FDA Food Fraud - Economically-Motivated Adulteration - Honey

FDA recently issued a report on sampling and testing of imported honey for economically motivated adulteration.

• More than 70% of honey consumed in the US is imported.
• Adulteration is the addition of undeclared cheaper sweeteners to honey, such as syrups derived from cane, corn, rice or sugar beets
• Of the 144 import samples collected and tested, the FDA found 14 (10%) to be violative. The remainder were in compliance.
• Of the 144 import samples, 75 were collected from bulk shipments and 69 were collected from retail shipments.
• Violative samples are subject to compliance actions, such as recalls and import refusal, consistent with the FDA’s mission to ensure that food is safe, wholesome, and properly labeled. When appropriate, the agency may consider pursuing criminal investigations. 
• When other sweeteners are added to honey, the Federal Food, Drug & Cosmetic (FD&C) Act requires that the resulting product be labeled as a “blend,” and not as “honey,” and have an ingredient statement.

https://www.fda.gov/food/economically-motivated-adulteration-food-fraud/fy2122-sample-collection-and-analysis-imported-honey-economically-motivated-adulteration
FY21/22 Sample Collection and Analysis of Imported Honey for Economically Motivated Adulteration

Case Studies - Allergen Root Cause Analyses

An article in Food Safety Magazine, titled Anatomy of Food Allergen Recalls,  sheds light on the root cause of six different allergen-related recalls.  Key points from that article:

Egg residue in pasta product - Line spillover form one product to another

• "The pasta in this product was obtained from a pasta supplier. The manufacturer of the implicated product decided to conduct an inspection of the pasta supplier's facility. In the course of that inspection, a location was discovered where a line transporting egg noodles crossed over a line transporting this company's non-egg product. The inspector was able to discern that egg noodles would periodically drop from the noodle line into the non-egg pasta. Subsequently, a tote of the finished non-egg pasta ingredient was found to contain several egg noodles on visual inspection. Since these noodles were discrete particulates, they were not likely present in every container of the manufacturer's retorted product. Thus, the presence of egg evaded detection when only a few containers were selected for egg analysis."
• "The line crossover was identified as the root cause, and a shield was placed over the non-egg line to prevent egg noodles from dropping into the non-egg pasta."

Peanut in Chocolate Ice Cream - Rework Issue

• "A review of rework records at the manufacturing facility clearly and astonishingly showed that peanut butter swirl ice cream had been incorporated into the chocolate ice cream. The use of rework as an ingredient explains why consistent and moderately high levels of peanut residues were detected in the chocolate ice cream. Further investigation revealed that a key employee had interpreted the like-into-like as permitting the use of any flavor in rework that would not affect the color or flavor of the chocolate ice cream."
• "The use of peanut-containing rework was identified as the root cause of this recall. Corrective actions included more specific and detailed employee training on preventive allergen controls and implementation of a new rework policy (exact-into-exact), where rework was only allowed to be incorporated into the same SKU of product from which it had been generated."

Peanut in Spice Mix - Poor Supplier

• "Due to the very high levels of peanut found in the cumin, the manufacturer suspected intentional adulteration; however, such allegations are difficult to prove. Other spice mix companies that were customers of the same Turkish supplier were also found to have received and distributed seasoning mixes and ground cumin with high levels of undeclared peanut. Initially, no consumer complaints were received, but several complaints ultimately were linked to products associated with the implicated cumin. Hundreds of product recalls ensued."
• "The root cause was the presence of undeclared peanut in cumin obtained from a specific supplier. The corrective action was the cessation of the import of ground cumin from the particular Turkish supplier. Some affected companies began to source ground cumin from U.S. suppliers that imported whole cumin seeds and ground the spice in U.S. facilities."

Cumin with peanut - Farming practices

• "The cumin-growing region of India is also home to peanut farms. An observation was made by inspectors in India that many of these farmers were reusing burlap bags that may have been previously used for peanuts or peanut meal. Peanuts in India are sometimes processed into peanut oil, leaving behind peanut meal that farmers might transport in burlap bags to feed cows; those same bags might be later used to carry cumin."
• "This root cause was never fully documented, but several spice manufacturers began supplying the farmers with new burlap bags. This practice coincided with fewer cumin or cumin-containing spice mixes testing positive for peanut residues."

Undeclared Almond in Paprika - Testing failure

• "In the EU, retail paprika samples were recalled for the presence of undeclared almond. The source of the ground paprika was a Middle Eastern supplier. This supplier had no almonds in its facility, although the supplier indicated that it used shared equipment to grind both paprika and mahaleb, a popular Middle Eastern spice made from the pits of a variety of mahaleb cherries."
• "Subsequent analysis revealed that mahaleb residues would test positive in the almond ELISA methods, and mass spectrometric analysis revealed that the residues in the ground paprika had come from cherry pits and not almonds. Canada rescinded its recalls for undeclared almond in paprika. Allergen ELISA methods are typically quite specific; however, in the case of botanical cousins such as almond and mahaleb cherries, cross-reactivity is possible."
• "The root cause of these recalls was a faulty analytical method. The corrective action involved the use of a more specific analytical method to distinguish between almonds and cherry pits. Due to the close relationship between almonds and mahaleb cherries, the proteins from these two foods are likely to be highly homologous, suggesting that ingestion of mahaleb might cause reactions in almond-allergic individuals."

