10 replies to this topic

[GMO]

Hi All, 

 

reading an old thread, I was wondering a bit about VACCP and how useful it has been.  I'm not saying it's not helpful, that it's not good practice to run through ingredients and understand the risk they present.

 

But... is it actually making consumers safer?  And a secondary point to that, are consumers actually getting what they pay for even if it's safe?

 

With the rewards for food inauthenticity being huge, but the penalties in most countries are tiny and recalls rare if food safety is not impacted, what is genuinely stopping malicious actors from economically based food fraud?  It's not our VACCP plans.  And let's face it, a lot of us spend a long time looking at what has come before rather than what could happen.

 

With headlines like this far off the front page, and, to my knowledge, no recalls associated with these tests, are we just doing this for due diligence rather than actually keeping people safe and not defrauded on quality?

 

All UK honey tested in EU fraud investigation fails authenticity test | Food | The Guardian

[TimG]

 

With the rewards for food inauthenticity being huge, but the penalties in most countries are tiny and recalls rare if food safety is not impacted, what is genuinely stopping malicious actors from economically based food fraud?  

The good actors, I guess. As a bottler (honey packer) we pull composites on EVERY SINGLE incoming lot/load and send them out to a lab in Germany for two different adulteration tests.

I can't say I've heard of (or maybe just don't remember VACCP) but we definitely have a food fraud mitigation program in place. I have rejected a few loads since I've been here. But I also seriously doubt those loads are being shipped back overseas. Most likely it's being purchased by your less savory actors and being bottled somewhere else here stateside.

[GMO]

The good actors, I guess. As a bottler (honey packer) we pull composites on EVERY SINGLE incoming lot/load and send them out to a lab in Germany for two different adulteration tests.

I can't say I've heard of (or maybe just don't remember VACCP) but we definitely have a food fraud mitigation program in place. I have rejected a few loads since I've been here. But I also seriously doubt those loads are being shipped back overseas. Most likely it's being purchased by your less savory actors and being bottled somewhere else here stateside.

 

Yes, the likes of food fraud.  Specifically that impacting food safety but also authenticity is normally included as well.

 

All the way to Germany?  What for?  Sounds a crazy long time to wait.  And if the supplier isn't then providing proof of destruction in a way you are trusting they have (and also explaining how it got past their systems) why are you still using them?

 

An aside......

 

An auditor once explained how the plant got away with the horse meat scandal.  Of course the signs should have been there in these ways:

• Mass balance
• The low cost of the beef..

 

But what they did was hollow out beef and pack it with horse meat.  Froze it so the only realistic test on arrival at plant possible would have been whatever they could quickly cut off and sample before it went to defrosting.  That would have been beef.  Meat gets defrosted and the whole lot goes through the mincer.  Now you have a mix but it's long past the point where you're testing.  By that point you just accept it's right.

 

That's why I'm super suspicious that a determined fraudster couldn't escape detection and I'm even more suspicious that sampling will ever be thorough enough at any intake to be enough.  Buy that product in pails?  I'd make sure all the pails on the top, sides and first couple of pallets at the back will be the right product but the ones in the middle would be the fake stuff.

 

Perhaps I should change career....  

[G M]

...

That's why I'm super suspicious that a determined fraudster couldn't escape detection and I'm even more suspicious that sampling will ever be thorough enough at any intake to be enough.  ...

 

I'd agree with you completely on that.  Someone who has experience can easily think of ways to bypass the typical protections against fraud, and unless you're paying for some ridiculously thorough testing you can't prevent most of it.

 

The first few food fraud evaluations I did got some feedback from auditors indicating they thought I was judging the fraud risk too harshly, or undervaluing the token testing and verification being done.  With a background in molecular biology I know the level of testing necessary to truly verify and validate with statistical confidence is never going to happen. I changed it to meet their expectations -- but just view it as theater.

[GMO]

I'd agree with you completely on that.  Someone who has experience can easily think of ways to bypass the typical protections against fraud, and unless you're paying for some ridiculously thorough testing you can't prevent most of it.

 

The first few food fraud evaluations I did got some feedback from auditors indicating they thought I was judging the fraud risk too harshly, or undervaluing the token testing and verification being done.  With a background in molecular biology I know the level of testing necessary to truly verify and validate with statistical confidence is never going to happen. I changed it to meet their expectations -- but just view it as theater.

 

That is EXACTLY it.  If you look at the level of sampling required to confirm absence of a contaminant, considering it will almost certainly not be evenly distributed and secondly a fraudster is very likely to make sure any easily accessible sampling points are right, it makes it a farce.

 

To my mind three things need to happen.

• Firstly any adulterated foodstuff found should be recalled and (evidentially) destroyed.  It's clear that isn't happening from the low level of honey availability issues, even if it's found by regulators!
• Secondly, increase the offences for food fraud and make them heavily financial as well as legal.  Find one product in the market place?  Assume it's the 100th time they've done it and fine accordingly (it's probably an underestimate).
• A lot more regulatory testing.  It will never reach the levels it "should" to detect every issue but too much of this is being put to manufacturers who themselves could decide to turn a blind eye.  Fund it through taxes to manufacturers if you like but they'd benefit too if all results are available.

[TimG]

Let's face it, there are little to no repercussions and there is also a group of consumers who might not be as concerned about it as others. We recently lost a rather large account because a competitor came in at a price point we were highly skeptical of. Our VP bought some of our replacement off the shelf, I sent it out, and it failed for adulteration HARD. He passed on that info, and they kind of did the 'well it's one time' dance. He then pulled another a month later which we verified was a different lot. Sent it out, failed again hard. Well gee corporate buyer, I wonder how you got 'honey' at that price...

