Issue #49 2022-08-01
TikTok Sauce (Natural or Not?), Recycling PPE, Food Standards Updates, Food Fraud FAQs
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TikTok Pink Sauce - “Natural” or Not?
New Food Safety Standards - What You Need to Know
Recycle PPE? Yes you can!
Food Fraud Corner - FAQs
Food fraud incidents and horizon scanning updates from the past week
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Welcome new readers!
We’ve had so many new subscribers join us in the last three weeks. I’m so happy you are here. If you haven’t had a look around the main newsletter website, you can check it out here… you’ll find all our past issues and can browse at your leisure.
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This issue of The Rotten Apple has a short discussion about what a natural food really is, in the context of the flousecent pink sauce that’s gone viral on TikTok (looks disgusting!). Then, for food safety nerds, there is a time-saving summary of the soon-to-be enforced updates to three major food safety standards (definitely skip this if you’re not an auditor or consultant). I’ve included a link to a free webinar too.
Plus - great news! - it’s now easier to recycle all the hairnets, gloves, face-shields and disposable ear-plugs that create such problematic waste in food businesses.
Finally, a quick primer on the differences between food fraud and food defense.
This issue ends with food fraud incident reports, which are behind a paywall. Paid subscriptions go towards supporting the work I do for the (open-access) Trello Food Fraud Database.
Thanks for your support,
TikTok Sauce Goes Viral (Natural or Not?)
A TikTok celebrity created a fluorescent pink sauce that has gone ‘viral’. Consumers and commentators are questioning the sauce’s safety credentials and whether or not it is really “natural” as claimed.
"I am literally being tortured because I won't give answers to people in regards to my safety as a [food] business owner…. I have a right to reserve my silence" Pii, TikTok chef
If you are making food, do you have a right to be silent about safety? I would say not. Consumers have a right to safe food. And a right to complete and accurate information about the food too.
If you haven’t seen the sauce yet, it’s pretty spectacular. TikTok videos that feature the sauce have been viewed millions of times.
The first batches of the sauce were shipped with an error on the nutrition panel, which suggested each bottle contains more than 400 servings, each of 90 calories. The brand owner blamed her graphic designer for the mistake. Hmm.
Food safety specialists are concerned about the pH of the sauce, and the fact it is not refrigerated during transport, saying that could make it risky. Consumers are questioning how a so-called “natural” sauce can be such a bright colour.
What is a ‘natural’ food?
Most countries – including the USA – do not have a legal definition for ‘natural’ food in their food laws.
Guidance is available, but it varies. A lot. For example, the United Kingdom’s Food Standards Agency guidance for ‘natural’ suggests the food must be a “single food to which nothing has been added, and with minimal processing” in order to be called natural. Rules in India are similar.
On the other hand, the US Food and Drug Administration (FDA) guidance allows for a much broader range of food to be considered ‘natural’. The FDA says food can be considered ‘natural’ even if it is a mixed food, and no matter what type of processing it has undergone. The main criteria for ‘natural’ is that the food cannot contain any artificial or synthetic ingredients.
The other food regulatory body in the US, the Department of Agriculture has labelling guidance for meat and poultry that is almost the opposite, suggesting that the food should only be “processed in a manner that does not fundamentally alter the product”. Confusing!
Getting it wrong
A food bar claiming to be “crammed with 100% natural ingredients” got the brand owner in trouble in 2018, because two ingredients were judged to be not natural. The two ingredients were cocoa powder and sunflower oil.
Cocoa powder is made using a process that involves washing with potassium carbonate (the ‘Dutch process’). Sunflower oil is refined in a process that usually makes use of solvents.
These processing steps mean that cocoa powder and sunflower oil cannot be considered ‘natural’, according to the British Advertising Standards Authority. The brand owner had to pull its advertisements.
What’s the pink colour in the viral sauce?
The pink colour in the TikTok sauce is said to be derived from dragonfruit, which would make it a “natural” colour. The food techies among you are no doubt asking how a fruit-derived colourant can retain such a vibrant colour throughout processing and shelf life. I’m afraid I don’t have a clue. If you have any insights I would love to share them with this community (just hit ‘reply’ to get in touch).
Claiming that a food is ‘natural’ is a bit of a legal minefield. In a country with published guidance, it’s obviously best to follow the guidance. If there is no guidance, the safest bet is to use peer-reviewed consumer research as evidence of what local consumers agree is natural. That way, you can argue your case with local authorities if necessary. It is also best practice to include an on-pack explanation of what exactly is meant by any ‘natural’ claim.
What You Need to Know About New Standards
Three major food safety standards are being updated at the moment. BRC’s new standard will be released today, 1st August, with enforcement from 1st February 2023. AIB’s new standards were released last month and will be enforced from 1st January 2023. IFS published a draft updated standard for comment earlier this year, but the issue date has not been released yet.
