Issue #62 | Hippo Torture | WTF is Food Laundering | HACCP + Microplastics |
What is food laundering (and why should we care)?
Microplastics in HACCP Plans
News and Resources Roundup
A new way to serve pumpkins, or hippo torture, you decide!
Food fraud incidents, updates and emerging issues
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Welcome to another week and welcome to Issue 62 of The Rotten Apple, the newsletter for food professionals that tries to entertain as well as inform.
The big story this week is a new concept in food safety called ‘food laundering’. It was introduced in a recently published paper by food fraud researchers from The Netherlands. I loved the paper which seeks to correct some of the problems that occur when using ‘old’ definitions in food fraud investigations.
Also this week, I perform a quick sanity check on microplastics in food. Should they be treated as hazards in your HACCP plan? Microplastics are all over the news at the moment, after they were discovered in human breast milk. They are obviously a food safety hazard. Or are they? Read on to find out what the science (really) says.
If you’re in a country that 🎃 celebrates all things spooky today 🎃 you’ve probably just had to stock your cupboards with an indecent quantity of sweets/candies/lollies. Enjoy the festivities, and the video I found for you. It’s of hippos celebrating Halloween (whether they want to or not!).
This issue ends with food fraud incidents and horizon scanning news, behind the paywall. Sorry, not sorry, this girl’s gotta pay for my neighbours’ kids’ sugar-treats.
Have a great day,
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Food Laundering - a New Concept in Food Safety
Food fraud academic papers: yawn. Food fraud definitions by academics: double yawn. I’m a total food fraud nerd and I still find many academic papers about food fraud hard to read. Some are just plain frustrating. But when Karen Gussow from The Netherlands writes a paper, I sit up and listen. And so should everyone else.
Her new paper, co-written with A. Mariet, asserts that definitions of food fraud from past academic papers just don’t cut it. Better still, their paper explains (exactly) why the old definitions are no good, based on dozens of real-world cases. And - best of all - they propose a better definition. Brilliant!
How the concept was ‘discovered’
Gussow and Mariet looked at 53 cases of ‘food fraud’ that had been investigated in The Netherlands and found that 22 of them - almost half - don’t actually fit with the well-accepted definitions and types of food fraud such as Spink and Moyer’s famous 2011 definition or their seven types of food fraud such as adulteration, concealment, tampering, etcetera.
These twenty-two cases were ones in which the fraud did not involve actual ‘food’ but instead concerned material that was illegally sold as food, such as animal byproducts that were unfit for human consumption, bootleg alcohol, illegally slaughtered animals, expired or spoiled foods and foods that were illegal because they contained high levels of contaminants like aflatoxins or heavy metals.
In a significant number of cases, the perpetrators were not dealing with the food materials directly but were doing things that would allow for food fraud to occur. Such things included the alteration of trade documents by a logistics business and the falsification of analytical results by a food testing laboratory.
Some of the cases - approximately half - did fit well with currently used definitions, such as perpetrators adding colourants to tuna flesh and falsely representing the religious status of foods.
The problem (and why it matters)
When food fraud definitions are not adequate, the authors say, “… public health risks caused by food fraud are assessed based on a limited or perhaps even skewed image of food fraud.”
For example, adulteration food fraud is a type of concealment, and substitution or addition can be both adulteration and dilution. In other words, multiple ‘types’ of food fraud are actually the same and this can make it hard to categorise incidents and organise data and information.
Put simply, if we aren’t capturing all food fraud scenarios properly in our definitions we can’t effectively mitigate the risks.
Having analysed the cases, the authors proposed a new food fraud definition that encompasses three concepts. Their new definition is able to capture food frauds that did not strictly fit within currently used definitions.
“Food fraud is committed by any actor who is intentionally involved in illegal acts for economic advantage, thus causing or facilitating illegal food to be laundered into the supply chain or for food to be fraudulently value-enhanced.” (Gussow, 2020, p. 113).
Three concepts: food laundering, fraudulent food enhancement and facilitative food fraud
The new definition captures three new concepts: food laundering, fraudulent food enhancement and facilitative food fraud.
Food laundering is turning illegal food, ingredients or materials into legal/legitimate products by physical techniques or by administrative/documentation falsification. For example, forging documents to make illegally-harvested fish or illegally-slaughtered meat appear to be legal, genuine ‘foods’.
“Food laundering encompasses the use of illegal material as food” Gussow and Mariet, 2022
Fraudulent food enhancement encompasses ‘classic’ food fraud types such as the addition of unapproved colourants to increase the value of a spice. It also, in this new definition, includes enhancements that do not involve physically touching or tampering with the food at all, such as falsifying the hypoallergenicity of a food by using a deliberately incorrect label.
Facilitative food fraud is perpetrated by actors who do not directly handle food. For example, a laboratory that alters analytical results for a food business and thereby facilitates the food business’ attempts to mislead their customer.
Food laundering, food safety and enforcement
Food laundering presents food safety risks, because it results in unsafe and illegal food entering the legitimate food supply chain. Fraudulent enhancement, such as adding harmful colourants to spices, likewise creates food safety risks.
But they are not the same thing. For the authors of this paper, food laundering cannot, by definition be the same as fraudulent food enhancement. This is because they say [quote] “Food cannot be both illegal/unfit and legal/fit for human consumption”.
