This is an excerpt of an email from a food industry leader. If this person has this question then I’m sure many of you do as well. The original question was: “Would a good food defense program help prevent ‘intentional adulteration’?”
Answer: Maybe. Probably not yet…
The “maybe” is based on questions of scope and scale of the Food Defense program. Let me begin by noting that Food Fraud is beyond an “adulterant” or “economically motivated adulteration” (EMA)… for example you may also have problems or recalls if you have country of origin fraud, mislabeling, or even unauthorized repackaging that compromises traceability.
In most cases Food Defense is defined as combating intentional attacks for harm. The attackers often want to get publicity or want to really hurt people, so we often find out quickly about the act. With Food Fraud they definitely do NOT want to get caught… they’ll be sneaky, actively try to evade our tests and systems, and they’ll be both persistent and keep evolving to stay stealth.
I’m finding that, as with many types of crime, prevention is not only infinitely more cost/time effective, but it is the only thing that often actually works. Using Situational Crime Prevention, we go look for the vulnerabilities… then decide how we can reduce that threat.
At that point, when we understand the vulnerability – e.g. species swapping of animal protein – we know what and where we should test. We know what we should be testing for. That is, to “detect.” If the fraudster is in the legitimate supply chain then the countermeasure can “deter” against that specific attacker. If it is known that the customer does “some” species tests when receiving products, and new bad guys can find out that the company is testing, then the species tests lead to prevention. Also, you’re looking with the right test at the right spot at the right frequency. For example, a company was running species tests 24/7 during an incident, then completely stopped testing after the Food Fraud incident had passed. They said “Why test? The incident is over.” Click – that was the door of their fraud opportunity re-opening. They don’t need to test a lot but they should be testing at least some product… if only to counter the claim “willful negligence” for this “reasonably foreseeable hazard.”
Food Defense is evolving in practice to include all “intentional contamination.” If a company’s FD Program really does cover beyond the physical attacks, including looking for the fraud opportunities and prevention from inside and outside the legitimate supply chain, then “yes,” the Food Defense program would address Food Fraud.
It is very structurally efficient for a company to put Food Fraud under Food Defense… but the countermeasures and processes are very different. Think of combating shoplifters compared to ferreting out suppliers diluting product. What about combating employee theft versus country of origin labeling fraud. No one – me included – will ever be able to be an expert on all Food Fraud concepts and threats. We’re trying to create an educational foundation of knowledge… and then a group of colleagues. (I consider myself as the Food Fraud Librarian.) We will need to help train and support those people who will take the reigns of Food Fraud Prevention. We will need to start by defining the scope and scale of a good Food Defense Plan.
I ended my email to the food industry leader with “Actually, this would be a great blog post, maybe I’ll post it.” So I am. Consider if your Food Defense plan really does address Food Fraud prevention. Don’t wait for FSMA or GFSI… companies have Food Fraud risks every day. JWS.