Do you re­ally know what you’re eat­ing?

We’ve all been vic­tims of food fraud, but can any­thing be done to stop it?

National Post (Latest Edition) - - FRONT PAGE - Laura Bre­haut

The scale was stag­ger­ing: more than 300,000 ba­bies sick­ened and 54,000 hos­pi­tal­ized. Kid­ney dam­age claimed six young lives. Up­wards of 80 per cent of the vic­tims were just two years old or younger.

The cul­prit? Tainted milk. The vic­tims of the 2008 Chi­nese milk scan­dal didn’t fall prey to in­ad­ver­tent con­tam­i­na­tion but rather de­lib­er­ate de­cep­tion for profit. In to­tal, 22 com­pa­nies were im­pli­cated in adul­ter­at­ing milk pow­der in China, in­clud­ing in­fant for­mula, with melamine. Used in in­dus­trial plas­tics, floor­ing and coun­ter­tops, melamine is the toxin of choice when it comes to in­ex­pen­sively bump­ing up the pro­tein con­cen­tra­tion of di­luted dairy prod­ucts.

A decade later, the suf­fer­ing con­tin­ues as many of the af­fected chil­dren still con­tend with kid­ney dial­y­sis and surg­eries. To­day, roughly nine in 10 Chi­nese con­sumers buy or­ganic in­fant for­mula. The wrong­do­ing has in­stilled a deep dis­trust of not just lo­cally pro­duced milk pow­der, but also the in­tegrity of food safe­guards as a whole.

This is the power of food fraud: the ad­di­tion, adul­ter­ation, mis­rep­re­sen­ta­tion or sub­sti­tu­tion of food for profit com­pro­mises health and rocks faith in sup­ply sys­tems. It puts an es­ti­mated US$30 to $40 bil­lion each year in the hands of scam­mers in­stead of rep­utable pro­duc­ers. It cheats con­sumers and dam­ages brand rep­u­ta­tions. And al­though there are sys­tems in place to en­sure our food is safe to eat, all too of­ten it feels as though the onus is placed on con­sumers to safely nav­i­gate gro­cery store aisles.

“We’ve all been vic­tims of food fraud, whether we re­al­ize it or not,” says Syl­vain Charlebois, pro­fes­sor in food dis­tri­bu­tion and pol­icy at Dal­housie Univer­sity. “There are two lay­ers to the food fraud prob­lem. One is the so­cio-eco­nom­ics of food, ba­si­cally see­ing many com­pa­nies sell­ing food at a lower price. And se­condly, pub­lic health: (if you) buy a prod­uct and in that prod­uct there are (un­listed) in­gre­di­ents you’re al­ler­gic to… that’s a prob­lem. Food fraud could kill peo­ple.”

Food sup­ply sys­tems are ex­ceed­ingly com­plex, and as such, rife with op­por­tu­ni­ties for fraud to flour­ish. Con­sider one of the most mun­dane fast-food menu items: the cheese­burger. Ev­ery con­ti­nent on the planet, with the ex­cep­tion of Antarc­tica, has a hand in putting to­gether the seem­ingly sim­ple sand­wich. Com­prised of more than 50 com­po­nents, the num­ber of coun­tries in­volved in its pro­duc­tion is stag­ger­ing; it takes in­gre­di­ents from 14 dif­fer­ent na­tions just to make a vine­gar for the burger’s sauce.

De­cep­tion could hap­pen at any point in this in­ter­de­pen­dent sys­tem with each coun­try in­volved hav­ing dif­fer­ent reg­u­la­tions and stan­dards. It’s the mul­ti­fac­eted struc­ture of the global food sup­ply chain that al­lows fraud to oc­cur, and the fact that it’s clouded from view makes it ex­tremely dif­fi­cult to mon­i­tor. What isn’t dif­fi­cult to de­tect is the mo­ti­va­tion. Ac­cord­ing to a Michi­gan State Univer­sity study, which was pub­lished in the Jan­uary 2017 is­sue of Food Con­trol, a sin­gle ship­ment of fal­si­fied food can mean tens of thou­sands of dol­lars in il­licit profit.

