Food Integrity – modern solutions to an age-old problem
Food crime is nothing new, but as food fraud becomes more globalised and sophisticated, then so must the means used to detect and prevent it.
By Mike Mitchell Fair Seas Limited
During the early part of 2013, confidence in the food manufacturing industry across Europe was rocked by the discovery of widespread substitution of beef with horsemeat. Major retailers and food brands across a number of different countries became implicated in an issue which has cast doubt on the effectiveness of current regulatory measures and accepted industry practices to guarantee food authenticity, traceability and provenance.
But should we have been so surprised by what became known as ‘horsegate’? Whilst we may have believed that modern audits and analytical standards should have protected society from such large scale product adulteration, food fraud in itself is nothing new – indeed, it is probably a practice as old as the food trade itself. We know this to be true because there is evidence in the annals of food law which show regulatory efforts to combat food fraud throughout history. In ancient Rome and Athens for instance, there were laws regarding the adulteration of wines with flavours and colours. Food control statutes were passed in thirteenth century France and Germany. In England in 1203, King John made a proclamation regarding penalties for the adulteration of bread, and the following monarch Henry III, introduced a statute in 1266, which ordained the public humiliation of dishonest bakers, vintners, brewers, butchers, and others in the pillory or tumbrel (the ducking stool).
For those of you who may not be familiar with the concept, a tumbrel or ducking stool is a chair fastened to the end of a pole; it was used to plunge offenders into a pond or river as a punishment, and was used particularly for disorderly women, scolds, and dishonest tradesmen. The tumbrel was just one of a number of public humiliations inflicted upon unscrupulous tradesmen – here we see a baker who has been caught trying to cheat customers being dragged around the community on a sleigh with the offending loaf of bread tied around his neck whilst the scales of justice loom behind him as evidence his fraudulent activities. Indeed, the penalties for tampering or adulterating bread dough with less expensive ingredients were so severe that it gave rise to the English tradition of the ‘baker’s dozen’ – where thirteen pieces were sold for the price of twelve in order to avoid allegations of cheating.
However, it wasn’t until the development of industrialised food manufacture in the 19th century that the fraudsters were truly able to exploit consumers and traders on a grander scale and with more cynical, widespread and technical mal-practice. Even by the early 1800’s the deliberate adulteration of food was common practice. Spent tea leaves were made to look like the genuine article by boiling them with ferrous sulphate and sheep’s dung. Poisonous compounds containing lead, copper or mercury were added to sweets to enhance their colour, and bitter tasting substances, many containing poisons such as strychnine, were added to beer to enhance its flavour and to save on the cost of hops.
One of the first attempts to systematically identify the scope and scale of deliberate food fraud was made by the German scholar and chemist Fredrick Accum (1769-1838) in his ground breaking book of 1820 ‘A Treatise on Adulteration of Food and Culinary Poisons’.
The book proved popular and the first edition of a 1,000 copies was sold out within a month with a second and extended edition appearing later the same year. Accum made many enemies through his ‘name and shame’ approach and ultimately was forced to leave England in light of a hostile lawsuit. Whilst he may have paid a personal price, his pioneering work was one of the first public articulations of the need for food safety governance and of a risk based analytical approach to the detection of adulteration.
Accum’s opening remarks have a remarkable resonance even now, almost 200 years after they were written:-
“To such perfection of ingenuity has the system of counterfeiting and adulterating various commodities of life arrived in this country, that spurious articles are everywhere to be found in the market, made up so skilfully, as to elude the discrimination of the most experienced judges…
The eager and insatiable thirst for gain, is proof against prohibitions and penalties; and the possible sacrifice of a fellow creature’s life, is a secondary consideration among unprincipled dealers.”
The criminal ingenuity, the lure of illicit profit, the lack of regard for the consumers’ well-being – all of the essential elements of motive and opportunity which spawned the horse meat crisis of 2013 are perfectly described here in Accum’s words from 1820.
As a chemist, it is hardly surprising that the primary focus of Accum’s Treatise is the chemical adulteration of common household foods and commodities – but he does offer some observations regarding the treatment of meat and fish by a process known in those days as ‘blowing’.
“The abominable custom daily practised of blowing, as it is technically called, or inflating butchers’ meat, especially the joints of veal and lamb, with the breath respired from the lungs, to make it appear white and glistening, is a practice which claims the interference of the Magistrates. This detestable custom unquestionably renders meat not only unfit for keeping, but likewise unwholesome for human food.
But not only butchers’ meat, but sea fish, especially cod, haddock and whiting, are in a similar manner often blown, to make them appear large and plump: a quill, or the stem of a tobacco pipe, being inserted into the orifice at the belly of the fish, and a hole being made under the fin, which is next to the gill, the breath is blown in, to extend the bulk of the fish.
