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The Fight Against Food Fraud

​FOOD FRAUD HAS BEEN A PROBLEM SINCE ANCIENT TIMES, when Pliny the Elder was known to complain about the prevalence of fraudulent Roman wine. Food fraud generally refers to the deliberate substitution of, addition to, tampering with, or misrepresentation of food, food ingredients, or food packaging. And although food fraud tends to be done for economic gain rather than to intentionally hurt people and animals, it can have deadly consequences. Globalization has only increased the scope of food fraud and the range of any fallout from dangerous ingredients.

Since 9-11, the government has focused more resources on protecting the food chain from possible terrorist attempts to cause harm, but attention is slowly shifting toward the detection and prevention of food fraud. “Now there’s this recognition that the bigger problem may be that people are adulterating [food] to make a buck,” says John Spink, leading food fraud researcher and associate director and assistant professor within the Anti-Counterfeiting and Product Protection Program (A-CAPPP) within Michigan State University’s School of Criminal Justice.

Take the example of melamine in milk and baby formula in China a few years ago. Melamine is a chemical that is used as a fertilizer and as an ingredient in plastics and concrete. It can also help foods like milk appear to have a higher protein content, which comes in handy when a dishonest milk manufacturer wants to sell diluted product. Unfortunately, melamine also causes kidney problems when consumed in large enough quantities. That is what happened in 2008, when hundreds of thousands of Chinese infants became sick after drinking milk and baby formula that was full of melamine.

A World Health Organization official was quoted as stating that this was “clearly not an isolated accident, [but] a large-scale intentional activity to deceive consumers for simple, basic, short-term profits.” Chinese milk powder exports were drastically reduced worldwide, and steps were taken by organizations like the U.S. Food and Drug Administration (FDA) to limit the amounts of melamine allowed in food products. Melamine was the culprit in a pet food recall in the United States in 2007 as well. In that case, imported ingredients were tainted with melamine.

One of the challenges in trying to detect the problem is that it is often difficult to know if a product has been diluted or tampered with just by taste, and many of the tests that look for the presence of a certain ingredient or chemical don’t measure exactly how much of that chemical is present, says Spink.

The field of experts hoping to find ways to prevent food fraud face a range of challenges. We look at some of these issues and the progress being made.

There are many types of food fraud; the umbrella includes everything from adding ingredients that should not be in the food to mislabeling fish as a more expensive type. Some of what gets grouped into the discussion, like medicine, isn’t food per se, which leads to some confusion and disagreement about terminology. For example, the term “economically motivated adulteration” (EMA) is often used synonymously with the term “food fraud.” However, the U.S. Pharmacopoeial Convention (USP), a scientific nonprofit that sets standards for drugs and food ingredients among other things, considers EMA as a specific type of food fraud.

The USP sets federally enforceable standards for drugs. It also publishes the Food Chemicals Codex, internationally recognized standards “for determining the purity and quality of food ingredients.” The FDA recognizes these standards as defining “appropriate” food grade within sections of the food additive regulations. However, the standards can be superseded by acts of Congress and other FDA regulations.

While globalization has allowed food fraud to spread and can lead to more people being hurt by the fraud, it has also made the topic easier to study, according to Spink. “It’s like a disease; when there’re very few outbreaks of the disease, we treat it when people come to the emergency room, but we don’t really understand how to prevent it or how it replicates. The same thing with food fraud. We now have enough big cases and enough cases across the world where we’re able to put it together and really study what’s the nature of this fraud activity,” says Spink.

But the nature of food fraud is constantly changing. As with many types of counterfeiting, once the authorities are onto the bad guys, the bad guys are usually smart enough to have abandoned the thing that will get them caught (like melamine) and have figured out their next step.

“A lot of times you feel like you’re chasing things that have already happened [and meanwhile] …the perpetrators will come up with some novel way of adulterating something,” says Karen Everstine, research fellow at the National Center for Food Protection and Defense (NCFPD) at the University of Minnesota.

That makes developing useful detection and response protocols difficult. Adding to the problem is the range of potential types of fraud. “It manifests itself so differently in all the different types of food products,” notes Everstine.

In the face of all of these obstacles, researchers seek methods they could use to provide early warning or detection across multiple food products, she says. The first step is to gather as much data as possible. That means taking advantage of whatever data sources already exist, “so we wouldn’t have to put out a ton of new resources to collect data,” says Everstine.

The good news is, “we really feel like we’re starting to get a handle on some of these data sources that can be helpful,” Everstine says. Among those sources is information collected by border authorities on imported food. That data might help pinpoint anomalies in the supply chain that could lead to information about food tampering.