For as long as cheats have been in ac­tion — tint­ing veg­eta­bles with cop­per in the 19th cen­tury or diluting milk with chalk or plas­ter in the Mid­dle Ages — the list of vul­ner­a­ble prod­ucts has grown equally ex­haus­tive. From horse­meat mas­querad­ing as beef in what The Guardian called “the big­gest food fraud of the 21st cen­tury” to es­co­lar (a.k.a. “Ex-Lax fish”) com­monly stand­ing in for but­ter­fish and white tuna, and pa­prika and chili pow­ders con­tam­i­nated with pro­hib­ited Su­dan dye to en­hance their red colour, fraud­u­lent food prac­tices have been honed over mil­len­nia.

“When we started to look and track how far back we could find ev­i­dence of food fraud, we got back about 2,000 years and then we thought, that’s prob­a­bly far enough to say as long as food has been con­sumed, some­body has tried to cheat it,” says Chris El­liott, pro­fes­sor of food safety at Queen’s Univer­sity Belfast.

The po­ten­tial for fraud lies in ev­ery sin­gle food on the mar­ket. To il­lus­trate this point, El­liott plays a game with his stu­dents: they name a food and if he can’t counter with an as­so­ci­ated fraud within 15 sec­onds, they’re re­warded with no course­work for the en­tire se­mes­ter. He’s never been beaten.

When he’s not ed­u­cat­ing stu­dents on the per­va­sive­ness of food fraud, El­liott con­ducts large-scale in­ter­na­tional re­search into bet­ter ways of both de­tect­ing and de­ter­ring it. Driven by the re­mark­able in­ge­nu­ity of fraud­sters, he and his team of an­a­lyt­i­cal sci­en­tists are in a con­stant game of cat and mouse. He founded the In­sti­tute for Global Food Se­cu­rity as an at­tempt to get one step ahead. It’s here that re­searchers per­form pre­dic­tive an­a­lyt­ics to iden­tify the ma­jor threats in food and bev­er­age safety. El­liott brings up the 2013 Euro­pean horse­meat scan­dal — into which he led the U.K. gov­ern­ment’s in­de­pen­dent in­quiry — and uses Tesco as an ex­am­ple of how food fraud can oc­cur. The multi­na­tional re­tailer pur­chases 9,000 dif­fer­ent in­gre­di­ents, he says. How does it de­ter­mine which of the thou­sands are most vul­ner­a­ble to fraud?

In nar­row­ing down the search, El­liott and his team ex­am­ine at what point fraud is most likely to hap­pen: is a par­tic­u­lar in­gre­di­ent easy or oner­ous to adul­ter­ate? They also look at fac­tors such as crop fail­ures around the world, com­modi­ties ex­pe­ri­enc­ing de­vi­a­tions in sup­ply and de­mand, and the com­plex­ity of sup­ply chains, all of which drive fak­ery. Herbs and spices, for ex­am­ple, are ex­tremely high-value com­modi­ties with con­vo­luted sup­ply chains. Saf­fron is more ex­pen­sive by weight than gold; vanilla is more valu­able than sil­ver. For the en­ter­pris­ing scam­mer, the sec­tor is ripe for a swin­dle.

“We’ve come up with our own for­mula, our own al­go­rithms and from that we can pre­dict what the top five or 10 food com­modi­ties or food in­gre­di­ents are to fraud. And we dis­trib­ute that to some of the com­pa­nies that we work with and that al­lows them to fo­cus and tar­get their re­sources on their big­gest vul­ner­a­bil­i­ties,” he says.

The ex­tent of the is­sue hit home re­cently with an Oceana Canada re­port, which re­vealed just how wide­spread seafood fraud is in this coun­try. The ad­vo­cacy group con­ducted DNA test­ing on nearly 400 seafood spec­i­mens from roughly 200 restau­rants and food re­tail­ers in five Cana­dian ci­ties (Vic­to­ria, Van­cou­ver, Toronto, Ot­tawa and Hal­i­fax). Al­most half of the seafood was mis­la­belled. Oceana Canada found cheaper species, such as had­dock ($39.88 per kg) be­ing sub­sti­tuted for more ex­pen­sive hal­ibut ($74.77 per kg) and At­lantic salmon ($37.66 per kg) passed off as sock­eye ($101.69 per kg). But be­yond the lit­eral and fig­u­ra­tive bait and switch, seafood fraud poses a food safety is­sue and puts pres­sure on al­ready threat­ened or en­dan­gered species.

