Issue #90 | Checklist Mastery | Rewards for Whistleblowers | Reusing Glass Bottles | Crystal-clear Gravy??!

2023-05-29

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.

• Audit checklist mastery

• Rewards for whistleblowers

• Reusing glass bottles

• News and Resources Roundup

• Crystal-clear gravy (just for fun)

• Food fraud news and incidents

Hello lovely readers,

Welcome to Issue 90. A huge thank you to everyone who has renewed their subscription in the past few weeks. I’m delighted to report a 100% retention rate for paying subscribers 😀 - so glad you are getting value from your subscriptions!

This week I’ve got a super-helpful piece on how to create brilliant internal audit checklists (okay internal audits are YAWN, but a good checklist can help).

Also this week, an exploration of whistleblowing, including the results of last week’s poll. Anecdotally, I have noticed that many food fraud incidents are revealed by insiders, so I think whistleblowing is incredibly important for protecting consumers from the risks it poses. My feeling is that people are more likely to tip off authorities over food fraud if they suspect it poses a risk to food safety. I have no hard data because, as far as I am aware, it has not been studied or quantified. If you are a food fraud academic or post-grad, perhaps this is a topic for you?!

As usual, in this email there’s a link to this week’s food safety news and resources. It includes news that is unusual or unexpected - not just a long list of boring recalls, plus free training sessions.

Also this week, is it safe to reuse glass bottles for beverages? I reckon it is. The bottle-washing process is pretty robust. Plus, crystal-clear gravy, so you can see your meat - a fun spoof advert.

Food fraud news and incidents can be found at the end of every email, for paying subscribers. There’s also a human-friendly 🎧 audio version, so you can give your eyes a rest (and enjoy my Aussie accent 😏).

Thank you for being here,

Karen

P.S. Keeping these newsletters independent and ad-free is hard work! Please consider a paid subscription for access to extra features like indexed posts, downloadable past issues and monthly supplements.

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Audit Checklist Mastery

I’ve seen some shocking internal audits over the years. (I’ve probably done a few that weren’t as good as they could have been too 😟!)

At the heart of all good internal audits is a strong checklist which clearly lists requirements, helps the auditor get the job done efficiently and makes sure they don’t miss anything.

In this month’s supplement for paying subscribers, I describe best practices for making robust, user-friendly auditing checklists.

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Blow That Whistle

Ray Dirks was an insurance company analyst.  In 1973 Ray was told about a massive scam being perpetrated by senior executives in a publicly listed insurance company in the USA. He decided to reveal it to financial regulators.

After blowing the whistle on the fraud, Dirks was left fearing for his life - a contact warned him to switch hotels and use an alias so that he wouldn’t meet with an ‘accident’. He was also accused of insider trading because he warned other people about the fraud before going to the regulator. He ended up in the Supreme Court trying to clear his name.

Dr Yasmine Motarjemi, the former global head of food safety at Nestle, also blew the whistle with disastrous consequences for herself. After a ten-year legal battle, a Swiss court found in February 2023 that she had been bullied and “forced out of the company”.

Unfortunately, Dr Motarjemi’s whistleblowing does not seem to have had the impact she desired. In March 2022, years after she left the company, 56 people became ill with enterohemorrhagic E. coli linked to flour in Nestle pizzas. Two people died. This outbreak was alarmingly similar to one in 2009, in which Nestlé was responsible for another enterohemorrhagic E. coli 0157 outbreak in the United States, also due to contaminated flour, but this time in cookie dough.

The 2009 outbreak should have meant that Nestle was aware of the risks posed by enterohemorrhagic E. coli contamination in flour. When Dr Motarjemi raised the alarm with Nestle's upper management in 2009, she said she was ignored, humiliated, slandered and had her position downgraded.

This was a failure of whistleblowing, one in which internal concerns were ignored.

Nestle did not have enterohemorrhagic E. coli “on their radar” for flour, said Dr Motarjemi, in a virtual event I attended earlier this year, even though it had previously caused the toll house cookie dough outbreak.

Dr Motarjemi also suggested there had been failures with regulatory inspections in the pizza case because regulators had failed to follow up, she said, after seeing hygiene problems at the plant. Third-party audits to ISO 22000 standards also failed to succeed in eliminating the E. coli risk.

Regulators and certification bodies have a lot to lose when whistleblowers speak out about the companies they regulate and audit: the whistleblower is not only revealing problems at the company, but is also implicitly accusing the regulator or auditing body of being ineffective or even negligent.

Regulators and auditors should also be ‘blowing the whistle’ but are actually much less likely to do so than company employees, according to researchers who reviewed large financial frauds in US companies. Among the frauds the researchers reviewed, employees revealed as many cases as auditors and regulators put together.

Employees are best positioned to reveal problems in companies like Nestle because they have access to more information than auditors and regulators. For example, employees in the food-safety-pork-UK-scandal that was revealed earlier this year said that when auditors arrived at their facility for an unannounced audit, managers would give them a cup of tea to keep them busy while other employees hid suspect products on lorries and took them off-site for the duration of the audit.

One employee even claimed that if the meat could not be hidden on vehicles, workers would be ordered to put it onto a trolley and push it around the factory, staying out of the way of the auditor so it would not be seen.

But if employees are the best people to report problems in food safety, they also have the most to lose. Cheryl Eckhart, the QA Manager at a large pharmaceutical company said she lost both her job and her friends when she reported medicines being made in appalling hygiene conditions and with contaminated water at one of her company’s facilities.