Once data from existing sources is collected, the next step is to see what can be done with it in terms of analysis. One example of this is what is being done by Spink and his group. In an attempt to quantify known cases of food fraud and pinpoint the types of ingredients and products that are being tampered with, Spink and others have compiled The Food Fraud Database for the USP. It is the first database that outlines and tallies incidents of food fraud. Studying this data tells researchers what types of foods are most often adulterated and how they are adulterated, which may ultimately help authorities decide what they should be testing for.

For example, if a juice company diluted apple juice with water, the consumer “might just think it’s a little light, or the apples [for juice] weren’t as strong this season, but the company can then reduce the costs of producing that product by 5 percent,” explains Spink.

According to a Journal of Food Science article discussing the database, some of the top fraudulent foods are olive oil and milk. These are liquids that can be diluted by using lesser oils for the oil or lesser proteins for the milk, as in the melamine example. One of the few foods among the top food fraud incident examples that was not a liquid was saffron, which is known to be the world’s most expensive spice; it often fraudulently contains sandalwood dust and starch.

In addition to liquids, some solid food makes an easier target for food fraud than others. Amy Kircher, associate director of NCFPD, explains that processed foods or foods with multiple ingredients are easier to adulterate. “For instance, it’s obviously not easy to adulterate a head of lettuce, but it’s easier to adulterate a processed product, because you can introduce something into it, like a blend or a spice mix,” says Kircher.

Quality assurance. Everstine’s group is also looking at different quality assurance methods and assessing the vulnerability in different steps in that quality assurance process. She says the end goal is to go to the USP and provide it with information that will allow it to update its methods.

In some cases, the issue is whether a company is getting the ingredients it thinks it is getting from its supply chain partners. Everstine’s group is working on issues related to that as well. They are doing research to see whether they can “flag some of the ingredients that might be a higher risk so then food companies would know ‘okay, so for these ingredients, maybe we need to do a better job of verifying our supply chain or use other methods to ensure that the ingredients aren’t adulterated,’” says Everstine.

Government and Industry
The United States and other governments have turned more attention to EMA and food fraud in recent years, and they are both included in the purview of the White House’s federal food safety working group. Additionally, the International Organization for Standardization is working on countermeasures to food counterfeiting. And Spink says that, in addition to the various organizations researching the issue, the Institute of Food Technologists, the Grocery Manufacturers Association, and Global Food Safety Initiative are increasingly looking at food fraud.

The Food Safety Modernization Act (FSMA) was signed into law in the United States in 2011. David Acheson, partner and managing director of food and import safety for Leavitt Partners, worked on the early versions of the act with the FDA and now helps companies interpret it. According to Acheson, the section in the law that deals with intentional contamination of food and the law “makes it clear that food companies are going to have to focus on building preventive control systems” to control contamination. However, the term “intentional contamination” covers terrorism and intentional tampering for harm as well as economic food fraud, explains Acheson. The rules had not yet been released on the relatively new law at press time, so it was unclear how much FSMA would truly address food fraud for economic reasons rather than contamination with the aim to harm. “My instincts tell me that the focus is on the terrorist side,” says Acheson. Don Hsieh, director of commercial and industrial marketing with Tyco Integrated Security, says the law stresses putting preventive controls in place, rather than reacting after the fact. However, he says that it’s too soon to tell whether that could help curtail food fraud.

Acheson says he “would be surprised if the FDA is particularly prescriptive around EMA, partly because it’s so difficult to know exactly how to manage it.” A law needs to be very specific for implementation, says Acheson, “and I think this area is a little too gray at the moment for the FDA to really put much focus on it.” There is emphasis in FSMA on controlling supply chain risk, however.

Last year, the Government Accountability Office (GAO) released a report criticizing the FDA’s efforts to prevent adulteration. The FDA does recognize food fraud and has an EMA working group looking at the issue, but at the time of the GAO report, the agency had not even adopted a single clear definition of EMA that the entire agency would recognize. Additionally, the GAO criticized FDA for not collaborating enough throughout the agency.

Some progress has been made since the report’s publication, however. The GAO’s Alfredo Gomez, acting director of natural resources and environment, tells Security Management that the FDA now has an organization-wide EMA definition, and the agency has made progress on the GAO’s recommendation to provide guidance to agency centers and organizations on addressing EMA.

As an example of some recent FDA action, Gomez cites the FDA’s efforts to curb the mislabeling of seafood.