[GMO]

Let's face it, there are little to no repercussions and there is also a group of consumers who might not be as concerned about it as others. We recently lost a rather large account because a competitor came in at a price point we were highly skeptical of. Our VP bought some of our replacement off the shelf, I sent it out, and it failed for adulteration HARD. He passed on that info, and they kind of did the 'well it's one time' dance. He then pulled another a month later which we verified was a different lot. Sent it out, failed again hard. Well gee corporate buyer, I wonder how you got 'honey' at that price...

 

I don't know if you can do as you can in the UK but I'd be contacting trading standards and the EHO with that info or your equivalent competent authorities.  It's wrong it's not taken off shelf and there are zero penalties.

[TimG]

 It's wrong it's not taken off shelf and there are zero penalties.

 

$$ makes things right, that's capitalism. It's under their label, and they claim they've ran their own tests. With the state of honey adulteration testing, that might even be true. We run 2 of the 3 tests considered the 'best' by the honey industry (one for C3 sugars, one for C4), but there are fringe tests out there that won't pick up tailor made syrup doping until it's around 50%. Could they be passing that and failing our LC-HRMS? Absolutely! 

[jfrey123]

I'm just sitting here having flashbacks to a short clip online from some documentary.  It showed a bunch of lower income people in an Asian country using syringes to inject head on prawns with a salt brine, one by one, done to increase the weight of the order they were about to ship to the US.  Shady practices are all over the industry, hard to account for human ingenuity when it comes to deception.

 

But then I'm reminded that grocery stores are allowed to account for the weight of the dry pad that they place in the styrofoam trays in the meat section and include the weight in the sold by weight price.  Next time you buy a pair of 16oz ribeye steaks to share with the spouse on Valentine's Day, more likely than not you've got a pair of 13oz steaks with a dry pad ready to burst from oversaturation.

[Karenconstable]

Love this question (Does VACCP actually work to improve food safety outcomes?) I ponder it often. 

 

You're probably aware of the massive recall and scandal from lead in cinnamon-apple puree in the US in 2023-2024? 

 

That whole sorry saga should have been prevented with VACCP (better terminology: 'food fraud prevention program').  The manufacturer of the apple puree had a GFSI certification (can't remember which one), and so it definitely had a food fraud prevention program.  But the system didn't work. 

 

Reminder: the apple-cinnamon purees made by that manufacturer contained high concentrations of lead.  It was only discovered after sharp-eyed epidemiologists went looking in the pantries of a bunch of kids who had lead poisoning.  The number of cases of lead poisoning ended up in the multiple hundreds.  There were millions of units of products recalled. The US FDA's working hypothesis is that the lead was present in the cinnamon because it was added in the form of lead chromate to change the colour of the cinnamon powder - classic food fraud. 

 

Whoever did the food fraud prevention program for the puree manufacturer decided cinnamon wasn't vulnerable to food fraud, or decided it was vulnerable but didn't implement mitgations that included testing for lead. 

 

BTW if I had a dollar for every time someone showed me a food fraud mitigation plan that relies on: "Letter of guarantee from supplier"....

 

Thing is, would I have expected lead chromate adulteration in cinnamon?  Maybe not.  Even as a food fraud expert I may not have identified that as a potential problem.  Lead chromate is added to turmeric all the time, but cinnamon?  No. 

 

So, yes, VACCP is definitely a good idea, but it doesn't always work.  

 

And yes, food fraud vulnerability assessments and mitigation plans do sometimes work, as we just heard from Tim the honey man (thanks for sharing your insights, Tim).  But they aren't foolproof and many aren't worth the paper they are printed on. 

 

Great question, GMO, hopefully when you ask in a few years' time the answer will be more positive. 

[GMO]

The chemist in me is urging people to do basic testing for incoming materials.  HPLC, mass spectrometry, IR, NMR.  All of them can be useful to look for the unknown and unusual.  This would be prime areas for investment in AI as well.  If you compile a strong history of what "typical" looks like you can then look for the unknown without knowing what you're looking for.  The technology exists.  But there is no pressure to use that technology.

 

Why?

 

As is the case with any change or investment, where is the financial pressure coming from for me to take this action?  Of course I should be taking it for ethical reasons but let's work this through.

 

The plans I've had in any business are "good enough" but finding a problem by testing is fraught with risk.  As soon as you know something, you can't unknow it.  But as the person who finds it, you can't then ethically put something on the marketplace which could be contaminated (nor legally under UK and EU law under the "know or have reason to believe" requirement). 

 

I think we're living in a world where the adulterers of food are getting away with it or having a minor wrist slap and the manufacturers are only looking hard enough to satisfy standard requirements.  Until I start seeing regular public recalls for foods which are regularly inauthentic (honey, olive oil*) then I doubt anyone (legislators included) are taking this seriously.

 

It will take two things.  A change in law and a change in penalties.  Right now the incentive for businesses is not to look too hard and as in your case, that could lead to harm.

 

*I recently had a bottle of "extra virgin olive oil" from a UK discounter and when tasting it (I eat a lot of salads), it was obviously rapeseed.  The flavour was completely wrong.  We are all consuming inauthentic foods every day.  And if they are not labelled with what they really are, if the trace is faked, you have no idea what else is going on.  I went back to my Morrisons cold pressed (brilliant olive oil by the way) and put it down to experience.  But who else just didn't notice?