For me, the problem is that in an international marketplace, food that is illegal in one place can be legal in another place. This could really muddy the waters when people use the term ‘food laundering’. I will be interested to see if this term gains wide acceptance and use.
In terms of food safety, I like to make a distinction between enhancements that involve physical techniques and those that only involve document fraud. This paper puts both types into the same ‘basket’. For example, adding colour to tuna to make it appear fresher, and illegal enhancement by claiming kosher status falsely, are both considered to be ‘fraudulent enhancement’ in the newly proposed definition. However, the food safety impacts of each type of enhancement are very different, which for me justifies different priorities in mitigations.
Other key takeaways
Food fraud - at least according to this paper - should also encompass agricultural inputs like using illegal pesticides or antibiotics in food-raising. (I agree).
Whether or not theft of food or drug-smuggling using food shipments counts as food fraud is a tricky question and one that the authors have addressed decisively - and perhaps controversially - in their paper. More on this next month.
🍏 The main source for this article is Gussow, K.E., Mariët, A. The scope of food fraud revisited. Crime Law Soc Change (2022). https://doi.org/10.1007/s10611-022-10055-w 🍏
Microplastics - Hazards for HACCP Plans?
It seems that every week someone publishes a new report of microplastics being found in food animals, milk, meat and even human breast milk. Obviously, that’s a problem. But is it a food safety problem?
I set out this week to discover whether microplastics have been proven to be hazardous to human health when ingested in food. Yes, eating micro and nano-plastics sounds bad, but do they actually just ‘go straight through’ without causing harm? Turns out the science is very much undecided.
What are microplastics
Microplastics are plastic particles that are less than 5 mm in diameter (from the WHO paper, referenced below).
Nano-plastics are plastic particles measuring between 1 nm and 1000 nm (nanometres) (also from the WHO paper). One micrometre equals 1000 nanometres.
What are the possible (food safety) risks?
There are three main risks that could be posed by micro and nano plastics.
The pieces of plastic themselves could cause harm when ingested.
The micro and nano plastics could be vectors for pathogens, by supporting biofilm formation.
Micro and nano plastics could be vectors for other chemical contaminants that would cause harm when ingested.
Are these significant risks?
Reminder: if a hazard presents a significant risk to food safety, it needs to be controlled in a food safety (HACCP) plan.
Microplastics are now considered ‘ubiquitous’ (everywhere) and have been found in food, so they are certainly being ingested. It is thought that particles greater than 10 micrometres (which are bigger than nano-plastics) are probably not absorbed or taken up by the body.
Nanoplastics are less well-studied. We do not yet properly understand how much is in our food. “Possible adverse outcomes” are suggested from dietary exposure to nano plastics, because they are hypothesized to have similar modes of action to other ‘well-studied’ insoluble particles which can generate oxidative species (‘free radicals’) and stimulate inflammatory responses.
“The available data are of only very limited use for assessing the risk of NMP [nano- and microplastic particles] to human health” WHO report Dietary and inhalation exposure to nano- and microplastic particles and potential implications for human health (2022)
As for biofilms, not much is known about biofilms on microplastics, but there is little evidence that they pose a unique/new risk to human health. Even less seems to be known about chemical hazards from microplastics and nano-plastics. The WHO report says: “It is therefore not currently possible to characterize or quantify the potential role of NMP [nano- and microplastic particles] in the transport of chemicals.”
The short answer is, we just don’t know yet if these present significant risks when ingested in foods.
Right now there is no definite evidence that micro- or nano-plastics pose significant food safety risks to consumers. The particles that seem most likely to be hazardous are those that are smaller than 10 micrometres in diameter because they are the ones that are more likely to be absorbed or ‘taken up’ by the human body.
These particles are now considered to be ubiquitous in the environment and food, so formulating controls for such hazards could be a challenge. Watch this space.
The main source for this article was a new WHO paper on microplastics (2022). Get it from here: https://www.who.int/publications/i/item/9789240054608
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News and Resources
No algorithm, just dedication… a carefully handcrafted selection of the best food safety news and resources from around the globe. Our news and resources section is expertly curated (by me! 😎) and free from filler, fluff and promotional junk. Click the preview box below to access it.
A New Way to Serve Pumpkins (or Torture Hippopotamuses?)
After watching this video posted by Cincinnati Zoo, I have come to the conclusion that hippos either really like crunching up pumpkins. Either that or they are obliged to crunch the pumpkins put into their mouths by the zoo keepers so they don’t choke to death 😕!!
What you missed in last week’s email
• Risks with Carbon Neutral Claims
• Burkholderia cocovenenans – the food pathogen you might not have heard of
• Food Safety News and Resources Roundup, including encephalitis from cheese
• Food fraud incidents, updates and emerging issues
Below for paying subscribers: Food fraud news, incident reports, and emerging issues, plus 🎧 audio 🎧 for busy professionals
📌 Food Fraud News 📌
A New Resource for Food Businesses
Another new (huge!) peer-reviewed paper has been published. It covers multiple areas of food fraud mitigation and is very comprehensive. It includes a section about how food fraud is regulated and enforced across different countries and detailed instructions about how food companies should manage their supply chain vulnerabilities. And, if that wasn’t enough,
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