The imposition is detected by placing the thumb on each side of the orifice and pressing it hard, when the air will be perceived to escape.”
We can only wish that the detection of modern-day food fraud could be this simple. A more sophisticated response to the detection of seafood fraud than thumb pressure is required in the modern age and this is perfectly illustrated when we consider the wide ranging societal response to horsegate. For example, in June 2013, the Department of Health and the Department for Environment, Food and Rural Affairs commissioned a modern day Frederick Accum in Professor Chris Elliott, to conduct a thorough review into the integrity and assurance of food supply networks in the UK. The final version of this report into the integrity and assurance of food supply networks was published in July 2014, identifying eight pillars of food integrity:-
- Consumer first – requiring the government to recognize the needs of the consumer are of foremost priority in combatting food crime
- Zero tolerance – where even minor dishonesty must be discouraged and the response to major dishonesty deliberately punitive
- Intelligence gathering – recognizing a shared responsibility between government and industry on intelligence gathering and sharing
- Laboratory services – recognizing that those involved with audit, inspection and enforcement must have access to resilient, sustainable laboratory services using standardized methodologies
- Audit – encouraging government and industry to develop more robust, focused and expert audit options
- Government support – suggesting the need for government support in establishing a coordinated approach to food law delivery and oversight by the Authenticity Assurance Network role of the National Food Safety and Food Crime Unit
- Leadership – through active government coordination of effective prosecutions
- Crisis management – requiring all food integrity issues to be regarded as a risk to public health until there is evidence to the contrary and urging the Food Standards Agency to discuss with the Cabinet Office Briefing Room (COBR) the planning or organized responses to incidents
In a parallel initiative to the Elliott Report, in September 2013, The Food Standards Agency tasked Leatherhead Food Research to produce a report on data mapping, prioritization and industry collaboration. This report, which was led by Professor Tony Hines, recommended the creation of ‘safe spaces’ for industry to share their experiences of unusual or unexpected food chain issues.
The Food Standards Agency and industry representative bodies such as the Food and Drink Federation and the British Retail Consortium are still considering how to best develop these ‘intelligence hubs’ and how to produce new intelligence products which give strategic and tactical direction for enforcement agencies and industry.
Even prior to ‘horsegate’ one of the UK’s largest seafood processors Young’s Seafood had identified a number of common types of seafood fraud that they considered to be extant in the global market place. These became known as ‘the Seven Sins of Seafood’ and could be considered perhaps as a proto-version of the type of analytical tools discussed by Professors Elliott and Hines.
The original Seven Sins of Seafood were:
- Species substitution
- Fishery substitution
- IUU substitution
- Species adulteration
- Chain of Custody abuse
- Catch method fraud
- Undeclared product extension
It would appear that food crime in the seafood sector has evolved and diversified somewhat since Accum’s description of a straw being inserted into an orifice and being blown into by an unscrupulous fishmonger. In order to combat the diverse and complex sources of food crime in the modern era, we recognise the need for a three stage systemic approach to risk management:-
Thus, by the application of these three steps, we are able to move from a landscape of extant multiple risk exposure to one of managed and minimised residual risk, but in order to achieve this, new business tools are required in all three of these stages, for example:
- Identification – new Business Intelligence horizon scanning analytics
- Classification – building on risk management tools in other disciplines
- Mitigation – new empirical analytics and forensic auditing tools
But criminal activity is by its very nature adaptive and innovative – it is by design intended to elude detection. History teaches us that food fraud is an ever-present threat and in recognition of this we must embrace the concept that new tools will ever need to be added to the suite, and new approaches to inspection and audit continually developed. Further to this, these new tools should not necessarily be premised on the tradition of ‘policing’ supply chains – after all, criminals will always find new ways to elude detection – rather they should focus on the development of shared values and longer term, collaborative and trusting relationships.
Food fraud may not be a new phenomenon – but it is an evolving one and our sector can only benefit from a joined up and collaborative approach to sharing intelligence and developing the new tools and the disciplines which are needed to combat it. It is amazing that almost 200 years after his Treatise, we can return to Fredrick Accum as an advocate of this very approach – an approach which even in the 21st century, we are grappling to come to terms with:-
“The design of the Treatise will be fully answered, if the views here given should induce a single reader to pursue the object for which it is published; or if it should tend to impress on the mind of the public the magnitude of an evil, which, in many cases, prevails to an extent so alarming that we may exclaim, with the sons of the Prophet, ‘death is in the pot.’ For the abolition of such nefarious practices, it is in the interest of all classes of the community to co-operate.”