I had a very different response to my AFDO presentation this year than when I first presented back in 2007, when someone actually asked “why would someone counterfeit something like toothpaste?” About a year later counterfeit branded toothpaste was found in stores in the US and melamine in pet food soon followed. Horse meat and other incidents have led Food Fraud to be top-of-mind. And the AFDO membership is bracing for and embracing the Food Fraud challenge.
I recently returned from presenting again at the Association of Food and Drug Officials (AFDO) annual conference with some interesting feedback on Food Fraud. This feedback is important for industry because the attendees of AFDO are THE food and drug officials… the people who will be establishing and implementing the regulations. They have concerns about Food Fraud, and AFDO is helping to define how regulations will be implemented. Their priority list will become your priority list. Their membership is not only bracing for but embracing the challenge of Food Fraud.
AFDO is the “premiere professional organization for regulatory food, drug, and medical device officials from local, state and federal agencies.” Also, “AFDO has become a recognized voice in determining and shaping the national policies that affect all public health stakeholders. The consensus AFDO develops is a key to advancing uniform laws, regulations and guidelines that result in more efficient regulation and less confusion among industry in the marketplace.”
I’ve presented at several AFDO conferences and I can tell you that this is one of the most concentrated gatherings of some of the most important leaders in this space. It is important that these leaders represent a collaboration and coordination point for federal, state, and local entities. For me, especially because I focus on an emerging and interdisciplinary issue like Food Fraud, AFDO provides a very unique and important opportunity to immerse in the issues.
I was prepared for resistance or frustration since Food Fraud was going to be adding more work to the responsibilities of the agency inspectors. The expertise to identify and prevent Food Fraud is quite different than for traditional Food Safety incidents. But I shouldn’t have been surprised by this dedicated group of professionals, because the AFDO members accepted and embraced the challenge. In part, I think they knew they would be held accountable for Food Fraud incidents. In part, I think they knew the science would rally to help achieve the compliance and prevention goals and objectives within the context of current standard operating procedures and skill set.
I like to find real world, common examples to explain complex, developing subjects. The example of current procedures and skill sets that resonated with the AFDO audience is of a Customs agent. We need to first understand this agent’s day-to-day activities and challenges in order to then provide education and training correlated to the situation.
I provided an example involving seafood fraud and a Customs agent on the Blue Water Bridge from Port Huron, Michigan to Sarnia, Canada. This is a typical real-world situation. If we know of species-swapping of a fish, we can’t just send out a general notice to every border station. I think we’d be hard pressed to find too many Fisheries and Wildlife professors who could tell the difference between two similar fish fillets. The border guard is monitoring 1,000 cars a day and looking for people hiding in the trunks or hidden bales of marijuana. Now inspect fish fillets?
What we can do is create an alert something like this: “Look for non-commercial trucks such as pick-up trucks that have 30+ gallon coolers of raw white-color fish fillets.” That is a specific set of attributes the guard can watch for. Any suspicious drivers can be directed to the inspection area. A supervisor can conduct a further review or send in pictures to a central resource. This type of Food Fraud countermeasure optimizes the resources and is effective at detection.
The feedback I received during the conference confirmed that the AFDO members are indeed bracing for and embracing the Food Fraud challenges facing them. If the review process is well defined, we don’t need to develop subject matter experts on the Food Fraud prevention strategy. The inspectors or auditors don’t need to be experts in developing or evaluating a Food Fraud policy or strategy. We need to figure out how to separate the strategy policy-making from the implementation of strategy, and then devise inspection or audit criteria that indicate the system is in place, in balance, and that procedures are followed. It is critical that we academics work to define the foundation, then engage the public and private practitioners to help create a holistic, all-encompassing, global response. AFDO plays a critical role. Reach out and find your collaboration points… and participate. JWS.