ROCKVILLE, Md.—The United States Pharmacopeial Convention (USP) submitted a public comment letter to FDA urging them to reconsider its strategy to address Economically-Motivated Adulteration (EMA) of food ingredients.
“Economically-motivated adulteration of food ingredients is a significant concern, with its own challenges, posing a threat to public safety, eroding consumer confidence in the integrity of food and disrupting markets by placing control of the supply chain in the hands of criminals," said Ronald Piervincenzi, Ph.D., CEO at USP. “EMA should be addressed as its own unique category of food adulteration."
While USP agrees that it is not ideal to handle EMA under a typical food-defense/vulnerability approach, the organization says EMA would be equally misplaced under preventive controls. The suggested approach includes a vulnerability assessment mostly focused on determining the likelihood of EMA occurring, but also including a component of public health risk assessment; a second component would be a vulnerability control plan to mitigate these risks.
USP highlighted the concerns related to economically-motivated food adulteration:
- Dilution: such as olive oil diluted with potentially toxic tea tree oil or products watered down using non-potable water.
- Substitution: including sunflower oil partially substituted with mineral oil or hydrolyzed leather protein in milk.
- Concealment: such as harmful food coloring applied to fresh fruit to cover defects.
- Mislabeling: including toxic Japanese star anise labeled as Chinese star anise or mislabeled/recycled cooking oil.
USP offers free public resources including a Food Fraud Database and plans to develop additional tools.