthorised cannabidiol-containing (CBD) foods might be okay to sell and buy.
Unauthorised?! Yes, you read that correctly: CBD foods are illegal in the UK right now. In publishing the list, the FSA is publicly acknowledging that there are many CBD foods widely available throughout the United Kingdom, even though they shouldn’t be. The list captures those products for which the FSA has received a “credible” application for authorisation from the manufacturer. So products on the list might be safe and might (one day) become legal.
I’m not sure what I think about the FSA’s list. It’s an unusual approach, but in terms of safety, better than doing nothing. The FSA doesn’t say when, or if, CBD foods as a category, will ever achieve regulatory approval.
Not a good week for children’s Easter treats
Salmonella in chocolate
You probably already know that a multi-country recall is underway for chocolate products made by Ferrero, including products for children. More than 100 cases of salmonellosis in children have been recorded. Kids with salmonellosis can experience more severe symptoms than adults and some have experienced bloody diarrhoea.
But chocolate is a low moisture food, surely bacteria can’t grow in chocolate, I hear you ask!
That’s true, bacteria can’t grow in chocolate, because there isn’t enough water. But some bacteria can persist in chocolate, including Salmonella.
There have been multiple outbreaks of salmonellosis from chocolate and cocoa powder. In some of those outbreaks, Salmonella was never found in the finished product at all. Where it was found in products, it was often present at levels of less than 1 bacteria* per gram of food. That’s tiny! (By comparison the delicious tabouleh salad I ate for lunch yesterday likely contained more than 100,000 bacteria per gram).
Unfortunately, only a few Salmonellae cells are needed to cause illness, especially in children. In high-fat foods like peanut butter and chocolate, it’s thought that the fat protects the Salmonellae from stomach acid, allowing them to make it through to the victim’s intestines, where they can grow and cause an infection.
How does Salmonella get into chocolate in the first place?
Cocoa beans undergo a fermentation process after they have been harvested. The fermentation develops the flavours and aromas of chocolate. Fermented cocoa beans have high numbers of bacteria, including Salmonella, and some bacteria can survive the post-fermentation drying process.
Perhaps surprisingly, Salmonella can also survive cocoa bean and cocoa nib heat treatment processess in the chocolate factory, if the treatments are not done with the correct temperature-time-moisture parameters. It can also survive the conching and tempering processes that are used to make chocolate glossy and ‘snappy’.
Previous chocolate outbreaks or contamination events have been attributed to:
- Cross-contamination from birds in the factory,
- Chocolate crumb contaminated by a leaking water pipe,
- Contaminated water in warming/cooling vessel jackets,
- Cross-contamination from raw cocoa bean dust via cooling air blowers,
- Recontamination of cocoa liquor after a kill step,
- Rework (=half-finished product that needs to be re-processed) stored near raw materials during building works in a factory.
What went wrong at Ferrero’s factory to cause this recall?
We don’t know.
A chocolate food safety expert has said he is perplexed at how a big company like Ferrero could get it wrong. In a LinkedIn post, he describes his experience setting up a HACCP plan to “eliminate the risk” of Salmonella at a massive chocolate refinery in Manchester (UK) in 1988. Ninety million tonnes of product later and there have never been any Salmonella problems at that facility, he says. His post and its comments are worth a read. A link is below.
Learn more about chocolate CCPs (critical control points)
There is a super-detailed and really interesting (for food techs) presentation that explains cocoa processing steps and Salmonella-elimination heat treatments for cocoa beans and nibs online.
The presentation is by Mondelez International. I usually wouldn’t share links to company-owned materials but this document appeared on page one of my Google search and is completely open to public access. Highly recommended.
In short: Perhaps surprisingly, Salmonella can persist in chocolate during processing and storage 🍏 There have been other outbreaks of salmonellosis from chocolate 🍏 CCPs in chocolate manufacture include the heat treatment of cocoa beans and cocoa nibs to eliminate Salmonella hazards 🍏
*Not exactly bacterial cells per gram, more correctly colony-forming units per gram (cfu/g).
