This 2019 publication, by Food Authenticity Network Advisory Board Member, Dr John Spink, is now free to download. The food fraud prevention update includes a practical recommendation for ‘How to Start?’ and ‘How Much is Enough?’
A practical approach to food fraud prevention was laid out in the Food Fraud Implementation Method (FFIM). This method has been refined over the years and was finally formalized and published in 2019 and is applicable today.
After conducting an incident review and hazard identification, the method includes 10 questions, 2 concepts, 7 steps and 1 decision. (To note, the article had seven questions but over time this was later expanded to ten.)
Photo by Irham Setyaki on Unsplash
The Food Fraud Implementation Method (FFIM): “How to Start”
“10 Questions”: For this first pass, the response is just “yes” or “no.”
- Have you conducted at least one Food Fraud Vulnerability Assessment (Y/N)
- Is it written (and can you show it to me now) (Y/N)
- Have you created a Food Fraud Prevention Strategy (Y/N)
- Is it written (and can you show it to me now) (Y/N)
- Can you demonstrate Implementation (Y/N)
- Do you have Executive Level Sign-off (Y/N)
- Have you minimally conducted an annual Food Fraud Incident Review (Y/N)
- Do you have a method to review your incidents and general market incidents (Y/N)
- Note: Do you address all types of Food Fraud (e.g., adulterant-substances, stolen goods, diversion, intellectual property rights counterfeiting, etc.) (Y/N)
- Note: Do you address all products from both incoming goods (e.g., ingredients) and outgoing goods (e.g., finished goods) through to the consumer.” (Y/N)
“2 Concepts”:
- Concept One—Formally and specifically, mention food fraud as a ‘food’ issue (e.g., in a formally approved and published corporate policy handbook)
- Concept Two—Create an enterprise-wide food fraud prevention plan (e.g., this is the Food Fraud Prevention Strategy, and it is the only link between the food fraud incident assessments and calibration with the risk tolerance assessment to the enterprise-wide system)
“7 Steps”:
- Convene a Food Fraud Task Force
- Create an Enterprise-wide Food Fraud Policy/Mission Statement and begin drafting a Food Fraud Prevention Strategy/Plan
- Conduct the pre-filter Food Fraud Initial Screening (FFIS) (e.g., this is a very high-level vulnerability assessment that covers all products across the entire enterprise. One risk matrix or assessment could meet the objective.)
- Review additional needs, including additional information or a more detailed Food Fraud Vulnerability Assessment (FFVA) (e.g., in ERM/ COSO terms, this is a “detailed assessment.”)
- Review-specific Food Fraud vulnerabilities in an enterprise risk map (Enterprise Risk Management)
- Consider countermeasures and control systems to address the ‘very high’ and ‘high’ vulnerabilities (e.g., it is helpful to provide examples of possible countermeasures or control systems. These examples will help calibrate if there is enough information to make a confident resource-allocation decision.)
- Propose a Food Fraud Prevention Strategy, including the calibration of the Food Fraud risks on the enterprise risk map (E.g., this should be in a corporate human resources template to facilitate actual resource-allocation decision discussions.)
“1 Decision”:
- Finally, after the FFPS proposal is submitted, the last step is for management to decide on the optimal plan. It is essential to consider that no decision on the new proposal is a decision – no decision is a decision that accepts the status quo. In some situations, the total resources applied to the problem may be reduced.
Enterprise Risk Management: How Much is Enough?
The connection of the Food Fraud Vulnerability Assessment to the enterprise-wide risk assessment leads to a calibration of the problems. The enterprise-wide risk map defines the issues that are above the risk tolerance. The most valuable part of the process is that the same map illustrates when there is “enough” of a risk treatment. Zero risk is not practical and often not even possible.
The FFIM has been added to the 'Guides' tab of FAN's Food Fraud Prevention section.
