Focus on Food Safety: Using case studies to inform risk assessment methodology

The apple sauce and cinnamon incident in the United States raised many concerns about how risk is approached for safety and integrity. When assessing risk within typical food safety management system, we were trained to the same classic hazards. The vocabulary is changing, and it is important to reflect on the implications of each category.

Food risk refers to the likelihood of harm occurring due to consuming a particular food product. Food risk assessment involves identifying potential hazards, evaluating their likelihood and severity, and implementing measures to mitigate them.

Food fraud involves the intentional deception for economic gain, where food products are adulterated, mislabelled, or misrepresented. This deception can occur at any stage of the supply chain and may involve dilution, substitution, or addition of unauthorized substances.

A food threat typically refers to deliberate acts or intentional contamination of food with harmful agents, such as toxins, chemicals, or biological agents, with the intent to cause harm to consumers, disrupt food supplies, or instil fear.

Food vulnerability refers to the susceptibility of the food supply chain to various risks, threats, and vulnerabilities that may compromise its integrity, safety, and security. This includes weaknesses in infrastructure, processes, and control systems that can be exploited by malicious actors or natural events.

All of these food risks work in interacting ways. The cinnamon and apple sauce incident certainly struck fear into many consumers’ minds. It was a case of fraud because lead chromate was used as an adulterant to increase the weight of cinnamon for sale.

Assessing risk

Risk assessment methodology requires an approach similar to HACCP hazard identification and risk assessment but may require extension of the boundaries of the assessment. It is up to individual organizations to determine what the boundaries of control can be. For some, those boundaries extend one supplier back. With access to blockchain traceability, boundaries of control can extend potentially even farther back all the way to the primary producer.

Within supply chain mapping, each node in the map can be assessed for possible hazards, followed by strategic planning within the quality management system for identification, mitigation, and elimination of each hazard.

Part of the challenge is that there is not a one size fits all response to risk assessment. If we were the apple sauce manufacturer, how would we assess the risk on the cinnamon? We must use a systems-based approach and multiple directions to comprehensively reduce or eliminate risk.

Supplier verification is common in all HACCP-based food safety management. Performing third-party audits or inspections can be part of that, but can an auditor observe a fraudulent action at the time of occurrence? Certificates of analysis are another important part of risk assessment. Extending blockchain traceability to these certifications could be critical. It’s not uncommon for these certificates to be performed on very low frequency on certain commodities because of the high cost of analysis. I’ve personally seen certificates of analysis results being pushed forward to new lots without new assessments.

Integrity of the transportation and shipping of products is also essential. Purchase orders and bills of lading used to be only text based, but it is now possible to put physical images of shipments into this documentation for identification on receipt. Tamper evident and traceable shipping seals are becoming common. The Use of RFID tagging on shipments is also becoming commonplace, so that shipments travel exactly to the specified destination.

Possible tests

Should we instead focus on incoming goods testing especially to prevent fraud? Cinnamon, for example, is prone to fraudulent substitution by other brown plant materials. DNA fingerprint assessment would the prime method in such cases. However, DNA testing would not pick up lead or other heavy metals contamination that would be measured by atomic emission spectroscopy. Are there better methods such as FTIR, which will speed systems? Each FTIR requires calibration to the commodity, but this could be an important approach. It would be costly to require these assessments on every lot though.

One part of risk assessment is exposure evaluation. It’s not uncommon for companies to look at minor ingredients and validate against the certificate of analysis, then assume that hazard exposure is low because of the dilution effect of ingredients. It’s common to find low levels of lead in commodities from agricultural contamination. In the case of the apple sauce, exposure was higher than assumed because of reliance on convenience food for small children. These affected children were consuming the product with higher than anticipated frequency. Dilution effects for hazard reduction are a slippery slope and should be avoided.

Our perception of risk is changing. In the risk assessment process, piracy, global conflict, climate change and environmental disaster are impacting the integrity of food systems. Using case studies such as the apple sauce recall allows us to plan better for future incidents.

Dr. Amy Proulx is professor and academic program co-ordinator for the Culinary Innovation and Food Technology programs at Niagara College, Ont. She can be reached at aproulx@niagaracollege.ca.

This column was originally published in the April/May 2024 issue of Food in Canada.