LinkedIn Post by chocolate HACCP expert: https://www.linkedin.com/posts/denis--treacy_kinder-surprise-eggs-recalled-over-salmonella-activity-6917082063896522753--Z4Z/
Past events, causes and contamination levels (not original sources, but do include bibliographies): https://www.mondelezinternational.com/-/media/Mondelez/Procurement/Supplier-Quality-and-Food-Safety/Training-and-Webinars/Updated-Cocoa-processing-expectations-training-for-suppliers-February-2020_final.pdf
Milk Fraud Done Differently
Milk, milk, milk. I’m sick of hearing about food fraud in milk. But this story is different.
Every week food safety officials in India and Pakistan find and dispose of milk that has been adulterated with detergent or dirty water or vegetable oil. It’s awful but predictable. And I’m thoroughly sick of it.
Last week I learned about a completely different type of milk fraud, one that seems very calculated, one that required a high degree of sophistication and the involvement of multiple people.
The striking thing about this story is what we still don’t know about it… the true scale of it, nor who was really profiting from it. We don’t even know if it still might be happening today.
It's March 2021. Daniele Seniga, a milk industry quality controller, is at a dairy cooperative that makes mozzarella cheese in Italy. A tanker of milk arrives at the co-op. Seniga takes a sample of milk from the tanker as it sits in the loading dock and tests the milk against the co-op’s quality criteria. It passes. He accepts the load.
The milk is unloaded into a tank at the factory. Seniga takes another sample, this time from the factory tank. Weirdly, his test results show that the milk in the tank contains water. The concentration of water is 5%, an amount that far exceeds any agreed or legally allowed limit. He thinks there has been a mistake, so he retests it, and even switches test equipment to make sure there has been no mistake. But every test shows the same thing: the milk in the tank contains water.
It's a problem. Seniga has accepted the load but now it’s not fit to make cheese. He needs to understand what’s going on. He tells his colleagues at the loading dock about the problem and asks them to keep the truck and driver on site while he figures out what to do. But the driver somehow manages to reload the watered-down milk into the truck and drive away with it, leaving no evidence that anything ever happened.
So Seniga waits. He is ready when that truck next visits the factory. When it arrives, he calls the police who arrest the driver and confiscate the truck. The driver confesses that the tank in the trunk is divided into two sections, one containing milk, one containing water. The driver says the tanker is set up so that he can press a remote control button that causes the contents of the two tanks to be combined after the quality control sample is taken, but before the milk is unloaded.
Wow. Prosecutors and magistrates get involved and the prosecutors inspect the tanker and confirm the setup. And, of course they tell the milk company. The milk company denounces the haulier, and the truck driver is “removed”. Senior executives at the milk company claim that this was just a one-off incident.
A one-off incident? Daniele Seniga did not think so. Why would anyone go to the effort of building a double tank system and remote control signaller if they were only going to use it for one delivery? Doubts remained. However, some months later, Seniga was also removed from his post, and the quality control inspections were taken over to be “managed internally” by the dairy co-op.
The enforcement authorities can do no more, saying they only have evidence for two occurrences, end of story.
Well that’s a doozy! You might imagine that adding just 5% of any diluent or bulking agent to food would not be profitable, but you would be wrong. For high volume items, even tiny amounts of dilution or adulteration can add up to really big profits when it’s done consistently. For example, when melamine was discovered in milk powder in China in 2008 - the famous melamine baby milk scandal that sickened more than 300,000 infants - investigators found that the fraud had been happening for at least 18 months and probably years or even decades before it was publicly revealed. If you sell enough food, small concentrations of adulteration can add up to big profits in the long term.
The Italian story has a few parts that don’t quite make sense to me. Unfortunately, I found only one source for this story and couldn’t get any more information about it.
The relationship between the business entity that supplied the milk and the mozzarella factory that received the milk isn’t clear and the news story makes it seem that both might be the same milk cooperative. In that case, who could profit from such a fraud? Like the quality controller, I find it hard to believe that the transport company would have been motivated to come up with such a scheme on their own.
