Two recent news stories about honey, illustrate yet again the vital importance of communications to health. In these completely unrelated cases, it was all about translations, the rendering of messages from one written language to another. The fraudsters seemed to have assumed they could get away with selling their products to unsuspecting consumers due to a lack of language skills on the part of regulatory authorities.
In September, Bloomberg Businessweek broke the story on a honey scandal at the global level with an article entitled The Honey Launderers: Uncovering the Largest Food Fraud in U.S. History , describing a convoluted plot by German company ALW to sell millions of pounds of Chinese honey in the US, by disguising its origins. Over the course of several years, ALW arranged with the Chinese brokers to channel their product through other countries, where it was filtered, doused with additives to disguise its unpleasant flavor, and re-labeled to make it seem to have come from nations authorized to export honey to the US. Some of the adulterated honey was also found to contain residues of the antibiotic chloramphenicol, long banned in the US. The impetus for the fraud was purely financial , as honey fetches top dollar in this country, the major world consumer. Over a decade ago when domestic beekeepers complained that honey imports from China were seriously undercutting their business, the US imposed such stiff tariffs on Chinese honey imports that little enters the country legally any more. But the super-cheap price of honey in China has remained a lure for international exporters. Some Chinese producers seize this opportunity to increase their own profits by artificially increasing the quantity of honey available to be sold. According to the FDA investigation of this case, a number of techniques like harvesting the honey early and not letting the bees complete the process naturally were routinely used in China, along with machine-drying the honey to speed things along. ALW abetted the process and instructed its 2nd-country middlemen to add sweeteners to disguise the sour taste caused by the premature harvesting.
In order to keep the doings secret, ALW officials exhorted the young German employees sent to run the firm’s US operations to use the phone, not emails, to discuss business and to conduct all communications in their native language. While the staff did restrict their discussions to the German language, they continued to use emails for correspondence. Their missives were later translated into English during the course of the FDA investigation. The federal prosecutor who worked on the case commented:
Earlier in the year in a less notorious case, the honey firm Nature Nate’s in Texas garnered FDA censure because it violated the instructions issued by the FDA following a 2012 audit, when the company was ordered to stop advertising its honey in ways that characterized it as a drug, i.e. by making various health claims for its products. While Nate’s had promised to stop the spurious marketing by Fall of 2012, an FDA follow-up in mid-2013 found that the firm continued to make these claims on its Spanish-language website, under the banner ” Remedios Caseros con Miel or Honey Home Remedies “, describing such benefits (in English translation) as:
• “Food Poisoning. Blend 1 Tablespoon Apple Cider Vinegar and 1 Tablespoon of North Dallas Honey dissolved in a glass of chilled water.”
• “‘[O]rganic honey’. A client of mine that is a doctor told me to try yours for allergy relief. It has COMPLETELY eliminated allergies for the entire household … it is our daily dose … “
A cached copy of the Spanish information on how to use Nate’s honey as an arthritis remedy said:
Para la artritis – 100% Pure Raw & Unfiltered Honey naturenates.com/espanol/para-la-artritis
“Receta 1. Tome una taza de agua caliente con dos cucharadas de miel y una cucharadita de canela en polvo por la mañana y la noche. …
And the phenomenon of the FDA using translation as an investigative tool is hopefully now a regular practice, as a evidenced by yet another recent case, this time involving the Sundial herbal supplement company which got an FDA Warning Letter based on claims made solely in Spanish which characterized its products as drugs. As a commentator for Regulatory Affairs so aptly explained
…just because a product’s unapproved claims aren’t in English, that doesn’t mean FDA isn’t paying attention.