food fraud...

Food Fraud Prevention

24th Australian HACCP ConferenceSydney, Australia / Hosted by SAI Global

August 30, 2017 / 9:20 to 10:15 AM

John Spink, PhDDirector & Assistant Professor, Food Fraud Initiative

College of Veterinary Medicine/ Food Safety

www.FoodFraud.MSU.edu Twitter @FoodFraud and #FoodFraud

*

WARNING:Counterfeiters Attend

Anti-Counterfeit Conferences

www.FoodFraud.msu.edu © 2017 Michigan State University 2

Global TrendsCRIMINAL LIABILTY FOR CORPORATE LEADERS

• Health Hazards• Financial Reporting

© 2017 John Spink 3

Massive Open Online Course (MOOC – free, open, online)• Free, open, online, open to everyone, includes a ‘certificate of completion’• Food Fraud Overview MOOC -- May & November• Food Fraud Audit Guide MOOC -- April, July, NovemberExecutive Education (Short-Course)• Food Fraud Strategy, Quantifying Food Risk with Vulnerably Assessments

Graduate Courses (Online, Three Credits)• Anti-Counterfeit & Product Protection (Food Fraud)• Quantifying Food Risk (including Food Fraud)• Global Food Safety (including Food Fraud) • Food Protection and Defense (Packaging Module)• Packaging for Food Safety

Graduate Certificate (Online, Four Courses Each)• Certificate in Food Fraud Prevention (Food Safety)

Master of Science in Food Safety (Online)• www.online.FoodSafety.msu.edu

Food Fraud Curriculum

Research

EducationOutreach

4© 2017 Michigan State University

Defining Food Fraud• Action: Deception Using Food for Economic Gain

– Including the FDA defined sub-category of Economically Motivated Adulteration (EMA)– Consistent with GFSI, EC/EU, UK, ISO, and others…

• Motivation: Economic Gain – “Food Defense” motivation is traditionally harm or terror– “Intentional Adulteration (general)” is any substance purposely added for any reason– “Intentional Adulteration (FSMA-IA)” is terrorist or large scale attack for health harm

• Effect:– Economic Threat– Public Health Vulnerability or Threat

Examples• Horsemeat in ground beef• Peanut Corporation selling known

contaminated product• Diluted or extra virgin olive oil• Melamine in pet food and infant formula• Over-icing with unsanitary water

• Unauthorized unsanitary repackaging (up-labeling or origin-laundering)

• Cargo Theft reintroduced into commerce/ Stolen products

• Expired product date code tampering or “refreshing”

Reference: Spink & Moyer (2011). Defining the Public Health Threat of Food Fraud, Journal of Food Science

© 2017 Michigan State University 5

The Food Risk Matrix

ActionIntentionalUnintentional

Harm: Public Health, Economic, or

Terror

Food Defense

Food Safety

Motivation

Gain: Economic

Food Fraud

Food Quality

Prevent by Understanding the Motivation

Source: Adapted from: Spink (2006), The Counterfeit Food and Beverage Threat, Association of Food and Drug Officials (AFDO), Annual Meeting 2006; Spink, J. & Moyer, DC (2011) Defining the Public Health Threat of Food Fraud, Journal of Food Science, November 2011


Terrorism

GFSI v7 Definitions• Food Safety

– A concept that food will not cause harm to the consumer when it is prepared and / or eaten according to its intended use.

• Food fraud– A collective term encompassing the deliberate and intentional

substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health.

• Food defence– The process to ensure the security of food and drink from all forms of

intentional malicious attack including ideologically motivated attack leading to contamination.

• Food Security (WHO, Global definition): safe, nutritious, continuous supply of food (not protecting food from attack)


GFSI Conference 3/2014


FoodFraud.msu.edu

Source: Food Fraud Think Tank Presentation, GFSI, 2012, 2013, 2014

TamperingOver-Runs

What is Food Fraud?

Food Fraud

Dilution Contaminant

Grey Market/ Theft/ DiversionCounterfeiting

Unapproved Enhancements

Mislabeling

Substitution

FDA/FR* “Economically Motivated Adulteration”

All FraudUK, EU, GFSI, China,

ISO…FDCA & FSMA-PC

FoodFraud.msu.edu


GFSI Issue 7 PublishedFood Fraud Terms

FSM AI 21 Food fraud vulnerability assessment• The standard shall require that the organisation has a documented food

fraud vulnerability assessment procedure in place to identify potential vulnerability and prioritise food fraud mitigation measures.

FSM AI 22.1 Food fraud mitigation plan• The standard shall require that the organisation has a documented plan in

place that specifies the measures the organisation has implemented to mitigate the public health risks from the identified food fraud vulnerabilities.

