The U.S. Pharmacopeial Convention (USP) Monday released a comprehensive plan to combat food fraud for monetary gain. The USP said the new guidance is designed to help food manufacturers and regulators pinpoint which food ingredients are most likely to be adulterated by a supplier, and to advise the best way to prevent this act — officially known as economically motivated fraudulent adulteration of food products (EMA). EMA can be especially tricky to fight since it’s hard to predict where to find it, explained Dr. Jeff Moore, senior scientific liaison for USP, a nonprofit organization that sets food and medicine safety standards, in a statement Monday. “The output from implementing this tool provides users with a basis for making informed, vulnerability-based decisions on how to deal with EMA within their organizations,” said Moore. The goal of the plan is also to help regulators identify what food fraud control measures have been taken and to “track the source of food fraud should it occur,” according to Moore. The document targets a specific type of food fraud — substituting non-authentic or substandard ingredients for real ones or removing authentic ingredients without the knowledge of the buyer for economic gain. Economically motivated food fraud can not only harm the food manufacturer — who is paying more for a substandard good — but can also harm the consumer. For example, if an ingredient is labeled as one thing but is actually another, consumers allergic to the unlabeled ingredient are at risk of a reaction. EMA is an issue both industry and regulators have recently become more determined to recognize and address. In October 2011 the Government Accountability Office recommended that FDA formally define EMA and and publish guidance on the problem. FDA subsequently created the Workgroup on Economically Motivated Adulteration. The agency is currently seeking comments on the topic to help finalize its rule. The federal Congressional Research Service (CRS) said in a report on EMA January of this year that Congress has “not addressed food fraud in a comprehensive manner.” It pointed out that food fraud is not defined as the responsibility of one single agency, but said the problem is “broadly addressed through various food safety, food defense, and food quality authorities as well as border protection and import authorities across a number of federal agencies.” Research defining the scope of food fraud is relatively new, but has started to grow in the past few years. “Economic adulteration and counterfeiting of global food and consumer products is expected to cost the industry $10 to $15 billion per year,” estimated the Grocery Manufacturer’s Association of America in a 2010 report. A 2013 study published in the Journal of Food Protection identified 137 unique incidences of EMA sine 1980. Seafood fraud was the most common type, with 24 incidences, followed by dairy (15), fruit juices (12), oils and fat (12), grain products (11), honey and other natural sweeteners (10), spices and extracts (8), wine and other alcoholic beverages (7), infant formula (5), plant-based proteins (5) and other food products (28). The goal of the USP tool is to help food producers formulate a fraud protection plan tailored to specific ingredients and to calculate those ingredients’ specific risk for adulteration. “The use of a framework such as the Guidance on Food Fraud Mitigation could offer manufacturers an opportunity to analyze their portfolio of ingredients and decide where to dedicate resources to protect the integrity of their food supply chains,” said Markus Lipp, Ph.D., senior director of food ingredients at USP, in an email to Food Safety News. The USP guide offers a step-by-step outline for identifying vulnerabilities in the supply chain and keeping fraudulent ingredients out. It also offers a way to predict the impact should EMA occur. The level of fraud risk for an ingredient, said Moore, depends on many variables. “The vulnerability of food ingredients to EMA varies according to several factors, from the size and reach of the supply chain for a particular ingredient (the longer the supply chain, the greater the opportunity of EMA at any point) to geopolitical factors (the Guidance has the example of vanilla and the lack of availability because of political unrest in Madagascar, one of the few producers of vanilla beans), or market-driven demand for a particular ingredient (one example was when guar gum started being used by the natural gas industry, which raised prices and exposed guar gum to adulteration where it didn’t exist before),” said Lipp. The components of the plan include:
1. Identify the fraud vulnerabilities of an ingredient based on factors such as its fraud history, the buyer’s testing frequency, the relationship with the seller, and that ingredient’s supply chain.
2. Potential impacts assessment: identify how economic adulteration of a certain ingredient could impact public health and company profit or, on the regulatory side, confidence in regulatory officials.
3. Develop an appropriate mitigation strategy, bringing the ingredient’s vulnerability to an appropriate level based on its potential impacts on food safety and economics.
The tool also provides real-life examples of economically motivated food fraud, how it was discovered and how it’s being prevented going forward. EMA vulnerabilities must be continuously assessed, according to the guidance. Changes in any of the factors (e.g., economics surrounding the ingredient, change in supply chain, change in geopolitical status for a region) may all indicate the need for an updated vulnerability characterization,” reads the document. Lipp said USP also submitted the guidance to FDA this week, arguing that EMA should be considered its own category of food protection, and should not be lumped into the category of “preventive controls,” where it is currently filed with the agency. See past Food Safety News coverage of economically motivated food fraud: Tests Show More Honey Isn’t Honey Seafood Fraud: A Threat to Your Health, or Just Your Pocketbook?