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Defining food fraud prevention to align food science and technology resources

John Spink, Christopher T. Elliott FIFST and Kevin Swoffer FIFST discuss food fraud and the key role of food scientists and technologists in supporting fraud prevention

Introduction
Food Fraud – or the more narrowly defined concept of economically motivated adulteration (EMA) – is one of the hottest topics in the food industry. Food Fraud is deception using food for economic gain (1). The horsemeat scandal exposed vast supply chain vulnerability. While melamine in infant formula and milk seemed to occur in distant parts of the developing world, the horsemeat scandal occurred in our backyard and impacted on large and small food businesses and retailers alike.

Defining success
We focus here on the role of testing and other food science-related work processes. Two emerging and evolving research areas are Food Integrity, which includes Food Authenticity. Many universities and non-governmental associations are expanding their research capabilities in these areas.

Whilst better means of detecting Food Fraud are required, “success” must be measured in terms of how the activities support prevention. We need a systems approach to optimise the roles of all food supply chain and research partners. Broad partners include the likes of Interpol, to whom Dr Spink spoke on ‘The impact on prevention defines the value of enforcement and prosecution’ in October 2013.

What is clear is that Food Fraud prevention is a food issue and should be addressed with the involvement of food experts from specific disciplines. There are very unique aspects of the complex food production systems that are baffling to outsiders. There are complexities to authenticating food that are unlike any other sciences – the complexity of profiling a multi-component food product requires methodologies that are still far from routine and easy to use and interpret. There is an incredible amount of inherent variation in the same food product produced over the course of a year. Factors such as climatic and environmental conditions and physiology can produce radically differing product composition of what would be considered the same “food”. Only the “food” analytical community really understands these issues and the technical capabilities or limitations.

While addressing Food Fraud is critical and urgent, we need to continue to create a firm foundation of understanding and also harmonisation of terminology. There are researchers working beyond developing new tests to detect fraud – they are focusing on prevention. Success should not be measured in detecting rogue product but preventing Food Fraud happening in the first place. Ultimately, the goal is to protect and improve consumer confidence. The aim of food science and technology is to support that goal. We share some of our experiences in this article.

Food fraud prevention
Food Fraud is not a new crime. Some of the very first food laws were enacted to address Food Fraud adulteration incidents. The first US Food Law was enacted in 1906, in part, as a response to a diethylene-glycol economically motivated adulteration incident. The updated Food, Drug & Cosmetics Act in 1938 also, coincidently, had a publicised incident of the same contaminant. That contaminant was found in counterfeit branded toothpaste in the US and was one of the many sparks that created the US Food Safety Modernization Act. What is new is an academic focus on Food Fraud and on processes and procedures that focus on prevention.

Prevention is a holistic and all-encompassing concept that goes beyond just evaluating the presence of an adverse event to include an understanding of the root vulnerability. Systems are vulnerable to many gaps that can be exploited by the unscrupulous in supply chains. While this seems quite challenging, the food industry and public health professionals have adapted their work processes to focus primarily on prevention. For food, HACCP is a prevention-based programme that is aligned with a quality process such as Six Sigma. Food Fraud prevention utilises the same core processes but addresses “attacks from everywhere but inside” the manufacturing operation (the topic of one of Dr Spink’s presentations to the Association of Food and Drug Officials).

Traditional HACCP programmes focus on activities and operations within a defined production environment. HACCP training programmes explicitly state companies should address hazardsthat occur at a known frequency and that lead to a public health threat. Activities such as horsemeat adulteration in beef would clearly be defined as outside that scope. Testing for horsemeat adulteration would be considered a “prerequisite” programme for each of the processors receiving the food ingredient. Each entity in the supply chain would rely on their upstream supplier to assure the authenticity. This system inherently creates a fraud opportunity since the original producer – who is authenticating the product for the entire supply chain – could be a fraudster!

Fraud opportunity and prevention
Figure 1. The Crime Triangle.There is a well-respected Crime Science theory of Situational Crime Prevention that utilises the Crime Triangle. The Crime Triangle is a tool to deconstruct the components that contribute to a fraud opportunity, including consideration of the victim, fraudster, and the guardian or hurdle gaps. It is useful to consider these components when determining and evaluating countermeasures (Figure 1). (See (1).)

Specifically, the countermeasures fall into three categories: detect, deter, and prevent. Of course, the goal is to prevent fraud but we don’t create countermeasures for threats that have never occurred, or that we aren’t even aware could occur.