More than half of the sub­sti­tuted fish species “could have po­ten­tial health con­se­quences for con­sumers,” Oceana Canada said. For ex­am­ple, the afore­men­tioned es­co­lar, “lax­a­tive of the sea,” can cause se­ri­ous gas­troin­testi­nal dis­tress. All of the Cana­dian sam­ples la­belled but­ter­fish and 10 of the 15 white tuna spec­i­mens were ac­tu­ally es­co­lar.

With any­where from five to seven steps in the sup­ply chain, which is “sig­nif­i­cantly longer than any other type of food,” says Ju­lia Levin, Oceana Canada’s chief seafood fraud cam­paigner, seafood is an ex­cel­lent ex­am­ple of the lack of trans­parency that ex­ists in food sys­tems. With­out full chain trace­abil­ity, fig­ur­ing out where or when the fraud oc­curred, and who should be held re­spon­si­ble, is an ar­du­ous (if not im­pos­si­ble) task. “There are some stud­ies that have been done and they have found it at ev­ery stage of the sup­ply chain,” adds Levin. “Ob­vi­ously we see more mis­la­belling once the fish has been pro­cessed. If it’s a whole fish, it has its mor­pho­log­i­cal fea­tures: it has its skin; it has its fins. So if you rec­og­nize fish, if you work with fish, you can iden­tify the species by look­ing at it. But once it be­comes a fil­let or once the skin is taken off, it be­comes a whole lot eas­ier to mis­la­bel it.”

Levin’s ex­pla­na­tion re­veals an in­con­ve­nient truth when it comes to food fraud: it can be highly


so­phis­ti­cated. El­liott de­scribes a re­cent ex­am­ple of an es­pe­cially in­ven­tive de­ceit in which tuna un­fit for hu­man con­sump­tion was adul­ter­ated to give it the ap­pear­ance of mar­ket-ready fish. “Old tuna gets very, very dis­coloured. It turns a dirty brown colour whereas when you go in to buy tuna, it has to be that nice pink colour. And what they found out was, by pump­ing it full of chem­i­cals called ni­trates and then blast­ing car­bon monox­ide over the fish, they were able to get that lovely, lovely, rosy pink colour back again,” says El­liott. “To me, that’s pretty good chem­istry; that’s good sci­ence, and I have to tell you, it’s in­cred­i­bly dif­fi­cult to dif­fer­en­ti­ate tuna that is very old and has been re­gen­er­ated ver­sus fresh tuna.”

In its seafood fraud re­port, Oceana Canada calls for boat-toplate trace­abil­ity, and uses the EU as an ex­am­ple of how more strin­gent reg­u­la­tory re­quire­ments – in­clud­ing catch doc­u­men­ta­tion and a card­ing sys­tem where coun­tries are held re­spon­si­ble for polic­ing their own sup­ply chains – can have a pos­i­tive im­pact. (Mis­la­belling fell from ap­prox­i­mately 23 per cent in 2011 to seven per cent af­ter 2014.) Last year, the U.S. im­ple­mented boat-to-bor­der trace­abil­ity in re­sponse to seafood fraud, which re­quires the im­porter to pro­vide in­for­ma­tion in­clud­ing gear type, species and name, when and where the fish was caught, and proof of chain of cus­tody. “They have all the right trace­abil­ity re­quire­ments, but it stops at the bor­der. So once seafood en­ters into the do­mes­tic com­merce sup­ply chain that in­for­ma­tion is lost, which is very prob­lem­atic,” says Levin. “Mis­la­belling does hap­pen once prod­ucts have en­tered a coun­try’s mar­ket as well as be­fore. But it is a good first step be­cause at least to the bor­der level they’re re­quir­ing boat-to-bor­der trace­abil­ity. So it’s still bet­ter than what we have.”

