Tackling Food Fraud on a Global Level
By Food Safety Magazine
“Food fraud” is a collective term encompassing the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, labeling or product information, or false/misleading statements made about a product for economic gain. Recent global food fraud scandals have highlighted the need to strengthen companies’ ability to detect and mitigate the risks of food fraud within their organizations and across their supply chain. Authorities, consumers and other stakeholders expect food companies to proactively mitigate food fraud risks. However, current food safety management systems are not designed for food fraud mitigation, which requires a different perspective and skill set than either food safety or food defense. For instance, socioeconomic issues and past food fraud incidents are not included in traditional food safety or food defense risk assessments and are not generally part of any current food safety audit. Vulnerabilities to food fraud can also occur outside the traditional activities of a company.
The risks to food safety have never been higher. While food fraud is not new, the motivation to adulterate or counterfeit food for financial gain is growing, and thus new solutions are needed. While current food safety management systems are not always designed for fraud detection or mitigation, new food safety guidelines require it. That is why SSAFE (see “SSAFE: An Important Food Safety Partner”) created a free fraud vulnerability assessment tool that companies can use to help identify vulnerabilities to food fraud threats. This is an industry-led solution that can help meet the new requirements for food fraud mitigation set out in the Consumer Goods Forum’s Global Food Safety Initiative (GFSI). SSAFE worked with Wageningen University, VU University Amsterdam, PricewaterhouseCoopers (PwC) and food industry leaders worldwide to help put the global food supply industry in a stronger position to fight fraud and provide a basis to develop company-specific intervention strategies.
This science-based tool is based on the study of criminal behavior and decision making. It’s structured into two parts. The first examines the elements affecting criminal behavior, while the second relates to a company and its external relationships and environment (such as suppliers). The assessment is easy to use and can be applied anywhere in the food supply chain, from animal feed and primary production to manufacturing and catering. It applies fraud theory to support the identification of vulnerabilities in the food supply chain. There are three main elements—opportunities, motivations and absence of fraud control measures—that are believed to determine a company’s vulnerability to food fraud and make up the focus of the assessment. “Opportunities” and “motivations” are determined by the company’s internal and external environment and are defined as potential fraud risk factors. The potential risk resulting from these two elements can be mitigated by the third element, the “fraud control measures” that companies implement to detect or prevent fraud.
Specifically, the following types of food fraud (Figure 1) considered in this tool are:
• Mislabeling, the process of placing false claims on packaging for economic gain
• Dilution, the process of mixing a liquid ingredient with high value with a liquid of lower value
• Concealment, the process of hiding the low quality of food ingredients or a product
• Counterfeiting, the process of copying the brand name, packaging concept, recipe, processing method, etc. of food products for economic gain
• Substitution, the process of replacing a high-value ingredient or part of the product with a lower-value one
• Unapproved enhancement, the process of adding unknown and undeclared materials to food products to enhance their quality attributes
• Gray-market production/theft/diversion, which is the sale of excess, unreported product, resulting in loss of royalties or payments to the brand
Ready to Get Started?
If so, then there are a few things you should know:
• The tool is free to use for any company. Go online (www.pwc.com/foodfraud), download the app or use the spreadsheet to complete our 50 assessment questions.
• You can use the tool to assess your vulnerability to fraud at an ingredient, product, brand, facility, country or company-wide level (Figure 2). If you want help deciding where to apply the tool in your organization, complete the decision tree.
• The online tool is easy to use and you have the option to delegate responsibility for completing specific questions to different colleagues and departments to ensure its smooth completion by the right people, no matter how big or small your organization.
• Once completed, and depending on how you decided to apply the tool, the assessment will produce a profile of your company’s potential food fraud vulnerability, which can form the basis for developing interventions to mitigate identified vulnerabilities, as well as assessing potential risk to the enterprise.
• The assessment doesn’t give specific recommendations for mitigation techniques, but it does provide links to useful guidance on how and where to find solutions. It is not designed to detect fraud or predict future food fraud incidents. Yet, addressing vulnerabilities may identify fraud and give you the opportunity to stop criminal activity.
• You can use this tool as part of your food safety management system—remember, fraud vulnerabilities change over time, so use it regularly.
• At the end of the assessment, you’ll get a report that can be added to your food safety documentation that includes spiderweb graphics illustrating and identifying potentially high-risk areas of vulnerability. The outputs will enable you to prepare mitigation strategies and techniques, including the introduction of additional controls for reducing your food fraud risks.
• Responses to the assessment remain confidential to the company carrying out the assessment. It is important to note that respondents and their organizations are not identifiable from the online information recorded. All identifiable data are deleted at the end of your assessment, and all remaining data are aggregated to support general benchmarking and research to continue improving the tool and provide additional feedback to the industry.