One thing is for sure: the whole exercise would not have been profitable if it was only done twice.
It’s all a bit of a mystery. But it does give us a fascinating insight into the ingenuity of fraudsters and the vigilance needed to detect and prevent such frauds.
In short: 🍏 There are more questions than answers in this milk fraud story that occurred in an Italian dairy supply chain 🍏
Fun Activity and Long Reads
Hide a virtual Easter egg
Got friends or family in a faraway place? Hide an easter-egg virtually for them to find.
The Cadbury chocolate company has created a virtual easter egg hunt. You can “hide” a virtual egg by pinning it to a world map and sending a clue to your chosen recipient.
If your recipient is in the United Kingdom, you can also send a real chocolate egg to their home, if you buy and hide it by tomorrow, 12th April. Virtual hunts can be done up to 18th April 2022.
Note you do have to create an account with Cadbury to play, so you will be sharing your name, email address and date of birth. Your recipient’s details aren’t shared, you send them the clue and link to find the virtual egg yourself.
🍏 Spread some Easter joy: https://worldwidehide.cadbury.co.uk/ (no affiliation, not an endorsement) 🍏
Long read: Wheat as the bad guy (and it’s not just Monsanto this time)
“Humanity took a wrong turn with wheat.” So says John Lewis-Stempel who argues that wheat growing was the reason humans became “domesticated” and gave rise to tyrannical authoritarian regimes.
This is a wide-ranging article. From the tyranny of Roman-empire imperialism to the tyranny of modern corporate greed, Monsanto’s Roundup Ready Wheat gets a bollocking too.
You probably won’t agree with all the ideas in this piece (I don’t), but it’s an interesting long read nevertheless.
As for the future of wheat… “All is not lost. If the Russian invasion of Ukraine is causing a rethink of our reliance on oil and gas, this too is the moment to sow seeds of doubt about our dependence on the “golden grain””.
How political sanctions affect the global saffron trade
More on saffron, that beautiful, aromatic and fascinating spice. This long read discusses the impact of political sanctions on saffron trading.
Food Fraud Incidents and Horizon Scanning
Food fraud incidents added to Food Fraud Risk Information Database in the past week
A sophisticated saffron fraud ring has been dismantled. The powdered 'saffron' was in fact powdered gardenia extract that was imported from China. The extract had been treated to reduce levels of a marker compound that is used to differentiate gardenia from saffron. They also used fake import documents - Spain
Counterfeit versions of carbonated soft drinks, made with artificial sweeteners and possibly unclean water were seized by authorities – Pakistan
Foie Gras and related goose and duck liver products from farms, wholesale and retail establishments were investigated, with 46% of the establishments (n = 50) having at least one anomaly. Anomalies included non-compliance with rules about how much duck or goose liver was present, non-compliance with water and fat content, not all ingredients being listed on the label, use of an unauthorised additive (potassium nitrate), compliance with rules for PGI (protected geographical origin) logos and unverifiable claims about the country of origin – France. 07/04/2022
Tea powder coloured with unauthorised dyes has been found by inspectors – India
A facility that was adulterating chilli and fennel powder with bulking agents and unauthorised colours has been shut down by officials – India
A survey of 824 seafood samples, including fin-fish, mussels and prawns, collected from supermarkets and fishmongers in 6 European countries in 2019 found that more than 95% of pre-packaged products were compliant with EU labelling laws but only 76% of unpackaged products were compliant. For fishmonger-sold seafood, non-compliances included not disclosing the scientific name, the fishing gear and the catch area – Europe 01/12/2021
Food fraud horizon scanning (other updates to the Food Fraud Risk Information Database in the past week)
Ground black pepper can be adulterated with olive pomace and other olive by-products.
Here’s what you missed last month
All about saffron fraud (Issue 31)
A new way to verify the recycled content of plastic packaging (Issue 29)
A marijuana testing lab that was just a bit too good at telling their customers what they wanted to hear (Issue 28)
See you next week!
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