A good analogy is to consider burglary of your home:
• Detect: For food, this countermeasure identifies contaminants in ingredients or products. For your home, an alarm system notifies you that there is a burglar in your kitchen. This is good information but you’d rather they never got into your home.
• Deter: For food, this countermeasure addresses specific types of attacks or attackers. This could be food safety audits that validate the production facilities or the testing of raw ingredients for known contaminants such as melamine. For your home, this is either a police officer catching the burglar breaking your window or bars on the inside of your window blocking their path into your house. Now this is better to have kept the burglar out of your kitchen but you’d rather they hadn’t broken your window.
• Prevent: For food, this countermeasure persuades the fraudsters to not even attempt to attack your company or product. For your home, the bad guys drive right by and look for a softer target.

There are distinct roles in Food Fraud prevention for detection and deterrence countermeasures but they must be evaluated in relation to how they create a hard target. The success of the countermeasures is defined by the holistic, all-encompassing contribution to prevention. Before considering the specific detection testing needs or innovation, a key aspect to understanding the optimal countermeasures includes understanding the laws, standards and certification.

Laws, standards, and certification
To begin, Food Fraud is usually managed from within a Food Safety or a Food Defence infrastructure. It seems that the placement under the Food Safety infrastructure is predicated on measures to control the contamination of food products and focuses on expected biological, chemical and physical hazards, while placement under Food Defence is predicated on measures that reduce the risk of food products from becoming intentionally contaminated by a variety of chemicals, biological agents or other harmful substances by people who would wish to cause harm. The European Parliament issued a Draft Resolution addressing “fraud in the food chain” in October. The draft has a focus on “control thereof” and “Considers that official controls should focus not only on food safety issues, but also on preventing fraud” (2).

The US Food Safety Modernization Act has eleven mentions of “intentional adulteration” which apply to Food Fraud. A specifi c section covers this topic and it will result in a rulemaking. The concept of economically motivated adulteration is not specifically mentioned in the Act, but FDA requested comments in the draft rulemaking for the ‘Preventative Controls for Human Food’ and in the recent rulemaking for the ‘Preventative Controls for Food for Animals.’ Other aspects of Food Fraud are covered in other laws or regulations but not necessarily, explicitly, under food laws. This Act also included over 70 references to prevention.

Industry initiatives also have a significant role to play with regard to Food Fraud prevention. The Global Food Safety Initiative (GFSI) (3) is a business-driven initiative for the continuous improvement of food safety management systems to ensure confidence in the delivery of safe food to consumers worldwide. GFSI provides a platform for collaboration between some of the world’s leading food safety experts from retailer, manufacturer and food service companies, and service providers associated with the food supply chain, international organisations, academia and government. One of the GFSI stated objectives is to reduce food safety risks by “delivering equivalence and convergence between effective food safety management systems.” This is achieved by a benchmarking process which allows for the recognition of food safety management schemes. The publicly-available GFSI Guidance Document sets the GFSI expectations of applicant food safety management schemes. The schemes must utilise internationally recognised ISO standards which provide assurance of compliance through formal accreditation and certification.

The GFSI Board is considering recommendations by a recently formed Food Fraud Think Tank and is evaluating how food fraud preventative measures should be incorporated into food safety management requirements of the GFSI Guidance Document. It is believed that schemes will be encouraged to meet these requirements within a defined timeframe. The details of these requirements are far from being finalised but the GFSI Technical Working Group responsible for the development and maintenance of the GFSI Guidance Document is working collaboratively with members of the Food Fraud Think Tank to meet the mandate of the GFSI Board.

There are other organisations that are involved in related Food Fraud activities. The US Pharmacopeia/Food Chemicals Codex have Expert Panels on Food Ingredient Intentional Adulteration and on Dietary Supplement Adulteration. They also have been active in combating counterfeit medicines and have held numerous workshops on related topics. The International Standards Organization has Technical Committee 247 on ’Fraud Countermeasures and Controls’. The scope of this group includes “material goods,” which include food. Their new proposed standard on terminology includes fraud, fraud opportunity, and vulnerability assessment related to prevention. We expect other groups to also formalise their Food Fraud prevention-related activities and statements. DG Sanco in the European Commission has recently set up a Food Fraud Unit to help protect the European consumer.