Ac­cord­ing to Aline Dim­itri, deputy chief food safety of­fi­cer at the Cana­dian Food In­spec­tion Au­thor­ity (CFIA), the agency has been con­duct­ing au­then­tic­ity test­ing and la­belling re­views for many years, and while food fraud is “not a novel is­sue” for them, nei­ther is it “ex­tremely preva­lent.” The CFIA re­lies on a com­bi­na­tion of his­toric data, in­tel­li­gence, sur­veil­lance, en­vi­ron­men­tal scan­ning and cus­tomer com­plaints to de­ter­mine its pri­or­i­ties. Ac­cord­ing to Dim­itri, fewer than three per cent of the griev­ances the agency re­ceives are re­lated to food au­then­tic­ity.

How­ever, if con­sumers are unaware that some­thing like species sub­sti­tu­tion in fish is an is­sue, they’re un­likely to make that as­so­ci­a­tion and file a com­plaint should ill­ness oc­cur. Health im­pacts and other ram­i­fi­ca­tions of food fraud can’t be quan­ti­fied or in­ves­ti­gated if peo­ple aren’t re­port­ing them. Fraud is rooted in per­ceived op­por­tu­nity: the abil­ity to de­ceive with­out be­ing caught. The fact that an act of de­cep­tion goes un­de­tected means the trick­ster was suc­cess­ful; not that it didn’t hap­pen.

“I read the same things that come from dif­fer­ent reg­u­la­tory au­thor­i­ties right across the world and they say, ‘We have no ev­i­dence this is go­ing on.’ Well, I will tell you, wher­ever I look in the world for fraud in the food sys­tem, I find it. Ev­ery­where. So the harder you look, the more likely you are to find prob­lems,” says El­liott. “And I think one of the prob­lems with reg­u­la­tors (is) they’re very scared to look be­cause they’ll find prob­lems and then the next thing is, if you find a prob­lem, then we’ve got to deal with it.”

El­liott draws a par­al­lel be­tween buy­ing food and fill­ing a pre­scrip­tion or board­ing an air­liner. Peo­ple don’t pon­der whether or not their pre­scrip­tion drugs are coun­ter­feit or if the plane they’re board­ing has been re­paired with un­ap­proved air­craft parts be­cause there are mea­sures in place to pre­vent th­ese things from hap­pen­ing.

En­hanced trace­abil­ity is in­te­gral to lift­ing the shroud of se­crecy that cov­ers food sup­ply sys­tems. On Jan­uary 15, 2019, new food safety reg­u­la­tions are com­ing into ef­fect in Canada. Dubbed the Safe Food for Cana­di­ans Reg­u­la­tions (SFCR), the leg­is­la­tion will af­fect sup­pli­ers, im­porters and ex­porters. One key pil­lar of the rules is “one for­ward and one back” trace­abil­ity, which Dim­itri de­scribes as “the in­ter­na­tion­ally rec­og­nized stan­dard.”

Un­der the new reg­u­la­tions, ev­ery food busi­ness will be re­quired to keep records of who it bought a given prod­uct from and when, and who it sold it to (with the ex­cep­tion of re­tail­ers, which won’t need to re­tain records of con­sumers). This also ap­plies to im­porters, which Dim­itri high­lights as an im­por­tant change. “The im­porter has a re­spon­si­bil­ity to en­sure that what­ever is com­ing into Canada meets Cana­dian law. That was not the case in the past,” she says. “It’s a shift that will en­sure that we are clos­ing the gap of per­cep­tion that im­ported prod­ucts are not as safe as do­mes­tic prod­ucts. So we are mak­ing sure that there’s no am­bi­gu­ity on this and im­porters are just as re­spon­si­ble as do­mes­tic pro­duc­ers to make sure that the food that’s com­ing into Canada is safe.”

This new trace­abil­ity com­po­nent will al­low the CFIA to con­duct in­ves­ti­ga­tions and re­call items more quickly, Dim­itri adds, be­cause that in­for­ma­tion will be read­ily avail­able and con­sis­tent across the in­dus­try. While it’s a “solid step” in the right di­rec­tion, as Charlebois puts it, does the agency’s “one for­ward and one back” ap­proach to trace­abil­ity go far enough?

