By Timothy Hansen
Each month, EAS answers one question sent in by our readers. This month’s Ask the Expert is answered by Independent Consultant and former head of the NOAA Seafood Inspection Program and Division Director in FDA’s Office of Seafood, Timothy Hansen. Tim has extensive experience in seafood regulatory affairs, certification, and advises the seafood industry on science and technological matters. If you would like to ask a question of one of our experts, click here.
Question: As a seafood importer how can I protect myself from fraudulent suppliers?
Hansen: The seafood industry is mostly comprised of smart, hardworking, honest professionals that take regulatory compliance seriously, and a few unscrupulous operators who aim to misrepresent their products for financial gain or enhanced competitive advantage. It would be wise for all firms and particularly importers of seafood to be aware of some of the more common fraudulent practices so that you can protect your firm, your customers and ward off FDA enforcement action by perpetuating fraud to your customers. Some types of fraudulent activities to be aware of:
Species substitution, usually representing a lower cost but similar species as a higher cost or higher quality species such as Chum Salmon for Coho Salmon. When this occurs, not only is the fish fraudulent but so too is the labeling including PDP, weight declaration and nutritional information.
In other cases, suppliers may provide a fraudulent shipment weight due to overglazing of ice, overbreading that exceeds USDC, NIST or AOAC standards, or even what is called “rat packing” where the superior product is on top, hiding the inferior product underneath.
According to the NOAA Fisheries Seafood Inspection Program, as of 2014 around 30% of seafood in the U.S. is considered fraudulent. This can be attributed to intentional fraud where the seafood operator is looking to gain an unearned profit, “best” the competition, or they commit fraud due to pressures stemming from the inability to fill customer orders. In other cases, unintentional fraud may also be committed, attributed to honest mistakes such as the misinterpretation of regulations or miscommunications and messaging errors due to poor process controls which lead to unknowingly receiving and accepting a fraudulent product from a supplier.
There are a number of ways the seafood industry can protect themselves, the most obvious of which is to develop relationships with reputable suppliers and to regularly inspect incoming shipments. In addition, if your firm does not already have fully developed product specifications guidelines consider creating these as part of your business operations plan. You will also want to have a Quality plan in addition to your HACCP plan and enhance your labeling controls beyond the minimum HACCP requirements. Consider also utilizing process control techniques such as statistical weight control charts and Quality Assurance software.
Protocols for all Quality, HACCP and other SOPs must be developed by a competent person, either within your organization or created by an outside entity, such as EAS, with expertise specific to the seafood industry. Ensuring compliant process control techniques can significantly increase your company’s integrity, leading to a satisfied customer, and reduce your risk of regulatory action.
EAS has a team of experts with career histories in FDA inspections and the seafood industry. If we can help your company to create or improve your compliance programs, please give us a call. We invite you to view our many industry services facts sheets on the EAS website, or more specifically that which pertains to our seafood services.