BRC Issue 9
The new standard will be released today. Here are the major changes you need to know about.
Hybrid audits will be allowed, in which some elements can be done remotely using teleconferencing, with the remainder performed on site.
Food defence will have its own section, but sites are offered the option of combining food defence and food fraud in the same set of documents. Food defence and food fraud now also feature more heavily in the assessment processes for suppliers. Food fraud training is a requirement for personnel who perform vulnerability assessments.
There are new rules that cover the processes involved in selecting and commissioning new equipment and there are new requirements for facility fittings like plastic strip curtains.
In high-risk settings, the standard has stronger rules for sites that rely on the time-separation of activities as a food safety control.
AIB Updated Consolidated Standards
AIB has done a major overhaul of their entire suite of standards. Some have been deleted entirely, with their elements incorporated into other standards. USA-specific requirements have been separated out so that companies who are not producing food for the USA market no longer need to comply with them.
For example, HACCP and HARPC have been separated, as have the rules for food defense, which are different depending on whether the business is making food for the USA market or not.
Pest management requirements have had a complete overhaul in the AIB standards. AIB has also created requirements for traceability, training and record-keeping, which brings the AIB standards a little closer to GFSI-benchmarked standards.
It’s worth noting that AIB has opted not to include clauses that explicitly reference food safety culture as an auditable element in their updated standards.
A draft version of a proposed new standard was published by IFS for comment earlier this year. It contained many minor changes too numerous to list here, plus a few major changes.
Notable proposed updates include:
The addition of a sustainability policy (see Issue #38).
Significant wording changes for validation and verification (2.3.11).
Monitoring requirements for personal hygiene (3.2.3).
A new requirement related to chemicals as foreign material risks (4.12.3).
Metal and/or X-ray detectors have to be tested at the start and end of every production, plus at every product changeover (4.12.5) and they have to receive maintenance at least once a year (was ‘regularly’) (4.12.4).
There are new and specific requirements for the content of audit reports, including a description of the condition of the site’s infrastructure and information about its water supply.
Food fraud (‘authenticity’) gets a big boost, with almost all clauses related to food safety now also mentioning ‘authenticity’ as well. The requirements for food fraud and food defence are more explicit, addressed in more places throughout the standard and with better wording around monitoring and controls.
Authenticity monitoring (= food fraud testing) has been explicitly mentioned for the first time in the section on testing and monitoring of products (5.6.1 and 5.6.8).
🍏 Free Webinar on BRC Issue 9 from the Experts at IFSQN 🍏
This free webinar will explain BRC Issue 9. It will be held in September.
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Sustainable Supply Chains
Recycle PPE? Yes, you can!
Previously ‘hard-to-recycle’ disposable PPE (personal protective equipment) items and coffee pods are now easier to manage.
The mix of materials in items like disposable earplugs makes them complex and expensive to recycle. The solution is to collect, store and aggregate quantities of the same type of waste until there is enough volume to recycle it cost-effectively. TerraCycle, an American company with global operations is doing just that.
PPE items like hair nets, beard nets, earplugs, disposal gloves and masks can be recycled using TerraCycle’s Zero Waste Boxes. The waste boxes are a ‘done-for-you’ solution. You order a box that is designed for a specific type of waste, such as disposable gloves, fill it and ship it to TerraCycle’s partners using the pre-paid shipping label affixed to the box. All transport is carbon-neutral.
Zero Waste Boxes are available in North America, Europe, some Asian countries, New Zealand and Australia. They are business/industry suitable, and there are residential options for recycling household waste.
🍏 Important: This is not an endorsement for TerraCycle, nor is it a paid editorial, I just thought it was a great idea and wanted to share it 🍏
Food Fraud FAQs
What’s the Difference Between Food Fraud and Food Defence?
The difference between food fraud and food defence is that food fraud is done to make money, while food defence relates to acts that are done to create harm.
Food fraud perpetrators do not seek to cause harm, they seek to increase profits or otherwise benefit financially, so food fraud is said to be ‘economically motivated’. However, food defence attacks are not motivated by economic gain, they are done to cause harm to consumers and companies.
The difference between intentional adulteration and food defence is that intentional adulteration is the act of contaminating a food product with the intention of causing harm to the people who eat the food. Food defence encompasses the prevention of intentional adulteration and can also include the protection of equipment, assets and workers in food businesses.
What you missed in last week’s email
· A Listeria Cold Case Solved - What You Should Know About NGS
· Pay Disparity in Food Science Careers 😞
· The Daily Harvest Outbreak Mystery: Still Not Solved, But Progress Has Been Made
· Emerging Food Safety Issues: Here’s What Dutch Experts Are Thinking About – And We Should Be Too
Below for paying subscribers: food fraud incident reports; plus an audio version of this email, read aloud by the author.
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