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This study (open access) applies both the Situational Crime Prevention (SCP) framework and the Enterprise Model to the Norwegian cod fishing industry.  It makes consequential recommendations for improving fraud prevention.  Although the SCP model has been used previously in Norway, the authors discuss whether previously adopted strategies adequately address the enterprise conditions that facilitate or drive unreported fishing.  They aim to provide new insights that can be used to reduce fisheries crime in particular and contribute to the understanding and analysis of food crime prevention in general.

The prevention frameworks and models used in this study focus on opportunities.  Five general prevention strategies are considered: increase the risk of detection, increase the effort, reduce the rewards, reduce provocations, and remove excuses. SCP focuses on the decision-making process of the offender, based on the principle that all crimes involve costs and benefits and that the decisions depend on these.

The authors analyse how the current prevention mechanisms in Norwegian fisheries address the enterprise environment that affects industry actors’ behaviour and misreporting practices by applying an integrated framework of combining the enterprise model with SCP.. They discuss why the existing prevention strategies are (in)sufficient for preventing unreported fishing.

The study shows that existing prevention mechanisms mainly address supply and regulation dimensions. Despite their significant role in driving and facilitating unreported fishing, less emphasis is given to market and competition. The analysis reveals the limitations of the heavy reliance of the current prevention strategy on fisheries resource control, as many of the motivating conditions are outside the realm of the control authorities.

The authors recommend that the authorities should expand the perspective to encompass contextual challenges such as competitive conditions and low profitability.

They conclude that the framework proves helpful for analysing fisheries crime prevention, offering insights into addressing food fraud in legitimate supply chains, but the analysis would have benefited from a more apparent distinction between the different conditions that influence criminal behaviour.

Photo by Fredrik Öhlander on Unsplash

This review (purchase required) and its associated recommendations is primarily aimed at regulators and competent authorities, but also has implications for food businesses.

The aim of was to consider food-related fraud prevention initiatives, understand what has worked well, and develop a series of recommendations on preventing food fraud, both policy related and for future research.

The authors found that reactive (including intelligence based) food fraud detection dominates over prevention strategies, especially where financial, knowledge, and time resources are scarce. First-generation tools have been developed for food fraud vulnerability assessment, risk analysis, and development of food fraud prevention strategies. However, examples of integrated food control management systems at food business operator, supply chain, and regulatory levels for prevention are limited.

They conclude that the lack of hybrid (public/private) integration of food fraud prevention strategies, as well as an effective verification ecosystem, weakens existing food fraud prevention plans. While there are several emergent practice models for food fraud prevention, they need to be strengthened to focus more specifically on capable guardians and target hardening.

Food Fraud Prevention – ISO 31000 Risk Management

Welcome! In support of the Food Authenticity Network (FAN), this blog series reviews key topics related to food fraud prevention. Watch here for updates that explore the definitions of food fraud terms and concepts.

This blog post builds on our previous review of the definition of risk and vulnerability as well as mitigation and prevention to review the International Standards Organization publication ISO 31000 Risk Management. The next blog post will shift focus to the ISO 31000 Risk Management concepts of the likelihood and then a separate blog post on the consequences.

International Standards – and specifically the International Standards Organization (ISO) – are efficient places to start when considering terms, definitions, and basic management system standards. Specifically, ISO 31000 Risk Management provides a crucial fundamental reference. Also, it is crucial to review what is published in this type of consensus-based, government-endorsed, official publication or what is part of informal documents or meeting notes (several of the widespread food fraud-related terms were published in workshop reports or even just meeting invitations). ISO 31000 Risk Management was published as a formal standard in 2009 after many years of a contensious consensus-driven process involving national standards organizations. This superseded more informal reports or informal guidance such as ISO Guide 73 Risk Management Vocabulary.

The publication of ISO 31000 was often contentious since some industries used terms in different applications. With the publication of ISO 31000, some people would need to change to achieve harmonization. Fortunately, food fraud prevention was developed after ISO 31000 was published (e.g., ISO 31000 significantly impacted my research and projects). Thus, from the start, food fraud prevention has focused on vulnerability and presenting the assessment in terms of “likelihood” rather than “probability” and “consequence” rather than “severity.”

