Wednesday, June 12, 2013

ASPECTS OF FOOD FRAUD - PART 3 of 3

In the first two parts, of this series, I explained the different types of food fraud and why food fraud is such a large problem - not only from a safety point, but from a supply chain management and risk management perspective.  But how do we combat food fraud?  After all, food fraud has been around for as long as food has been bought and sold.

THE ANSWER????

Is the answer to prosecute the fraudster?  In part, yes.  However - even if we jail 4 of every 5, there would still be 1 fraudster doing what we don't want.  Plus, getting the evidence takes time and cooperation with government agencies (the police and customs for example).  As a company, do you wish to have the increased risk on your product for enough time to get the evidence needed to prosecute?  The risk is for the upper management to determine.  I believe the better way is prevention.




ITEMS NEEDED FOR PREVENTION

  1. True "buy in" from Upper Management.  In other words a clear strategic direction, resources, and training.
  2. Knowledge of national and international legislations and related Documents (the below is not an exhaustive list).  Learning a common language so you can talk about the issues, not only in the company but with subject matter experts at places like Michigan State University.
    • ISO 31000 - Risk Management practices
    • ISO 28000  - Security Management systems
    • ISO 22000 - Food safety
    • USP - US Pharmacopeia - methodologies to discovering adulterated products
    • GS1 - Supply Chain Standards, best practices
    • GFSI (codex) - Global Food Safety Initiative
    • FD&C act chapter 4 section 401 subsection 342 - food adulteration(American Federal Food, Drug, and Cosmetics Act)
    • TC 247 - Anti-Theft practices and becomes ISO 12931
    • Canadian Food and Drug Act
    • US Food Modernization Act
  3. Potential designation of an employee who's main focus is looking at fraud
  4. Finding out how food fraud can occur in your company - where are the weaknesses in your systems and procedures.
  5. Detailing of the risk cost analysis stemming from the loss due to potential fraud.  This will need the help and advisement from account departments.  After all, QA and packaging personnel generally have little knowledge about business finance.  What is the tolerance level of risk for your company?
  6. Being Watchful.  You will not be able to stop all fraud.  The fraudsters will continue to find new ways to get around you and your procedures.  Looking for trends (market monitoring, seizures, NCFPD database - EMA) and unusual occurrences is important.  Check out foodfraud.org - which is the USP
SUMMARY

Prevention of Food Fraud will take involvement and ideas from criminology, food science, Quality Assurance, Packaging, Procurement, sociology, economics, and others.  The point is to reduce the opportunity for the fraudster to penetrate your company and supply chain.  Increase the difficulty of fraud, increase the risk of getting caught, and decrease the economic advantages to the fraud.  Difficulty can be increased with better traceability, tamper proof packaging, authentication exercises, and security measures against theft.  These actions can be Overt (holograms on packaging), Covert (watermarks or black light marks), or Forensic (lab tests).

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