Categories: Management: Food Defense, Risk Assessment; Regulatory: Audits/Certification/GFSI
Putting the Tool to Use
Because of fraud, companies are losing money and customers are losing faith. Food fraud is estimated to cost the global food industry $30 to $40 billion every year. But beyond the economic cost, food fraud can harm public health and damage brands. Globalization and increasingly complex supply chains are creating huge opportunities and rewards for fraudsters. The collision of megatrends—particularly climate change, resource scarcity, urbanization and demographic change—is increasing vulnerabilities and making it easier to profit from fraud. Today, even the most basic foods can involve huge numbers of suppliers around the world.
Small wonder, then, that food fraud is increasing. In response, GFSI is adding two new requirements to its guidance document to support companies in reducing the risks from food fraud to their own organization and consumers. By requiring companies to assess their vulnerability to food fraud and develop control plans to reduce their vulnerabilities, fraud mitigation will become an integral part of food safety management systems and a company’s enterprise risk management framework. This new food fraud vulnerability assessment is purpose-built to help companies identify areas of vulnerability and meet the requirements of all GFSI-recognized certification schemes as well as several regulatory authorities around the world. It’s a great place to start in identifying your vulnerabilities and planning your mitigation efforts.
SSAFE hopes that the development and launch of this science-based tool will help food companies spot and minimize their vulnerabilities. By using the tool, food companies will not only strengthen and protect themselves better but also help meet the new requirements set out by GFSI, drive use and application of the tool (one reason why the tool was translated into nine additional languages), drive its use deeper into the supply chain into small and medium-size businesses and, over the medium to long term, continue to build on the tool with our partners and other organizations that have or are developing tools to ensure solutions are consistent, aligned and benefit users across the entire food industry.
SSAFE works on many initiatives to protect the global food supply, not just food fraud mitigation. Some examples of other projects SSAFE is currently working on include the development of a global dairy farming food safety training framework, capacity building for food manufacturers in China and the development of an ISO technical specification for animal welfare (ISO/TS 34700:2016).
SSAFE Global Dairy Farming Food Safety Training Framework
The SSAFE Global Dairy Farming Food Safety Training Framework is intended to support food safety training and other capacity-building activities already occurring in the dairy farming sector, particularly in low- and medium-
income countries. The program provides requirements and guidance for good dairy farming practices and outlines the required knowledge and skills to create more consistency in the approach to training small to medium-size dairy farmers. It also provides recommendations and tools for determining training needs and the sourcing and selection of learning service providers.
The framework covers all regular dairy-farming activities that may influence the safety of animal products. This includes all relevant steps, from the on-farm production of feed intended for dairy cows to the delivery of farm products to immediate customers, including milk and live animals for meat.
The framework has recently been piloted in the Philippines, and SSAFE is using the outcomes from the pilot to update and publicize the framework. Over time, SSAFE expects this work to deliver a range of benefits such as:
• Improved quality and safety of dairy products
• Access to new markets for dairy farmers
• Consistency in the content and quality of training of dairy farmers
• A replicable model that can be used by anyone irrespective of type of organization, geographical location or size
• A tiered approach, enabling farmers to learn at a reasonable pace and improve continuously over time
SSAFE-SJTU Food Safety Training Program in China
SSAFE has been collaborating since 2013 with Shanghai Jiao Tong University (SJTU) in China to deliver basic and intermediate-level GFSI Global Markets Program training to food manufacturers in China. The objective has been to provide professional, systematic approaches and knowledge to accelerate food safety capabilities in China. Through this program, SSAFE and its members have demonstrated their commitment to helping Chinese food companies. SSAFE and SJTU recently extended their partnership for an additional 3 years to deliver training to 200–450 Chinese food manufacturers in Shanghai and Beijing.
ISO Technical Specification for Animal Welfare
Since 2012, SSAFE has worked in collaboration with the World Organization for Animal Health (OIE) to develop an ISO technical specification for animal welfare. The aim is to ensure appropriate care and well-being of food-producing animals, which is a basic expectation of consumers across cultures and geographies. The goal of this work is to facilitate the implementation of the animal welfare principles of the existing OIE code in the private sector and specify requirements for managing animal welfare in the food chain. That is why we worked together to develop a nonprescriptive, scientific, outcomes-based ISO technical specification that can help farmers around the world meet and implement the OIE principles of animal welfare. The standard was published at the end of 2016.
Food Safety Magazine thanks Quincy Lissaur, executive director at SSAFE, for contributing his expertise for this article.