ISO 31000 and Risk

In ISO 31000, a risk or vulnerability is defined in terms of likelihood AND consequence. It is critical to note that the assessment must cover both if the event occurs but also this impact. For example, jaywalking and murder are both clearly crimes, but the risk response is more based on a function of the consequence. An interesting – and often uncomfortable - realization for food safety professionals is that ‘risk’ does not only have negative consequences. Admittedly, food safety almost exclusively uses ‘risk’ for situations where there is an ‘unacceptable risk’ or a “hazard that requires a preventive control.” Understanding that, in the big picture, ‘risk’ does have an upside, such as financial investments.

• Risk (ISO 31000): “effect of uncertainty on objectives;”
  • NOTE 1: An effect is a deviation from the expected — positive and/or negative.
  • NOTE 3: Risk is often characterized by reference to potential events (2.17) and consequences (2.18) or a combination of these.
  • NOTE 4: Risk is often expressed in terms of a combination of the consequences of an event (including changes in circumstances) and the associated likelihood (2.19) of occurrence.

Then, a type of risk is a vulnerability.

• Vulnerability (ISO 31000 citing Guide 73): “intrinsic properties of something resulting in susceptibility to a risk source (3.3.10) that can lead to an event (3.3.11) with a consequence (3.3.18)."

“ISO 31000 includes a consideration for the preliminary or general assessments that may not require data that is very detailed, accurate, precise, certain, or robust decisions. What is often important is that ‘a’ risk assessment is conducted as long as the specification of the low certainty and low robustness is clearly defined. For food fraud prevention decisions, there may not be a lot of detail needed for a decision, or details may not be provided (at least not yet).” (Reference 1)

It is very important and of great value that ISO 31000 Risk Management provides a common set of terms.

Watch out for the next blog, which will review the application of ISO 31000 Risk Management topics of “likelihood versus probability” to “consequence versus severity.”

We’d love to hear from you in the comments box below if you have any questions on this blog.

References:

1. Spink, John W (2019). Food Fraud Prevention – Introduction, Implementation, and Management, Food Microbiology and Food Safety series, Springer Publishing, New York, URL: https://www.springer.com/gp/book/9781493996193

A new vacancy for a Senior Prevention and Relationship Management Officer has arisen at the Food Standards Agency's National Food Crime Unit (NFCU).

You will lead and line manage a team ensuring delivery of Prepare, Prevent and Protect projects, enabling the NFCU to achieve the intended outcomes of its 4P strategic and tactical action plans. Working closely with the food industry, other regulatory partners and internal partners, within the NFCU and wider FSA, the team work to support identification and mitigation of known vulnerabilities and emerging threats and risks. You’ll nurture and encourage the team to develop and implement innovative methods and tactics, from conception to delivery, which protect food businesses and the public.

You'll be playing your part in keeping food safe and what it says it is, and protecting UK consumers from deceptive practices in the food sector. 

For further information / to apply: Senior Prevention and Relationship Management Officer - Civil Service Jobs - GOV.UK

The deadline is 3rd September 2023.

Food Standards Scotland (FSS) has this week launched its Food Crime Risk Profiling Tool, an online programme which allows companies to assess their vulnerabilities to criminality.

Using the tool allows businesses to assess themselves against a series of statements on topics, such as how they source materials and their supply methods, before being given an individual report at the end which will highlight areas of good practice as well including specific guidance on areas they may wish to improve on.

To support businesses through this process, FSS will be holding several free online workshops later this year to help develop opportunities to increase authenticity and improve food crime resilience – those who sign up to the tool will receive an invite to the workshops.

For more information and to sign up to the tool, visit: https://www.foodstandards.gov.scot/food-crime-risk-profiling-tool

The tool has also been added to the Tools_Guides_Reports part of our Food Fraud Prevention section.

Food Standards Scotland (FSS) is currently in the process of finalising an online risk profiling tool and guidance to support industry in preventing food crime. FSS is looking for businesses to be involved in the review stage of this initiative to ensure it supports industry and achieves its purpose.

Please see an invitation from Ron McNaughton, Head of the Scottish Food Crime and Incidents Unit:

Food Crime Risk Profiling Tool (foodauthenticity.global)

Please contact foodcrime@fss.scot by 24th June if you would like to be part of the review.

