Food Safety Magazine, February/March 2012

REGULATORY REPORTBy Markus Lipp, Ph.D.Ingredient AdulterationUndermines Food SafetyIf the authenticity of aproduct’s building blocks isfraudulently altered, existingfood safety and quality systemscan be rendered useless.The food industry is no stranger to risk management.In the battle for consumer dollars,product recalls caused by contamination oradulteration can be catastrophic. Business,legal and moral repercussions resulting fromlapses in food safety and quality are top-of-mind issuesfor all manufacturers. Significant resources are dedicatedto minimizing these risks, generally through a variety ofindustry (and additionally, manufacturer- or retailer-specific)quality assurance (QA) systems. As global foodsourcing and international manufacturing sites have skyrocketed,risk management is an increasingly complexproposition, and quality and safety systems are challengedto keep pace.Contamination and adulteration are distinct threats.While both involve the presence of something thatshould not be in a food product, contamination is unintentionaland generally predictable (manufacturers areaware of potential risks that need to be controlled,though clearly a quality lapse has occurred in a contaminationevent). Economically motivated adulteration,however, involves purposeful and intentional replacementof the expected food substance with a cheaperone, including simply diluting the expected substancewith a solvent such as water. An important element isthat such replacement or dilution occurs without theknowledge of the seller. Consequently, this creates a singularityin the food safety system, insofar as nobody(aside from the perpetrator) is able to evaluate any consequencesfor the safety of consumersdue to the exposure to the said cheaperadulterant. Furthermore, to ensure repeatbusiness, economically motivatedadulteration is often designed to avoiddetection by standard QA testing.Adulteration, however, has yet tocatch the public’s attention as a foodsafety issue. Contamination—especiallymicrobial—tends to generate the majorityof the headlines and does, in fact,present potentially serious health consequencesto consumers. On the otherhand, intentional adulteration can be anequally critical issue. Though it has beenaround for hundreds (perhaps thousands)of years, intentional adulterationhas recently been spotlighted with therelease of a report by the U.S. GovernmentAccountability Office in November2011, evaluating the U.S. Food andDrug Administration’s (FDA) capacityto detect adulteration in food and drugs,the challenges the agency faces (largelyarising from globalization) and potentialoptions for preventing this threat. Thereport indicates just how far we stillneed to go in addressing this issue. Ofcourse, governments and industry havetaken other actions in the past few years,particularly in light of some high-profileadulteration episodes. FDA held its firstpublic meeting on economically motivatedadulteration in 2009. In 2010, theGrocery Manufacturers Association releaseda report it commissioned on thesubject. Among other findings, the reportstated that the cost of one incidentof product adulteration runs between 2and 15 percent of yearly revenues for acompany, which could translate to a$400 million impact for a $10 billioncompany. The report also laid out a hostof deterrence strategies, including developingfood ingredient specifications.Adulteration: A Long History,Modern UrgencyAdulteration is not a new threat. Notoriousexamples include episodes where16 F O O D S A F E T Y M A G A Z I N E