FSM AI 22.2 Food fraud mitigation plan• The standard shall require that the organization's Food fraud mitigation

plan shall cover the relevant GFSI scope and shall be supported by the organisation’s Food Safety Management System.

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Every ‘vulnerability’ does NOT need a control plan.

© 2017 Michigan State University FoodFraud.msu.edu

Inspection or Investigation• Inspection (Compliance):

– No active incident– Function: regulatory compliance, audit inspection– Convince an auditor or inspector that you meet the requirements– Q: Explain the process is in compliance

• Investigation (Prosecution):– Active incident: e.g. a baby just died– Function: Legal liability, criminal investigation– Present evidence to an investigator or prosecutor to prove no

willful blindness or neglect– Q: Explain why this incident was NOT a “hazard that

required a preventive control”


FoodFraud.msu.edu

Criminology: The Chemistry of the CrimeBusiness Decision: Enterprise Risk Management

Detect

Deter

Prevent

Review Incidents

Initial Screening (FFIS)

AdulterantsTampering

TheftOver-runsDiversion

Counterfeits

Enterprise-Wide Risk Assessment

VulnerabilityAssessment (FFVA)

Rank

Countermeasures

Enterprise-Wide Risk Assessment


I. Implementation Steps for Government Agency or Industry• Concept One: Formally, and specifically,

mention food fraud as a food issue and – “This statement confirms that AGENCY expects the food industry to

conduct risk or vulnerability assessments, including mitigation or prevention plans where warranted, on all incidents that could lead to a health hazard or the violation of a food law such as the FSMA or the FD&C. This includes all Food Fraud such as adulterant-substances, tampering, theft, illegal diversion or gray markets, illegal mislabeling, and intellectual property rights or product counterfeiting, and others. Consistent with existing Federal and State laws and regulations, third-party certifications play an important role in supporting this type of food supply chain protection.”

• Concept Two: Create an enterprise-wide Food Fraud prevention plan

Source: Spink, J., Fortin, N. D., Moyer, D. C., Miao, H., & Wu, Y. (2016). Food Fraud Prevention: Policy, Strategy, and Decision-Making–Implementation Steps for a Government Agency or Industry. CHIMIA International Journal for Chemistry, 70(5), 320-328. (ISI Impact Factor = 1.349; Scopus SJR = 0.55) (With translation to Mandarin/ Chinese)

II. Food Fraud Prevention Strategy Implementation Series of Activities 1. Convene a Food Fraud Task Force2. Create an Enterprise-wide Food Fraud Policy/Mission Statement and

begin drafting a Food Fraud Prevention Strategy/ Plan3. Conduct the pre-filter Food Fraud Initial Screening (FFIS)4. Review additional needs including additional information or a more

detailed Food Fraud Vulnerability Assessment (FFVA)5. Review specific Food Fraud vulnerabilities in an enterprise risk map

(Enterprise Risk Management)6. Consider countermeasures and control systems to address the 'very

high' and 'high' vulnerabilities7. Propose a Food Fraud Prevention Strategy including the calibration

of the Food Fraud risks on the enterprise risk map

III. Ongoing Management1. Implement Food Fraud Prevention Strategy

A. Document and refine the processB. Utilize the Food Fraud Prevention Cycle

A. Assign ‘accountability’ and ‘responsibility’ for key actionsC. At least annual vulnerability assessments (actually

set by your needs and emerging incidents)D. At least annual review of the best practices and

overall system – this is an emerging field.


Food Fraud Compliance Requirements: Scope

“Food Fraud Compliance Requirements — The general compliance requirements for Food Fraud prevention are:1. Conduct a Food Fraud Vulnerability Assessment (Y/N)2. Written (Y/N)3. Implement a Food Fraud Prevention Strategy (Y/N)4. Written (Y/N)5. Minimally conduct an annual Food Fraud Incident Review (Y/N)6. Note: Address all types of Food Fraud (Y/N)7. Note: Address all products from both incoming goods (e.g.,

ingredients) and outgoing goods (e.g., finished goods) through to the consumer.” (Y/N)

• Reference: • Food Safety Magazine, Feb 2017, “Food Fraud Vulnerability Assessment and Prefilter for FSMA, GFSI and SOX

Requirements”, http://www.foodsafetymagazine.com/magazine-archive1/februarymarch-2017/food-fraud-vulnerability-assessment-and-prefilter-for-fsma-gfsi-and-sox-requirements/

• New Food Magazine, Feb 2017: Food Fraud Prevention – how to start and how much is enough?”, http://www.newfoodmagazine.com/33890/new-food-magazine/past-issues/issue-1-2017/issue-1-2017-digital-version/


