Prevention Keeps the Horses In the Barn

If peanut traces can be found in cumin, what does that say about unsuspected contaminants that could surface in your ingredients or supplies? Are you doing everything you can to prevent such occurrences? Or are you trying to test safety into your product?

Since ancient times when black pepper was used as a form of currency, spices have held high value. But the sourcing of these flavoring ingredients has also been fraught with complexity and high risk of both intentional adulteration, due to economically motivated contamination, and unintentional contamination due to the sanitary, GAP and GMP conditions of many of the parts of the world from where they originate.

The recent recall of significant numbers of product containing ground cumin because of the presence of undeclared peanut protein shows how much impact such an incident can have. As of this writing, a full traceback has not been uncovered (or at least not disclosed), thus it is not yet known whether the contamination was intentional or unintentional. Regardless, you can bet that spice suppliers and processors around the globe are now testing their cumin for peanut presence.

But … isn’t that like closing the barn door after the horse has gotten out?

In a 2010 QA cover profile on McCormick (May-June 2010), I indicated one cornerstone of our brand protection philosophy is that, “Safe food starts with safe ingredients. We use a preventive approach which is only possible by having complete visibility, oversight and a chain of custody upstream in the supply chain. If you don’t practice such an approach, one is left to rely too heavily on intervention and not prevention.” I would say the exact same thing today—but would add, “If you prevent things from happening, testing becomes irrelevant.”

What do I mean by that? While we, at McCormick, do, of course, run regular tests on our ingredients and products, we don’t use testing as a means of delivering high quality, pure, and food-safe products. It is due to our strategic, preventive supply chain approach that we are able to assure consumers that they could purchase our products without concern for unlabeled allergens.

Why? Because well before FSMA made “preventive controls” an industry buzz phrase, we made prevention a standard. Economic adulteration of spices is a serious and damaging quality issue which the spice trade and its customers face. The means that we enact to counter that also help prevent unintentional contamination and can be implemented by all segments of the food industry, particularly those that engage in global trade and source ingredients and raw materials from remote and distant areas of the globe that are less developed and regulated.

In relation to cumin, we have a limited number of strategic partners or in-house facilities that purchase the seed whole, then grind it within their control, so there was no chance of those ground peanut shells being added to a ground product before we gain possession. In fact, in general, we grind spices at our own facilities or those of a limited number of strategic partner’s facilities, to maintain control and assure purity. Additionally, we have historical records from the in-depth sampling and inspection of incoming raw material which substantiate that we have not seen peanuts or peanut shells in incoming shipments. Finally, we process the cumin in plants which operate to developed world GMP standards and we handle no allergens of any kind in these facilities. These steps, in addition to other aspects of working close to the farming community, assure that we have visibility back to the field and a chain of custody that significantly mitigates, if not eliminates, the possibility for economic adulteration to find its way into the product stream.

When we work with joint ventures and strategic suppliers, we develop long-term relationships—and establish the rules of the road for all of them. The ultimate goal is to give the farmers transparency to the market and developed world quality expectations and help them to understand that it is in their best interest to properly grow, store, and care for the crops to ensure high value and best price.

Make no mistake, adulteration is not unique to spices. To provide another example of the harmful business impacts of adulteration—whether it actually causes a food safety issue or not, I’d like to discuss a 2005 incident in Europe, involving the recall of food in which traces of red dye Sudan 1 were found in Worcestershire sauce from a chili powder imported into the U.K. Sudan 1 is classified by the Whole Health Organization as a Category 3 carcinogen. That said, it is important to understand that the category—which at the time included caffeine, chlorinated drinking water, cloves, and sunset yellow dye—applies to agents for which the evidence of carcinogenicity is sufficient in experimental animals but is inadequate in humans. In fact, there is strong evidence that the mechanisms of carcinogenicity in animals does not operate in humans, and it would require the eating of large doses over many years to be an actual health hazard. Additionally, the regulatory statements at the time stated that, at the levels present, the risk from eating any of these foods was very small, but, as a precaution, it would be sensible not to eat them. Out of an abundance of caution, many products were recalled. However, the perception of potential risk as shouted on the front page of many newspapers and tabloids was grossly out of proportion to the actual threat.

Like many of today’s hot issues (e.g., lean finely textured meat, GMO labeling), the case was less one of food safety and more that of consumer perception. Despite that, more than 300 businesses were hit by the recall, global cost impact was estimated at $300 to $500 million, and, like today, it represented serious business risk to the integrity of the brands and the image of the companies involved.

Contamination risk—intentional or not—is faced by every faction of the food industry, but because there are very few food businesses that can say they do not use any spices, seasonings, flavorings, dyes, or other enhancements in their finished product, these are of particular concern. This is because, while a small portion of a food’s cost is for the seasoning or flavor, its impact is central to the overall taste and customer satisfaction. By the same token, if through an unscrupulous company, a very small amount of an adulterated spice finds its way into the trade, its use can explode into a huge quantity of product with exponential losses and cost impact.
 

The Solution.

As previously noted, the only real solution to supply chain contamination by any means is prevention. This needs to include aggressive enforcement of standards and regulation; punitive action to effectively discourage violators; auditing, inspecting, and educating your suppliers and suppliers’ suppliers to ensure your standards are met; ensuring that your management truly extends beyond first-tier suppliers; and conducting spot checks/screening for known and unknown economic adulterants. (For a more detailed listing of 15 strategies and lessons learned through the years, see my contribution to QA’s November-December 2014 China feature: Decades of Lessons Learned in China.)

By this point in my writing, some of you may be thinking, “This is all fine for McCormick. It’s a large company and can afford to do all this.” My response is that no one, no matter how small, can afford to not do all this. There will be an expense to it; there is a cost to anything one does in business, including food safety. But that is a cost of doing business in the food industry from which no company—no matter how large or small—should be exempt.