Industry Efforts
Private industry is also working on its end to improve systems for preventing and detecting food fraud and EMA throughout the global supply chain. Spink says that businesses, both directly and through group organizations, have become more involved in fighting food fraud in recent years. A major concern from the perspective of business is preventing counterfeit goods that not only siphon off profits but also risk harming the brand because people who find the product substandard or harmful won’t know it was counterfeit.

Even so, says Acheson, food fraud is not as much of a pressing issue for business as conventional food-safety issues such as salmonella in peanut butter, for example, because those incidents tend to be more deadly. However, more attention is paid after an economic-fraud issue that causes illness and death, such as the melamine scares. For example, the melamine incidents shifted the problem from just economic adulteration to a food-safety problem and public-health risk.

Companies should be more aware of how a food fraud incident can wreak havoc on brand strength and reputation, says Hsieh. He advocates traditional security methods of protecting the supply chain that he calls the “four As of brand protection.”

The first A stands for assessing vulnerabilities in the supply chain. The next A is access control, which means keeping outsiders from having the opportunity to do harm. Of course, the company must also have safeguards against tampering carried out by insiders.

The third A is alerts. “This is really about being more proactive versus reactive,” says Hsieh. He cites various sensors and how they can be used better. For example, he says that the temperature of food is often taken at the beginning and end of a journey, but if something has gone wrong in the middle, no one would know. “If you’re monitoring temperatures throughout that journey with temperature sensors, you can get alerts that … [the temperature on this food is reaching dangerous levels, and we need to] reroute it to the closest grocery or what have you, to kind of preserve those products.”

And in terms of security alerts from a physical perspective, there are options such as information management solutions where you’re monitoring multiple alerts whether it’s the door alarm, video alarm, motion sensing alarm, and then really kind of optimizing and prioritizing alerts that affect you, says Hsieh.

The final A is auditing to ensure that the system and tools work. Acheson points to Dun & Bradstreet’s (D&B’s) program called Duns Verified that is meant to complement standard food-safety audits. Thomas Marsden, director of business development for D&B, says the Duns Verified product was originally designed for use by government agencies; but can be adapted to the private sector. It involves D&B personnel interviewing and visiting foreign food suppliers on site to see that the factory is as it is claimed to be and to verify information they have provided.

“Our government agencies are hard-pressed to make visits to these sites abroad. It is costly to undertake those efforts, and as a result, we saw an opportunity to help support our customers,” says Marsden. The FDA is a client of Duns Verified. Marsden says, “It’s like a third-party certificate that gives them a little more confidence in the information that’s otherwise shared directly with them by the exporter and for which there’s a limited amount of verification you can do without going on site.”

The Duns Verified program is now being used by importers like Walmart as well, and D&B is branching out doing increased site visits in various countries in Asia and Latin America. The program does not test ingredients, however.

Another risk to consider in the supply chain is whether there are companies supplying products that are financially unstable or devastated by natural disaster, for example, and that might be tempted to turn to food fraud, says Acheson. He says that there are “not yet really good systems” to figure out which companies are more vulnerable to this type of thing, but he believes companies are looking at this threat as a part of their overall supply chain risk management strategy.

Acheson adds that even though large companies are constantly looking at food fraud and trying to determine how much money they’re losing because of it, it might take bigger episodes of obvious harm or financial loss to draw more attention to the issue.

Security Managers
Security managers can become more involved in preventing or detecting food fraud, according to Spink. “A real key for security managers and procurement managers is to have good relationships and know who you’re buying from, your suppliers,” he says. It is also advantageous to buy from companies that are reputable and known, and have a vested interest in keeping a good reputation. That means companies may want to avoid buying products through brokers or through anonymous sites like Internet auction sites.

In-house security can also be on the lookout for counterfeit products. “[S]omeone that selects vendors, they need to be aware of the type of fraud that goes on where they’re sourcing products. If they’re contract manufacturers, the people who manage the contract manufacturers need to be aware of the type of fraud that goes on there…how products might get diluted in the system. And the same with products in the marketplace; [they need] to monitor products everywhere to see if [their] brand is showing up where it shouldn’t be showing up,” Spink says.

Food fraud is a difficult problem to prevent and detect, and the consequences of missed incidents have proved deadly. Though illness and death are the incidents that draw more attention to the problem, companies must also contend with the economic damage a food fraud incident can cause. No matter what the incident, it is essential to catch food tampering before the food makes its way to the dinner table. Researchers and members of government and industry are devoting more resources to doing just that, but all those involved acknowledge that there is no easy solution.