FoodFraud.msu.edu

Takeaways: Focus on…• Preventing all Food Fraud

– not only adulterant-substances

• All compliance – not just FSMA-PC, FSMA, FDCA, or Securities Laws

• Reducing recall potential – do your job… your CFO and Board of Directors care

• Reducing liability– Corporate, legal, regulatory, and criminal…

for Executives, employees and YOU. © 2017 Michigan State University 17

© 2011 Michigan State University

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MSU Engagement 2017Outcome Benefit Commitment

Graduate Course

Share your knowledge and set direction of research

Plus Graduate Certificate in Food Fraud Prevention

14 Weeks, online, May to August, ~$2200

Executive Education

Share your knowledge and set direction of research

Develop the internal talent to support initiatives in the AC space, meet other thought leaders (“invitation only” sessions for brand owners)

2 Days on-campus ($1950)Feb 7-9 (9-10 FFIS)July 18-20/20-21 (FFIS)Sept 26-28/28-29 (FFIS)

Multi-Client Studies

Research the why’s of AC/D, understand underlying drivers

Uncovering the drivers may lead to new strategies to combat Counterfeiting

Teleconference Meetings with option for on-campus e.g. Veterinary and Animal Product Fraud

MOOC Engage global network of Food Fraud thinkers..

Two, 2-hour on-line webinar format with assessment. Students earn an MSU “credential”.

Overview: Nov 7&14Audit Guide: July 6& 13Oct 11& 182017: Mar, July, Nov

Contact: John Spink, [email protected] – 517.381.4491 – http://FoodFraud..msu.edu/www.FoodFraud.msu.edu © 2017 Michigan State University 18

Acknowledgements• MSU Veterinary Medicine: Dean Christopher Brown, Chair Dan Grooms, Chair Ray Geor, Dr. Wilson Rumbeiha,

Cindy Wilson, Dean John Baker• MSU Global: Associate Provost/ Executive Director Christine Geith, Jerry Rhead, Gwyn Shelle, Lauren Zavala,

Associate Provost/ EVP Dr. Karen Klomparens, Rashad Muhammad• Queens’s University Belfast (UK): Professor & Director Christopher Elliott, Dr. Moira Dean, Dr. Michael Hollis• MSU Online Master’s of Science in Food Safety: Director Melinda Wilkins, Ex-Director Julie Funk, Kristi Denbrock,

Heather Ricks, Peggy Trommater, Heidi Chen, Dr. Gary Ades, Chair Ray Goer• MSU Food Science: Chair Fred Derksen, Les Bourquin, Bradley Marks, Felicia Wu, VP of Research Ian Gray, David

Ortega, Gale Strasburg• MSU Program in Public Health: Director Michael Rip and Douglas C Moyer• MSU NFSTC: Dr. Scott Winterstein, Trent Wakenight,, Dr. Kevin Walker, Sandy Enness, Jen Sysak, Dr. Rick Foster,

to name a few critical contributors and supporters. • MSU Food Safety Policy Center: Dr. Ewen Todd• MSU School of Packaging: Dr. Bruce Harte, Dr. Robb Clarke, Dr. Laura Bix, Dr. Paul Singh, Dr. Diana Twede, Dr.

Gary Burgess, Dr. Harold Hughes, Dr. Mark Uebersax, Dennis Young, and Director Joseph Hotchkiss• MSU Communication Arts/ Consumer Behavior: Dr. Maria Lapinski and Dr. Nora Rifon• MSU Criminal Justice: Dr. Jeremy Wilson, Director Ed McGarrell, Dr. Justin Heinonen, Roy Fenoff, Zoltan Fejas,

Barbara Sayre, and Sara Heeg• MSU Supply Chain Management: Dr. Cheryl Speier, Dr. Ken Boyer, Dr. John MacDonald, Chair David Closs, Dr.

Stan Griffis, Dr. Judy Whipple• MSU College Social Science: Dean Marietta Baba and Assoc Dean Chris Maxwell• MSU College of Law: Dr. Neil Fortin and Dr. Peter Yu• MSU Libraries: Anita Ezzo, Nancy Lucas, Kara Gust• MSU International Programs: Dr. Mary Anne Walker, Dr. John Whimms• State of Michigan’s Ag & Food Protection Strategy Steering Committee: Dr. John Tilden, Brad Deacon, Gerald

Wojtala, Byron Beerbower• The Citadel: Dr. Roy Fenoff


DiscussionJohn Spink, PhD

[email protected]

Twitter: Food Fraud and #FoodFraud

www.FoodFraud.msu.edu

Video on YouTube: Search “Food Fraud” and “New Zealand”<< to be determined >>


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