It is not just senior employees who have a lot to lose if they ‘blow the whistle’. Employees at the UK pork processor said they were afraid to speak out over fears they would lose their jobs, or be given worse tasks by managers.

But if whistleblowing is important to food safety and food fraud detection, how do we get employees to come forward?  Tim Harford, economist and author of a podcast episode about whistleblowing, says that the key is for companies to create a culture in which whistleblowing is seen as being loyal to the larger community and company instead of being disloyal to your immediate colleagues.

And then there is money.

Monetary rewards for whistleblowing do work. When there is an opportunity to receive a payout for information, that can increase employees’ motivation to report a problem, says Harford.

South Korea rewards people who provide tip-offs about tax frauds, unsafe food, unlicensed medical products and more.  In the USA the False Claims Act allows for rewards for people who alert the government that it is being ripped off by a supplier.  Under the act, Cheryl Eckhart got a payout related to the dangerous medicines produced by her former employer, because they had been purchased by the US government for welfare programs. Her payout was $96 million.

While $96 million seems like a lot of money for a Quality Manager who was, after all, just doing her job, researchers who interviewed whistleblowers reported that most would not do it again if they were in the same situation, because it was not “worth the stress”.

We do need people to speak up when they see something that is not right in food production. A significant number of food fraud cases are revealed by tip-offs from insiders and suspicious consumers*. Lives can be saved when whistleblowers prevent food safety outbreaks.

Results of last week’s poll

In last week’s poll I asked if you were aware of where to report a food safety or food fraud concern.

The good news is that more than half of you know where to report a problem outside of your company, hooray. The bad news is that one-third of respondents didn’t know there was a way to report such problems.

Results of last week’s poll on whistleblowing

How to blow the whistle (in any industry)

There is an organisation dedicated to helping whistleblowers disclose problems safely and effectively, and to survive the fall-out. You can find their website here:

https://www.whistleblowingimpact.org/topics/post-disclosure-survival-strategies/information-for-whistleblowers/

*I don’t have a peer-reviewed source for this: to my knowledge, it has not been quantified by academics.

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Food Safety News and Resources

Our news and resources section includes links to free training sessions, webinars and guidance documents: no ads, no sponsored content, only resources that I believe will be genuinely helpful for you.

Click the preview box below to access it.

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Today I Learned… Bottle Washing (How it’s Done)

Should we be helping the planet by returning to a system for reusing glass beverage bottles like in the ‘olden days’?

This is an area that has been discussed desultorily in my country for a while now.  It seems sensible, but also a pain in the neck to implement.

When I worked for Coca-Cola (the brand owner, not the bottling plant) in Australia in the 1990s our QA lab would check the quality of products from all over the South Pacific, making use of ‘secret buyers’ in countries including Papua New Guinea, Tonga, Tahiti and New Zealand.

We checked pH and brix (sugar), caffeine content, carbonation and even how much torque was needed to unscrew the caps on the plastic bottles. And we checked the condition of the returnable glass bottles that were used by bottling plants in most Pacific island countries.

In many Pacific countries, glass was expensive, and bottle return and reuse systems were extensive. Coca-cola had photographic standards for acceptable and unacceptable levels of scuffing on reused bottles and the bottling plants were not supposed to refill bottles that were too scuffed from repeated use.

Each bottle had a date on the bottom which we would check and record in the QA system. The oldest I saw was from 1958 - it had been circulating in the system for more than 30 years.

So I knew that bottles were reused, but I didn’t know how they were made safe and sanitary for refilling.

A member of the International Food Safety and Quality Network (IFSQN) recently described how his/her company used to wash and reuse beer bottles in the 1980s:

“We would wash the bottles in a machine called a soaker.  It had rinse water pockets and hot caustic solution pockets plus several rinse water pockets and a rinse water jet. 

The bottles were pushed into carriers… [which would carry them] through the various pockets.  After washing, the bottles were conveyed to the filler.  Prior to filling, we had an empty bottle inspector camera system set up which would take a photo of the inside of the bottle and the finish [exterior surface] and reject any bottle that had foreign matter and/or glass fragments plus any bottle that had a broken finish.  [The camera] was calibrated daily.”

Thank you to IFSQN member lorlandini

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Crystal-Clear Gravy - Just for Fun

Who remembers Crystal Pepsi?  It was Pepsi that was completely clear.  It had the same flavour (almost) but was marketed as a clear and funky new alternative to classic Pepsi.

The TV show Saturday Night Live was amused.  So they created an advert for ‘Crystal Gravy’.

I love it!

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What you missed in last week’s email

• Would you know how to ‘blow the whistle’ on a food safety issue? Do the poll!

• Supplement fraud - two companies share their challenges

• Failures at major meat plants - it ain’t ethical but it (sort of) ain’t their fault?

• TikTok trends with a food safety/food fraud twist - Just for Fun

• News and Resources Roundup

• Food fraud news, incidents and updates

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Below for paying subscribers: Food fraud news and incident reports, plus an 🎧 audio version of this issue 🎧

📌 Food Fraud News 📌

“High cost didn’t guarantee purity or quality” say food fraud researchers

Researchers who studied food fraud and quality in avocado oils said that the cheaper oils were more likely to be fraud-affected but that more expensive oils were not necessarily free from adulteration. They checked the oils for quality and adulteration markers and found