Cereal with undeclared milk - Overspray transfers allergens

• "A breakfast cereal manufacturer used shared processing and packaging equipment for the processing of one cereal product with milk and another with no milk-derived ingredients."
• "The manufacturer realized that droplets from the wet washing procedure were transferring onto the roll stock plastic packaging used as the inner liner for the boxes of cereal. Corrective actions involved moving the packaging equipment further away and shrouding it during allergen cleaning."

Animal Feed Recall - Alfalfa Blocks Recalled, Linked to Death of 45 Horses Due to Botulism Poisoning

Manzanola Feeds is voluntarily recalling certain lots of Top of the Rockies Alfalfa Cubes because it has the potential to be contaminated with Clostridium botulinum.  The recalled Top of the Rockies Alfalfa Cubes are approximately 1 inch cubes, packaged in a 50 pound bag,  There have been 45 horse deaths associated with this issue, to date.

According to the FDA Advisory - "Some of the alfalfa cubes have been reported to contain what appears to be fur and animal tissues, indicating that material from an animal or animals may have been incorporated into the cubes during alfalfa harvesting. Some people have reported a foul odor in some of the bags. Clostridium botulinum, the bacterium that causes botulism, is commonly present in decaying animal carcasses. Testing of the alfalfa cubes and other feed and tissue samples is in progress."


https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/manzanola-feeds-recalling-certain-lots-top-rockies-alfalfa-cubes-due-possible-clostridium-botulinum
Manzanola Feeds is Recalling Certain Lots of Top of the Rockies Alfalfa Cubes due to Possible Clostridium botulinum Health Risk
Summary
Company Announcement Date:  December 16, 2022
FDA Publish Date:  December 16, 2022
Product Type:  Animal & Veterinary  Livestock Feed
Reason for Announcement:  Potential to be contaminated with Clostridium botulinum
Company Name:  Manzanola Feeds
Brand Name:  Top of the Rockies
Product Description:  Alfalfa Cubes

Texas Firm Recalls Cat Food Due To Salmonella Contamination

TFP Nutrition announced today that it is issuing a voluntary recall of a dry cat food - HEB Texas Pets Indoor Complete Dry Cat Food  due to potential Salmonella contamination.   The product was manufactured on November 13, 2022, at its Nacogdoches, Texas facility.





https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/tfp-nutrition-initiated-voluntary-recall-16-lb-bags-heb-texas-pets-indoor-complete-dry-cat-food
TFP Nutrition Initiated Voluntary Recall of 16 lb. Bags of HEB TEXAS PETS Indoor Complete Dry Cat Food Because of Possible Salmonella Health Risk
Summary
Company Announcement Date:  December 16, 2022
FDA Publish Date:  December 16, 2022
Product Type:  Food & Beverages
Reason for Announcement:  Potential Salmonella contamination
Company Name:  TFP Nutrition
Brand Name:  HEB TEXAS PETS
Product Description:  HEB TEXAS PETS Indoor Complete Dry Cat Food

RTE Crispy Chicken Entrée Recalled After Consumer Finds Shrimp in Product

Mountain View Packaging, LLC, a Boise, Idaho establishment, is recalling approximately 6,013 pounds of frozen, ready-to-eat Crispy Chicken with Almonds entrée products due to misbranding and an undeclared allergen - the product contains shellfish (shrimp), a known allergen, which is not declared on the product label.  The problem was discovered when the firm notified FSIS that they received a consumer complaint reporting shrimp in a product labeled as Crispy Chicken with Almonds entrée.


https://www.fsis.usda.gov/recalls-alerts/mountain-view-packaging-llc-recalls-frozen-ready-eat-crispy-chicken-almonds-entree
Mountain View Packaging, LLC, Recalls Frozen Ready-To-Eat Crispy Chicken with Almonds Entrée Products Due to Misbranding and an Undeclared Allergen
MOUNTAIN VIEW PACKAGING, LLC

FSIS Announcement

WASHINGTON, Dec. 15, 2022 – Mountain View Packaging, LLC, a Boise, Idaho establishment, is recalling approximately 6,013 pounds of frozen, ready-to-eat Crispy Chicken with Almonds entrée products due to misbranding and an undeclared allergen, the U.S. Department of Agriculture’s Food Safety and Inspection Service (FSIS) announced today. The product contains shellfish (shrimp), a known allergen, which is not declared on the product label.