“Ab­so­lutely not,” says El­liott. “We’ve had ‘one step for­ward, one step back’ in Eu­rope for more than a decade, prob­a­bly 15, 16 years and it is not good enough. It is ab­so­lutely not. You need full trace­abil­ity; full trans­parency over sup­ply chains. Quite of­ten, when­ever a prob­lem hap­pens and you start to ap­ply this ‘one step for­ward, one step back,’ it can take you weeks and weeks and weeks to ac­tu­ally map out where some­thing came from along sup­ply chains. It doesn’t need to be that way.”

In to­day’s dig­i­tal era, many sup­ply chains re­main mired in man­ual pro­cesses. When an in­ci­dent arises – be it an E. coli out­break in ro­maine let­tuce or frozen beef­burg­ers cut with un­de­clared horse­meat – track­ing down the source of the is­sue can be time-con­sum­ing. And when lives are on the line, time is un­doubt­edly of the essence. Wal­mart, the world’s largest com­pany by rev­enue, re­cently an­nounced that it’s adopt­ing a vol­un­tary tech­no­log­i­cal so­lu­tion to trace­abil­ity in leafy greens: blockchain. “Wal­mart be­lieves the cur­rent one step up and one step back model of food trace­abil­ity is out­dated for the 21st cen­tury and that by work­ing to­gether, we can do bet­ter,” the re­tail gi­ant wrote in a let­ter to leafy greens sup­pli­ers an­nounc­ing the change in trace­abil­ity prac­tices. Could a sim­i­lar ap­proach be the an­swer for min­i­miz­ing food fraud?

In this case, the buzz­word refers to fully dig­i­tiz­ing the food sup­ply chain process, mak­ing it track­able and un­am­bigu­ous. Us­ing the same tech­nol­ogy that un­der­pins Bit­coin, the path from pri­mary pro­duc­tion to con­sumer would be mapped com­pletely. Rather than a lin­ear, one step at a time path of ac­count­abil­ity, dig­i­tized trans­parency means that all par­ties have ac­cess to the same in­for­ma­tion at all times.

El­liott, who has been work­ing on blockchain for sev­eral years, says that the tech­nol­ogy is es­sen­tially “a very nice database.” Like all data­bases, it’s as use­ful as the in­for­ma­tion en­tered into it; blockchain, in and of it­self, won’t stop fraud but it could be one of the tools in­dus­try uses in com­bat­ing it.

With reg­u­la­tors largely tak­ing an ad hoc ap­proach to food fraud, in­dus­try has stepped up; pur­su­ing ways to proac­tively fill the void, and with very good rea­son. As we see with Wal­mart, com­pa­nies have a vested in­ter­est in food fraud pre­ven­tion. Link­ing a breach to an un­trust­wor­thy sup­plier can de­grade brand eq­uity and strike a blow to the bot­tom line. “One up, one back” trace­abil­ity is slow, costly and can con­trib­ute to al­ready colos­sal lev­els of food waste as prod­ucts are pulled off shelves. Map­ping food sys­tems is an in­tu­itive so­lu­tion; one that 12 of the world’s largest com­pa­nies (in­clud­ing Dole, Nestlé and Wal­mart) are al­ready bank­ing on, ac­cord­ing to The Wall Street Jour­nal. The po­ten­tial of blockchain to counter food fraud and en­able bet­ter food re­calls has be­come a hot topic in the in­dus­try, with lead­ers in the space pres­sur­ing the en­tire sup­ply chain to com­ply. “More and more con­sumers are aware that there is a prob­lem and that’s why there’s some mo­men­tum around blockchain tech­nolo­gies. Es­pe­cially with re­tail­ers, be­cause they do want to make sure that what­ever they’re sell­ing is authen­tic,” says Charlebois.

