INCIDENT REVIEW and RESPONSE– Buffalo Milk Diluted by a Tanker with a Double Bottom

A Food Fraud Management System (FFMS) should include processes to review operational, tactical, and strategic responses and planning. This buffalo milk food fraud incident provides an excellent case study for stress testing your food fraud incident review process.

Buffalo Milk Dilution Incident

I first read about this incident in the Food Authenticity Network blog post by Selvarani Elahi (who is a frequent co-author of mine and was awarded the very prestigious MBE for services to Food Measurement Science. The MBE is ‘Member of the Most Excellent Order of the British Empire’). I then did a bit more research and found an Italian news report with the full details.

(To note, buffalo milk is from water buffalos and is used to make buffalo mozzarella cheese and other products. Specifically, Italian buffalo mozarella cheese is made from the milk of Italian Mediterranean buffalos.)

• Timeline:
• Date that I became aware of the incident: November 14, 2022
• Date of the news article I found: February 18, 2022 – although I just found the incident, it has been public for at least nine months.
• Date of incident: March 12, 2021 – the actual incident occurred over a year ago but it often takes a while for the investigation to take place and then more time for a public notice.
• Date of seizure of the tanker truck: March 14, 2021 – the investigators set up a sting operation to catch the fraudster in-action.
• Date of the arrest/ public announcement: undefined but apparently in February 2022
• Summary: Throughout the reports, the act was identified as “fraud” and “food fraud” – this is significant, since this clearly identifies the act as “intentional deception for economic gain using food.” This designation properly assigns the incident to the most efficient countermeasures and control systems.
• Details:
• A quality control test found excessive water in the buffalo milk.
• This was traced to a tanker truck that had 500 kilos of water in a load of 11,000 kilos (about 5%)
• The incoming goods quality control testing: “the first by taking milk directly inside the tanker and the second taking a product sample after unloading into a bulk tank.”
• The fraud act: “the truck has a ‘double bottom,’ a simple system which in fact divides the tank into two parts, one containing milk and one containing water, which can be operated thanks to an electronic remote control after the first possible control drawing.”
• A further investigation of criminal activity indicated a wider conspiracy and not only one rogue driver:  “obviously other people involved in various ways with the plant in which the crime was committed.”
• The tanker truck driver was blamed initially as a single actor, mastermind.
• Later, there were questions about “when asked what return such behavior may have for a hauler who acts autonomously and in isolation.” The amount of investment in the tanker truck modifications would be quite costly and it was unclear how the driver would individually achieve economic gain.
• The source of the adulterant-substance water was unknown and untraceable – the water may not have been safe for human consumption, or may have been contaminated. Note: a ‘smart’ fraudster would use high quality water, but often, fraudsters are not aware of risks – risks of them getting caught in a standard food safety test and the health risk for the consumer.
• Detection:
• It is unknown how long the fraud act had occurred – with a dedicated, retrofitted tanker truck, this could have been a long-running operation.
• The report did not state the recall and product destruction for this incident – this is “adulterated foods,” with a lack of traceability of the fraudulent water, which would require the destruction of all current inventory for human consumption and a recall of all product that used the known illegal product.
• The article noted that: “This type of fraud attempt, ‘was widespread in the past.’ Today, thanks to the checks carried out on delivery and ‘quality’ payment, this fraud ’is less frequent.’” Note: less frequent but it did still happen.

Hazard Identification/ Incident Review

From this incident review, there are several key findings:

• This tanker truckload of Buffalo Milk is “adulterated foods,” illegal, and must not be used for human food production.
• There is no mention of whether any previous tanker deliveries occurred.
• There is a public health hazard due to the lack of traceability or confirmation of good manufacturing practices for the fraudulent water.
• This incident is first a food safety problem and second a food fraud problem.
• IMMEDIATE ACTION – FOOD SAFETY – QUARANTINE INVENTORY: before any other activity, the current product should be quarantined and then destroyed.
• IMMEDIATE ACTION – FOOD SAFETY – REVIEW PREVIOUS INVENTORY: review test results from the samples, possibly conduct tests on an other retained samples, and also review the previously produced finished goods for the presence of the diluted product.
• NEXT – FOOD FRAUD: review this incident through a food fraud lens.

Food Fraud Levels of Review: Operational, Tactical, and Strategic

Often during a food FRAUD incident review, a food SAFETY incident is identified. The immediate next step is to alert the food safety group or the crisis management team. After this response, the food fraud incident review can continue. Using supply chain management definitions, the actions are operational (immediate steps for products that are on-hand), tactical (a longer-term focus on changing activities to reduce operational problems), and strategic (long-term responses or bigger-picture planning that can be as broad as ‘what products do we produce’ or ‘should we stay in this business.’)

• Operation Response/ Planning: This would focus on standard operating procedures that could change today, this hour, right now, with just a phone call to an operator.
  • MORE INFORMATION: While two samples were taken, only the first sample was tested immediately for quality. The second sample was often discarded or kept as a “retain,” or not sampled at all.
  • PROCESS CHANGE/ CONFIRMATION: Confirm that a sample is taken at the start AND end of the delivery.
    • Possibly, for a while, take the third sample in the middle of the delivery.
    • Confirm at least the first and second quality control/ authenticity test is conducted.

• Tactical Response/ Planning: This activity is conducted after the initial emergency has passed, but still soon after. This considers immediate process changes that can fundamentally reduce the operational problems.
  • PROCESS CHANGE/ SUPPLIER NOTICE: Consider communicating to all suppliers of the incident regarding your updated detection countermeasures or control systems. “The goal is not to catch food fraud but to prevent it from occurring in the first place” – if you implement a new detection test but do not let your suppliers know, you will only catch food fraud and not prevent it.
  • FURTHER REVIEW:
    • Review previous deliveries by this tanker company to identify additional fraud acts.
    • Review other buffalo milk food fraud incidents – ensure other system weaknesses are addressed, such as different dilution or authenticity tests.
  • UPDATE: update the food fraud vulnerability assessment to cover this incident.

• Strategic Response/ Planning: This step is very difficult to implement since many times the work teams are so busy with urgent matters. The long-term response or planning is often delayed or not conducted.
  • What other products are received in liquid form where there is only a quality control sample taken from the start of the delivery – those other products have a system weakness or vulnerability.
  • What adulterant substances other than water could be used for fraudulent gain, and what tests could be conducted to reduce the fraud opportunity?
  • Conduct a review of the quality control and food fraud mitigation plans that allowed the system weakness that was exploited. One action may be to add more emphasis on the strategic response and planning.

By taking the methodical approach to addressing this issue – considering operation, tactical, and strategic responses, or planning – there can be an identification of immediately actionable, and often very low cost, countermeasures or control systems.