Andy Morling, the Head of the FSA’s National Food Crime Unit (NFCU), has been in post since March 2015. In his first few months he has been focusing on refining the function of the NFCU to maximise its ability to identify and mitigate food crime threats to consumers. Here he responds to questions about the activities of the new unit.
What measures are you planning to introduce to prevent food fraud? Whilst much of the NFCU’s resource will be focused on identifying on-going criminal activity, it will also look for opportunities to prevent and to deter offending. Crime prevention is generally a very cost effective way of investing law enforcement resources.
By and large, criminals are rational thinkers whose decisions to offend are based on a cold appraisal of risk and reward. They aim to derive the maximum return from the minimum investment of effort, time and money. Working with law enforcement partners and industry, the NFCU’s work in this area will focus on influencing that appraisal by removing or reducing the means, motivation or opportunities to offend. In this way, we hope to ensure that UK food supply chains remain unattractive and hostile to serious criminality. On the case Andy Morling, the Head of the FSA’s National Food Crime Unit (NFCU), has been in post since March 2015. In his first few months he has been focusing on refining the function of the NFCU to maximise its ability to identify and mitigate food crime threats to consumers. Here he responds to questions about the activities of the new unit.
"Without human intelligence, law enforcement efforts to tackle most forms of serious criminality, including counter terrorism, would be rendered almost completely ineffective."
How do you propose to raise consumer confidence in the control of food fraud? There are two harms to consumers associated with food crime and it is the mission of the NFCU to address both. Firstly, we will work to reduce the incidence of food crime by identifying and preventing on-going criminality and working with others to bring offenders to justice.
But there is no silver bullet. Where there is honesty, there is inevitably dishonesty. Where there are profits to be made lawfully, there are inevitably much larger profits to be made unlawfully. Where there is money to be made, there is fraud and where there is serious money to be made, there is serious fraud.
Secondly, we will work to reduce the fear of food crime. However, the vast majority of food produced and sold in this country is safe, authentic and untouched by the effects of serious crime. The sometimes sensationalist discourse of recent years may have led to consumers developing an irrational fear that the food they eat is criminally inauthentic. Furthermore, even where food crime does take place it is extremely unlikely to impact in any way on the health of consumers.
So the NFCU, whilst working to raise awareness of food crime, will strive to replace sensationalist claims with a more measured, intelligence led assessment of the threat. It [The NFCU] will publish a strategic threat assessment on an annual basis, articulating its understanding of the serious criminal threat to the UK and highlighting significant gaps in that understanding.
Are plans in place to encourage anonymous whistleblowing and responsible procurement? Information from human sources both within the food industry and outside is vital to the work of the NFCU. Without human intelligence, law enforcement efforts to tackle most forms of serious criminality, including counter terrorism, would be rendered almost completely ineffective.
Such information, which is generally given in confidence, is particularly vital where, as with food crime, traditional break-out points, such as victim reporting, are almost entirely absent.
Human intelligence in relation to food crime can come from a variety of individuals with many different motivations. It might be an employee of a food business looking to do the right thing, a competitor looking to re-establish a level playing field or a concerned professional. It might also be a fellow food criminal looking to deflect attention or even a convicted criminal looking for financial reward or sentencing benefits.
Whatever the motivation, I intend to fully exploit this rich vein of information by providing the right conditions and a safe environment for these individuals to come forward.
I really want to hear from these people and the NFCU will treat them and the information they provide with absolute professionalism. I am absolutely certain a strong flow of human intelligence is vital if we are to tackle the thin seam of serious criminality we suspect to be impacting on the food and drink we consume and the hard earned cash we spend on it.
How will you provide information and advice to industry on the status, prevention and identification of food crime? Are you tapping into the expertise in the food industry to develop emergency response strategies? At the core of the NFCU sits an analytical function whose role it is to maintain a national picture of the nature and dimensions of current and likely future threats to food supply networks. This is very much the ‘big picture’ to drive the wider counter crime work of the unit.