While the po­ten­tial im­pact of im­ple­ment­ing such sys­tems of­fers hope in the fight against food fraud, it also re­quires col­lab­o­ra­tion. “What we’re see­ing right now is that in­dus­try is tak­ing ad­van­tage of tech­nolo­gies and so they should. I com­mend in­dus­try for tak­ing the lead on im­ple­ment­ing th­ese types of tools be­cause it will help them make sure that they are pro­vid­ing their clients with safe prod­ucts, which is ab­so­lutely an in­te­gral part of their re­spon­si­bil­ity as a food in­dus­try,” says Dim­itri. “If they choose to go be­yond (one step for­ward, one step back) or to use a new tech­no­log­i­cal tool to do that, that is some­thing that we would be very pleased with be­cause that is the essence of why our reg­u­la­tions are writ­ten the way they are. And they don’t man­date a sin­gle way of do­ing busi­ness. What they man­date is what is the ul­ti­mate re­sult for the Cana­dian, which is a safe prod­uct on their shelf.”

While in­dus­try con­tin­ues to ex­plore the vi­a­bil­ity of mod­ern, re­al­time so­lu­tions and the CFIA pre­pares to im­ple­ment the most rudi­men­tary of mea­sures, what are con­sumers to do in the mean­time? If you’re ever in doubt, re­port the in­ci­dent to the CFIA so they can gather ev­i­dence re­lat­ing to the com­pany, Charlebois sug­gests: “Food fraud ac­tu­ally con­cerns ev­ery­one and it’s such a broad prob­lem that with­out the par­tic­i­pa­tion of the pub­lic, it be­comes very dif­fi­cult to re­solve. The more con­sumers are en­gaged with this is­sue, the bet­ter.”

Ex­perts agree that there are pre­ven­ta­tive ac­tions we can take: rec­og­niz­ing that if the price is un­be­liev­ably low, the food is prob­a­bly fraud­u­lent; pur­chas­ing the whole food rather than pro­cessed (e.g. whole fish, and un­ground cof­fee beans and spices); buy­ing from rep­utable gro­cers; or sup­port­ing com­pa­nies that have will­ingly im­ple­mented trace­abil­ity sys­tems. But ul­ti­mately, pro­mot­ing th­ese acts as a so­lu­tion to such a byzan­tine is­sue is some­what naive.

A fix to food fraud re­quires “a strong reg­u­la­tor work­ing with a strong in­dus­try to­gether in part­ner­ship,” El­liott says. From a con­sumer per­spec­tive, lift­ing the veil on the is­sue has the power to be the most trans­for­ma­tive. With in­creased aware­ness comes con­tem­pla­tion: when you’re din­ing on all-you-caneat sushi for $10.95 or buy­ing a litre of ex­tra vir­gin olive oil for $6.50, can you rea­son­ably ex­pect it to be authen­tic? “There are rea­sons (for that low price), and so peo­ple are be­ing in­vited to ask them­selves ques­tions about what’s ac­tu­ally go­ing on out there, as con­sumers. And that’s putting pres­sure on in­dus­try and busi­nesses for sure,” says Charlebois.

Con­sumer aware­ness is a strong driver for change but the best model, El­liott says, is China. In the fall­out of the milk scan­dal, China now has some of the strictest food safety reg­u­la­tions in the world. And the di­rec­tion has come from the up­per ech­e­lons of gov­ern­ment: the pres­i­dent has made it one of the top pri­or­i­ties of the coun­try. In the U.K., in the af­ter­math of the horse­meat scan­dal, in­dus­try has been lead­ing the re­form. “We’re pretty fraud-aware now and that was all trig­gered by the horse­meat scan­dal. That was some­thing that could have come and gone quite quickly, but the me­dia picked it up and then it be­came a re­ally big news story here,” he says.

In both in­stances, it took a tragedy to spur mean­ing­ful change. As our food sys­tems have evolved to be­come in­creas­ingly in­ter­twined and in­ter­de­pen­dent, so too should our means of trace­abil­ity and in­for­ma­tion ex­change. With the tech­nolo­gies at our dis­posal, there’s no valid ar­gu­ment for ad­her­ing to an­ti­quated means of iden­ti­fy­ing and in­ves­ti­gat­ing food fraud. Con­sid­er­ing the scale of the horse­meat and milk scan­dals alone should be enough to im­press the im­mense risk it presents and the need for com­plete trans­parency.

Hal­ibut or had­dock?

But­ter­fish or es­co­lar (Ex-Lax fish)?

Beef burger or horse­meat?

Sock­eye or At­lantic salmon?

Fresh or re­gen­er­ated tuna?

Pa­prika or Su­dan dye?


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