Seattle Company Recalls Long Pepper Product After Mold and Mycotoxin Detected in Sample

Something South African LLC of Seattle, WA is recalling the Peppercorn Collection Gift Set, affected Best Before End (BBE) date of JUN/2024, Batch 494951-T, because mold (Aspergillus brasiliensis) and Ochratoxin A were detected in the Malaysian Long Pepper.

"The recall was initiated when our supplier notified us that mold (Aspergillus brasiliensis) and Ochratoxin A were detected in the Malaysian Long Pepper. The company has ceased the production and distribution of the product as our supplier continues with their root cause investigation."

https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/something-south-african-llc-recalls-peppercorn-collection-gift-set-because-possible-health-risk
Something South African LLC Recalls the Peppercorn Collection Gift Set Because of Possible Health Risk
Summary
Company Announcement Date:  December 15, 2022
FDA Publish Date:  December 15, 2022
Product Type:  Food & Beverages
Reason for Announcement:  Mold (Aspergillus brasiliensis) and Ochratoxin A contamination
Company Name: Something South African LLC
Brand Name:  World Market

Product Description:   Pepper Collection Gift Set

Protein Powder Recalled for Milk Allergens Due to Mislabeling

Power Life Nutrition of Woodland Hills, CA is voluntarily recalling a limited amount of its High Impact Plant Protein due to a labeling error. For a brief period during the manufacturing process, jars containing High Impact Whey Protein were mislabeled as High Impact Plant Protein. The mislabeled product is safe to consume for consumers who ordered High Impact Whey Protein, but it does not contain an allergen declaration for the milk allergen in the product.

"The recall was initiated after it was discovered that a limited quantity of units of High Impact Whey Protein incorrectly contained the label for High Impact Plant Protein. Subsequent investigation indicates the problem was caused by an error in the manufacturer’s packaging process manufacturer." [?]

https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/thgh-partners-llc-issues-allergy-alert-undeclared-milk-power-life-plant-protein
THGH Partners LLC Issues Allergy Alert on Undeclared Milk in Power Life Plant Protein
Summary
Company Announcement Date:  December 15, 2022
FDA Publish Date:  December 15, 2022
Product Type:  Food & Beverages
Reason for Announcement:  Undeclared Milk
Company Name:  THGH Partners LLC
Brand Name:  Power Life
Product Description:  High Impact Plant Protein

Just Another Recall of Enoki Mushrooms After Listeria Detected in Sample

Utopia Foods Inc of Glendale, NY, is recalling its 200g packages of “Enoki Mushrooms”, imported from China and distributed nationwide in the US, because they have the potential to be contaminated with Listeria monocytogenes.  The recalled “Enoki Mushrooms” were distributed nationwide in produce wholesale companies.  No illnesses have been reported to date in connection with this problem.

The potential contamination was noted by a routine sampling conducted in the State of Missouri revealed the presence of Listeria monocytogenes in the 200g packages of “Enoki Mushrooms”.

https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/utopia-foods-recalls-enoki-mushrooms-because-possible-health-risk
Utopia Foods Recalls “Enoki Mushrooms” Because of Possible Health Risk
Summary
Company Announcement Date:  December 13, 2022
FDA Publish Date:  December 13, 2022
Product Type:  Food & Beverages
Reason for Announcement:  Listeria monocytogenes contamination
Company Name:  Utopia Foods Inc
Brand Name:  Utopia Foods Inc
Product Description:  Enoki Mushrooms

Infant Formula Recalled After Cronobacter-Postive Sample Detected at Copacker

ByHeart, a next-generation baby nutrition company, is voluntarily recalling five batches of ByHeart Whole Nutrition Infant Formula due to the potential for cross-contamination with Cronobacter sakazakii.  No distributed ByHeart product has tested positive for the bacteria.

"ByHeart owns its entire manufacturing supply chain with the exception of final canning, which is conducted by a reputable third-party packager. ByHeart is taking this precautionary measure because one test sample collected from the third-party packaging facility tested positive for Cronobacter sakazakii. All product packaged that day, and the first production on the next day, was isolated for destruction and not distributed. Out of an abundance of caution, we are now recalling all product produced during the entire production run."

https://www.fda.gov/safety/recalls-market-withdrawals-safety-alerts/byheart-issues-voluntary-recall-five-batches-its-infant-formula-because-possible-health-risk
ByHeart Issues Voluntary Recall of Five Batches of Its Infant Formula Because of Possible Health Risk
Summary
Company Announcement Date:  December 11, 2022
FDA Publish Date:  December 11, 2022
Product Type:  Food & Beverages
Reason for Announcement:  Potential for cross-contamination with Cronobacter sakazakii
Company Name:  ByHeart
Brand Name:  ByHeart
Product Description:  Whole Nutrition Infant Formula, Milk Based Powder with Iron for 0-12months