The next food fraud? Worse than the ”Horsegate”

If the explosion of the infamous “Horsemeat Scandal” was greeted at first with disbelief and barely concealed laughter from the public and media, the following concern for a public health risk revealed itself in a short time as completely not founded. None of these two reactions seem to be triggered by what could be the next food fraud scandal on a global scale.

The affected product, in this case, are spices (especially cumin, paprika and various mix) which, at a level not yet identified of the supply chain, have been adulterated with crushed almond shells, with the clear aim  of financial gain. The real risk – and what distinguishes this case from ”Horsegate” – is that such conduct poses a serious risk to the health of allergic consumers. Almond nuts

The tree nuts category, indeed, is one of the allergens that more easily could cause violent anaphylactic shock; the risk is more than real, since the analytical detection of almond’s traces (probably remained caked on the shells) was the cause of dozens of recalls and withdrawals from the market started in UK, US, Canada and several other European countries.

Although the intent of the contamination has not yet been demonstrated, it is clear that such a wide spread of withdrawals and recalls worldwide, as well as the involvement in the issue of many different brands on the market (even global retailers such as Morrisons and Sainsbury’s) and the different types product, clearly suggest a deliberate fraud.

Spices have quite high prices, which allow good profit margins through this kind of adulteration: in addition, not always the systems of internal traceability of the small and medium-size companies are adequate to the high complexity required by management of these raw materials and their mix. Finally, as highlighted by Prof. Chris Elliot in some recent interviews, the last season saw in Gujarat (India) a cumin harvest absolutely disastrous because of the weather, and this caused a spike in prices.

Although a British company, Bart Ingredients, has challenged the analytical methods used by the British “Food Standards Agency” (FSA), advancing the hypothesis of “false positives” attributed to another ingredient (the “Mahaleb”, extracted from a variety of cherry tree), the chances that this is proved true for all cases found seems utterly unrealistic.

UK, was the European country most affected by the phenomenon. Here the cumin’s consumption as a flavor enhancer in soups and processed products, and also in combination with other spices such as paprika, chili and curry, is very high. The extent of the contamination, however, is not yet fully established. At the moment there have been no reports of deaths or hospitalizations due to the issue, but unfortunately could only be a matter of time. The spices are used in many processed and prepacked foods and it will be very difficult to detect all the products contaminated and to remove them all from the shelves (e.g. the first recalls involved kit for fajitas in British supermarket).

This will be the first “stress test” for the newborn FSA “Food Crime United” and the UK food safety system as a whole, after its reorganization following the “Elliot Review”. Important signals, however, should also be sent by the European Commission, now engaged with the revision of Reg. (EC) n. 882/2004 and with the implementation of appropriate measures to fight frauds.

FSA UK – Survey on allergen advisory labeling

The survey examined the type of allergen advisory labelling present on pre-packed processed foods sold in the UK, and aimed to quantify the level of allergens resulting from cross-contamination and establish whether the type of advisory labelling used related to the level of allergen present.

The current regulatory framework within the European Union mandates the declaration of 14 allergens as constituent ingredients (i.e. peanuts, nuts, soybeans, mustard, eggs, lupin, milk, fish, cereals containing gluten, sesame, celery, sulphur dioxide, molluscs and crustaceans) in pre-packed foods. This legislation does not cover unintentional cross-contamination with allergens or the resultant use of advisory labelling.

The FSA introduced ‘best practice’ guidance on managing food allergens in 2006 to assist the food industry in the use of advisory labelling. However, due to the lack of standardisation in allergen risk assessment methodology and inconsistencies in allergen management practices, the application of advisory labelling varies in the way it is presented to consumers.

These variations have led some allergic consumers to believe that different types of advisory statements convey different levels of risk (i.e. ‘made in a factory that also handles X allergen’, versus ‘made on a line that also handles X’ allergen).

It was anticipated that the results of this survey will help to inform the development of proportionate risk based allergen management thresholds (known as action levels). It was envisaged that action levels will be used by the food industry as well as by regulatory and enforcement bodies to inform decisions about allergen management, and enable the appropriate use of allergen advisory statements, such as ‘not suitable for those with X allergy’ on pre-packed foods. Furthermore, it was anticipated that action levels will help food businesses make evidence-based decisions on the use of factual statements about whether or not a food is suitable for consumption by someone with a food allergy.

Five hundred and eight pre-packed processed foods were purchased in duplicate (two samples with identical batch/production codes giving a total of 1,016 products) from a range of retail outlets across the UK, including major and smaller national supermarkets as well as independent retailers. Products with allergen advisory statements and an equal number of comparable products without such statements were purchased.

Samples were tested for the unintentional presence and quantity of one or more of the following four major food allergens: milk, gluten, peanut and hazelnut. These allergens were chosen due to the large number of incidents the FSA received over the past few years and because of their importance to public health.

The survey examined the different types of advisory statements used on pre-packed foods and compared the use of these phrases to the levels of allergens present. It was anticipated this may help to establish whether the use of certain advisory statements are linked to the level of allergen present and indicate whether different types of statements convey different levels of risk to the consumer. In addition, the survey examined whether the suggested advisory labelling statements set out in the FSA’s Best Practice Guidance were being used by industry.

The snapshot nature of this survey and sampling methodology means that it may not be representative of the entire UK retail market; it is therefore difficult to extrapolate findings to the UK retail market as a whole. The main findings are as follows:

Undeclared allergen cross-contamination in the UK is lower than previously found in studies in other countries, notably Ireland and the USA.

The percentage of samples with detectable allergen (both with and without advisory labelling) and where that allergen was not present as an intentional ingredient, were as follows: gluten – 6.1% (33/542); milk – 8.2% (39/474); hazelnut – 2.9% (29/988); peanut – 0.21% (2/950).

The percentage of samples with detectable allergen, where that allergen was not present as an intentional ingredient and which did not carry an advisory label were as follows: gluten 3.3% (18/542); milk – 2.1% (10/474); hazelnut – 0% (0/988); peanut – 0% (0/950).

The percentage of samples in which no allergen was detected but carried an advisory label were as follows: gluten – 19% (97/509); milk – 18% (77/435); hazelnut – 44% (427/959); and peanut – 45% (430/948).

The wording of the advisory label did not reflect the level of cross contamination found (for any of the four allergens across any product category).

A wide variety of different statements were used across the product categories. The most frequently used advisory label was ‘may contain traces’ (38% (418/1106)). The second most frequently used was ‘may contain’ (20.6% (228/1106)).

FSA guidance recommends the use of ‘may contain X’ or ‘not suitable for someone with X allergy’. These two statements were found on 20.6% and 7.2% (80/1106) of products, respectively.

The survey is available here.

(Source: FSA website)