The role of Science and Technology
Of course, there is a critical role for science and technology in prevention, though defining success will involve including many new disciplines, including Crime Science. Many of the current Food Integrity or Food Safety tests or processes were developed to meet specific needs within an already clearly defined set of known, high frequency risks. The risk assessment of a food safety system is looking for toxicity and dose response. The scientific and business decision-making systems understand the test results and have a clear standardised response. There is a clear definition of acceptable levels of contaminants. The overall role of preventing public health threats has been defi ned and the acceptable levels are constantly monitored. This is not so for Food Fraud.

For traditional Food Safety prevention programmes, we know the contaminants are omnipresent in the environment or in the animals. The same type of Food Safety incidents have occurred in the past and will occur again. The goal of Food Safety programmes, including HACCP, is to reduce the potential for a public health incident.

The goal of a Food Safety programme is to implement process controls to reduce the opportunity for known contaminants to enter the supply chain and then to designate the product “safe” when those contaminants are not found.

For Food Fraud, the straight forward measure of the presence or absence of a contaminant is only part of ‘the puzzle,’ and in contrast to food safety hazards, there is a near infinite number of adulterants. In the case of diversion, stolen goods, or production overruns, the fraud does not include an adulterant at all. Actually, the Food Fraud is conducted with genuine products.

While some types of Food Fraud seem to keep occurring, there are often no indicators of what type of fraud will occur, or where. Unlike the Food Safety contaminants that are omnipresent and not implemented with conscious planning, food fraudsters are intelligent, clandestine, stealthy, and actively seeking to avoid detection. The fraudsters will lie in wait for an opportunity to present themselves. At the same time, a lax system may never get attacked and a hard target may receive frequent attacks. The goal of a Food Fraud prevention programme, including a HACCP type approach, which builds on the benefits of Food Safety and Food Defence programmes, is to create a system that prevents fraudsters from wanting to attack. The goal of a Food Fraud programme is to implement process controls to reduce the opportunity for unknown contaminants to enter the supply chain and to support prevention by reducing the fraud opportunity.

There are tremendous Food Safety and Food Defence programmes in place. There are tremendous science and technology systems and processes already in place or in development for Food Integrity and Food Authentication. There are tremendous supply chain management and customer relationship management systems in place. There is a tremendous opportunity to coordinate our intelligence-gathering across those platforms. Once we understand the nature of the specific fraud opportunity, and we have conducted intelligence-gathering, we can define the science and technology needs that will support prevention.

Call to action
Fortunately, many stakeholders and researchers are collaborating like never before. Food Fraud theories and definitions are only now being developed and there is an opportunity to harmonise terms and optimise countermeasures before the laws or industry best practices are put in place. There are many activities that need your participation and input.

As we are developing the technological or process countermeasures, we do need to continue to understand the nature of the fraud opportunity, and how the countermeasure contributes to prevention.

Taking the time to learn about Food Fraud sooner, rather than later, will help you optimise our Food Fraud prevention activities.

Professor John Spink is the Director of Michigan State University’s Food Fraud Initiative. He is published widely on product fraud and related concepts, and participates in several key national and international groups concerned with food fraud and many associated activities.
Tel: 00 1 (517) 381 4491 Email: SPINKJ@Msu.edu Web: www.FoodFraud.msu.edu

Professor Christopher Elliott is the Director of the Global Food Security Institute (GFSI) at Queen’s University (Belfast). He currently leads an independent UK review of the food supplies network following the horsemeat scandal.
Tel: +44 (0)28 9097 6549, Email: chris.elliott@qub.ac.uk, Web: www.qub.ac.uk/research-centres/InstituteforGlobalFoodSecurity/

Kevin Swoffer is the Director of KPS Resources. He has over 30 years’ experience within the food manufacture and retail sectors. He was one of the founder members of the GFSI in 2000 and has been actively involved in its development.
Tel: +44 (0)1227 861114, Email: kswoffer@yahoo.co.uk

References
1. Spink, J. and Moyer, D. C. (2011). Defining the public health threat of food fraud, J. Food Sci., 76(9), R157-162.
2. European Parliament (2013). Draft Report - on the food crisis, fraud in the food chain and the control thereof, Rapporteur (Chair): Esther de Lange, Committee on the Environment, Public Health and Food Safety, (2013/2091(INI), October 10, 2013.
3. GFSI, Global Food Safety Initiative. (2013). Home Page [Accessed November 2, 2013],
 

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