Recent articles in The Age and Sydney Morning Herald (January 3, 2022) shed light on “Australia’s $3 billion food fraud conundrum”. This is a subject on which kosher certification authorities have much to say.
Food adulteration is generally defined as “the addition or subtraction of any substance to or from a food such that the natural composition and quality of the food substance is affected”.
It can be:
- Intentional – either by eliminating substances in food or by knowingly altering the existing natural properties of food.
- Unintentional – caused by ignorance, negligence or lack of facilities to maintain food quality.
- Accidental – occurring during the period of growing, harvesting, storage, processing, transportation and distribution of food.
Intentional food adulteration or “food fraud” is where kosher organizations show their value as an added level of food assurance. In fact, it has been claimed that the appeal of kosher certification to the American public lies in the depth with which reliable kosher agencies will investigate ingredients and production processes for kosher compliance.
As part of a kosher survey, we ask companies to complete a checklist that covers ingredients, ingredient suppliers, recipes, co-production (what else is done on shared equipment), an overview of the manufacturing production schedule, allergen control and change cleaning. . We even check the potability of the water in the boiler used to heat the plant.
This checklist, along with periodic site audits and a legally enforceable contractual agreement, forms the basis of modern kosher certification.
Do we pick things up? Yes.
Common documented areas of food fraud around the world include:
Fish Substitution: A report in the Journal of Conservation Biology (6/22/18) noted that studies of more than 9,000 seafood samples from restaurants, fishmongers, and supermarkets in more than 30 countries found that 36% of them were mislabelled. In Australia and New Zealand, 40% of the time the fish sold as snapper was not snapper.
Kashrut requires that with the exception of salmon and trout (which have a distinctive orange-pink flesh), skinless fish fillets cannot be accepted from an unsupervised fishmonger. Kosher fish fillets are batch supervised and must bear appropriate kosher seals to maintain kosher integrity.
Extra Virgin Olive Oil (EVOO): Between 2016 and 2019, researchers (Olive Oil Times 4/21/21) found the following events: the substitution of olive oil with other oils; mislabeling of olive oils; misuse of a geographical indicator. (EVOO came from another region); distribution of counterfeit products; and the dilution of olive oils with other lower quality oils.
The impact of some of these practices could render EVOO, theoretically inherently kosher, as non-kosher depending on the blended oils. the oils are kitniyot or contain chametz additives.
Refined oils require kosher certification due to potential sharing of equipment with tallow production (animal fats and bones). If there are shared production lines, we ensure that proper segregation is in place and that koshering procedures are closely monitored.
Honey is considered one of the most adulterated foods in the world (Insider.com 9/26/20) with glucose and sugar syrup used as fillers or to replace honey.
For those looking for the therapeutic benefits of honey, these are not available in honey substitutes. And the environmental damage that can be caused by the bee population can be affected, which impacts pollination processes for other plants.
For the kosher consumer, glucose is often derived from wheat and is therefore prohibited on Passover. As part of a kosher audit, random load checks take place to ensure that only pure honey is packaged as kosher. Additionally, we check for cross-contamination on the filling lines.
Regarding other foods, it should first be noted that certain “additives” can be dangerous or even carcinogenic. Adulteration has been widely reported in milk (melamine – remember the Chinese milk and infant formula scandal in 2008), red chilli powder (addition of red brick dust), tea (addition of leaves of tea already used) and black pepper (addition of ground papaya seeds) .
Examples of intentional tampering found by Kosher Australia over the years include: the addition of refined canola oil to supplement EVOO, the baker who added powdered milk to his breads and concealed the powder in bags of flour, and the flour producer who kept a bag of vitamins to show the health inspector that he was adding the correct fortification, but the kosher auditor noticed that the vitamins were past their expiration date years earlier.
And there are cases of mostly inadvertent tampering caused by human error.
A pareve, allergen-free production cycle was about to take place when the kosher auditor noticed that some production equipment was coated in milk chocolate.
A series of gluten-free and lactose-free bread mixes were to be produced and when the mixers were checked by the kosher supervisor before production for cleanliness, milk and regular milk (gluten flour) were present in substantial quantities.
A documentation error led to the inclusion of a dairy chocolate in a pareve product. This was picked up when the auditor cross-checked the certification with the supplier and noted that the chocolate was dairy. Quality assurance had mistakenly documented the ingredient as dairy and allergen free when it was not.
It is fascinating that ancient rabbinic literature already recognizes the possibility of food fraud by requiring kosher meat to be continually under the control of an observant Jew (see Shulchan Aruch, Yoreh Deah 118).
The same goes for filleted fish, hard cheese, wine, and some say all kosher foods where there is potential benefit in replacing the more expensive kosher product with a cheaper non-kosher analogue.
Unfortunately, there have been very public cases of meat substitution (e.g. the 2006 Monsey kosher meat scandal) that have led US kosher authorities to tighten their procedures.
(Fortunately, Australia’s kosher meat industry is structured differently, so control by kashrut authorities from paddock to plate is good – a subject for another time.)
With the widespread use of home delivery systems such as Uber, Deliveroo and Door Dash, Kosher Australia insists that deliveries must be properly sealed at the restaurant/takeaway outlet. If a delivery arrives unsealed, we encourage consumers to contact the food vendor for answers.
Given the many opportunities for food fraud, our community is fortunate that the procedures employed by Kosher Australia and other trusted kosher authorities enable kosher consumers to have confidence in the foods they purchase for their families.
Yankel Wajsbort is Managing Director, Kosher Australia.
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