The NFCU team has been working hard in recent months to pull together the Inaugural Annual Assessment of food crime, which is due to be published this spring. This enhanced understanding of the threat will be shared widely across public and private sectors to facilitate better decision making at local, regional and national levels.
The assessment draws on intelligence and information held by the FSA, industry and other government bodies. It will offer consumers, industry and government a single version of the truth on the current threat from food crime. Crucially, it will also highlight gaps in our understanding because an important part of addressing any crime problem is recognising what you don’t know and targeting resources to fill those gaps.
A vital part of any law enforcement effort is to reinvest learning from operational activity back into crime prevention. So in addition to its role pursuing offenders, the NFCU will have an important wider role to play in helping to prevent criminals from exploiting similar vulnerabilities in the future. The unit will share its understanding of specific criminal threats with relevant sectors of industry and also analyse offending methodology. The aim is to identify opportunities to work with industry to design a model that highlights criminal vulnerabilities.
Do you have access to sufficient analytical laboratory capacity to tackle food fraud convincingly? Although the NFCU is still in the first phase of its build, where the focus is on understanding the dimensions of the food crime threat, I’m not currently aware of any shortfalls in analytical capacity.
Will you be investing in the expansion of world class laboratory facilities to improve standardisation, validation and efficacy of analytical methods in the future? DH, FSA and PHE are continuing to work together on agreeing an option in relation to laboratory services. We hope to be in a position to agree how we plan to proceed by the end of 2015 and will then consult with stakeholders for their views on how we take this forward.
Will audits for food fraud prevention be introduced? There are no current plans to introduce audits.
"Any testing methodology that can provide my unit with incontrovertible evidence of adulteration, is promising from a law enforcement standpoint."
Which areas of research into authenticity testing do you consider to be the most promising? There are many different areas of research in this field and this is why the FSA has a dedicated Science and Research team and a Chief Scientific Adviser, so I’ll leave that for the scientists to answer. The importance here should be a focus on our two teams working together and that is what we are doing at the FSA. What I can say from a lay perspective, is that any testing methodology that can provide my unit with incontrovertible evidence of adulteration, is promising from a law enforcement standpoint.
How will you interact with the police? Is more police training in this area required? The NFCU is plugged into policing networks and infrastructure and is able to share information and intelligence through recognised national mechanisms. Where an intelligence package is developed to the point where a full criminal investigation towards prosecution is appropriate, the matter will be referred by the NFCU to a territorial police force, local authority or other agency on a geographical basis, taking into account the location of the criminality and where the offender resides.
The level of direct involvement of NFCU staff supporting force operational activity will be dependent on the level of risk to consumers, the benefits of the expertise that it can provide and the availability of such expertise locally. Police forces, local authorities and other agencies receiving intelligence packages and other support from the NFCU will retain primacy with regard to the investigation and prosecution.
The unit will work collaboratively with police forces, local authorities and other agencies to ensure that prioritised and effective action is taken against food crime, based upon a clear national picture of the threat posed. Action will range from supporting criminal investigations leading to criminal justice outcomes, varying degrees of disruption activity, and preventative action to reduce vulnerabilities to food crime.
"Many lessons were learned during the horsemeat incident and the Government’s commitment to establishing the National Food Crime Unit was a bold step in the right direction."
Do you have sufficient expertise and resources to respond to another horsemeat crisis? It is important to recognise that there remains uncertainty about the precise scale of the threat to UK consumers from food crime. This is why the unit’s strategic analysts are currently working to get a clearer picture. This is a measured response and the model we are putting in place is perfectly scalable should our improved understanding of the threat suggest this is necessary. Many lessons were learned during the horsemeat incident and the Government’s commitment to establishing the National Food Crime Unit was a bold step in the right direction. For its part, industry has made great strides in its own efforts to ensure the integrity of red meat sold in the UK. More and better testing of products and audits of supply chains will undoubtedly further reduce the likelihood of another incident of that magnitude.