Imagine more than 450,000 diners are preparing to order meals at NYC’s best restaurants for the 2017 NYC Restaurant Week. These diners are counting on a culinary experience after paying a hefty reservation fee. Now imagine that food at all the NYC restaurants has been intentionally tampered with, and diners are ingesting low-quality adulterated products. An entire network of people now are buzzing about the fraudulent food – word spreads rapidly. Widespread fear, social media blasts, and the press are all questioning the integrity of the NYC restaurants, the product itself, and the suppliers. It may take weeks to find the source of adulteration especially if there is an entire network of people to investigate. This is the dramatic side of food fraud, but it’s important to realize this scenario is possible.
On February 16, 2017 the Italian government arrested 33 suspects whose allegations include exporting fake extra virgin olive oil to the United States. According to Olive Oil Times, the suspects were involved in an elaborate olive oil scheme to import olive pomace oil, a product that’s extracted from already-pressed fruit pulp using chemical solvents, then labeling the low-quality, adulterated oil products as extra virgin olive oil and exporting it to the US. Those products were sold through retail chains in New York, Boston and Chicago. Retail chains that supply NYC restaurants products for high profile events such as NYC Restaurant Week. Such incidents could have a significant economic impact.
“From this example of olive oil, to substituting horse meat for beef, to adding crushed peanut shells to ground cumin, there are many examples of food fraud.” Earl Arnold, Global Manager of Food Defense and FSMA at AIB International. “Food fraud is a growing concern across the world.”
Selling fraudulent and misbranded olive oil might not concern everyone in the food industry, but the bigger issue is intentional adulteration for economic gain has the ability to cause: product reputation issues, industry credibility, economic impacts, loss of public confidence, effectiveness of government regulations, and disruption of trade.
Arnold said, food fraud can do a few different things. It can cost a company a lot of money when paying for a specific commodity, like honey, as an ingredient and receiving honey blended with corn syrup. Secondly, if the fraudulent ingredient poses a recall risk, add the cost of a recall and potential legal fees for all products that ingredient was added into. Brands could be damaged and it can take a long time to recover from this type of issue. Today, all certification schemes associated with GFSI include requirements to consider food fraud. GFSI requires some type of supplier assessment and mitigation strategies to prevent food fraud.
The changes to FSMA’s final rule on preventive controls released in December 2013, was largely designed to provide information on how companies will implement mitigation strategies, and ensure that the mitigation strategies are working as intended. In developing the rule, FDA interacted with the intelligence community and considered vulnerability assessments conducted in collaboration with the food industry. The goal of this rule is to prevent acts intended to cause wide-scale harm, including but not limited to food fraud.
“The preventive controls rule for human food regulation 21 CFR 117 requires you to consider economically motivated adulteration.” Arnold said. “This is food fraud that poses a known food safety risk to the consumer. During the hazard analysis you need to evaluate this risk and develop controls if a significant hazard is identified.”