This is Tenet's quarterly publication helping in house counsel and those from a science background assessing food safety keep up to date with current and emerging fraud related risks.

If you work in the food and drinks industry and take an interest in fraud and financial crime impact in the sector, please take a look at the 3rd issue of The Secret Ingredient.

Emerging regulations and industry standards are requiring risk and vulnerability assessments of Food Fraud as a prerequisite to countermeasures and decision-making systems.

These assessments and risk management systems are not familiar food safety tools. It is effective and efficient to utilize an enterprise risk management (ERM) framework, such as developed by the Committee of the Sponsoring Companies of the Treadway Commission (COSO).

ERM risk assessment occurs into two stages: (1) a qualitative initial screening followed by (2) a more detailed quantitative assessment. All types of Food Fraud can result in enterprise-wide risks so an enterprise risk management system must cover all types of vulnerabilities.

The model developed in this paper addresses the unmet need of the first stage referred to here as the Food Fraud Initial Screening (FFIS).

Access the full paper here.

This is Tenet's first edition of their quarterly newsletter specifically focused on the prevention and protection against fraud and financial crime for the food sector.

In each issue, Tenet will provide articles to assist with fraud prevention planning, advice on protecting brand integrity and recomendations to improve quality control - all from a legal perspective.

The US National Counterintelligence and Security Center (NCSC) and the Department of Defense’s Center for Development of Security Excellence (CDSE) have published a risk mitigation guide to help organizations in the food industry understand insider risks, establish insider risk programs, and develop mitigation strategies.

The “Insider Risk Mitigation Programs: Food and Agriculture Sector Implementation Guide” was developed in collaboration with federal partners and stakeholders, including the FDA.

The guide includes links to federal resources in food and agriculture, and case studies concerning food adulteration, IP theft and active shooter incidents that were carried about by insiders.

Any organization can be exposed by an insider threat, which is a person who has authorized access and uses it to commit harm to the organization. “Those with authorized access to facilities, personnel, or information can include employees, vendors, partners, suppliers, or others,” according to NCSC. “Most insider threats exhibit risky behavior prior to committing negative workplace events. If identified early, many insider threats can be mitigated before harm to the organization occurs.”

Insider threats can target food organizations through food adulteration, food fraud, theft and workplace violence.

This guide has been added to the Food Authenticity Network's Food Fraud Mitgation section under the 'Guidance' tab.

The International Association for Food Protection (IAFP) (https://www.foodprotection.org/) is one of the three largest food-related professional associations, with more than 4,500 individual food safety professionals focusing on “advancing food safety worldwide.” IAFP started in 1911 as the International Association of Dairy and Milk Inspectors. Their focus expanded to food sanitarians and the current, broader food protection focus. For those of you not familiar with the food industry, “The term public health sanitarian shall mean a person who applies the principles of the natural and social sciences for the detection, evaluation, control and management of those factors in the environment which influence the public’s health.” (reference)

IAFP also is the publisher of several scholarly journals, including the Journal of Food Protection and Food Protection Trends. “The Journal of Food Protection is the leading publication in the field of food microbiology and remains the premier journal dedicated to food safety.”

The IAFP Food Fraud Professional Development Group has published an “interest survey” to be completed by IAFP and PDG members, plus the public at large. We are reviewing our direction for 2021 and beyond. This survey is your opportunity to be heard and to help lead the direction of food fraud prevention.

The survey takes only a few minutes to complete. 

Link to the survey: https://www.surveymonkey.com/r/FfPdg2021JulyIntroduction

QR code to the survey:

Food crime is a key threat to food companies and consumers around the world. The cost to the global food industry for food fraud (which is only one type of crime) has been estimated at around EUR 30 billion every year, according to a 2018 report by the European Commission.

Many companies are making important efforts to reduce and prevent crime from happening across the supply chain and protect their customers and consumers everywhere.

In order to help the food sector to continue strengthening its efforts in preventing food crime, SSAFE has partnered with five leading experts to develop a free educational video series. Dr. John Spink, Dr. Chris Elliott, Dr. Wim Huisman, Jason Bashura and Neal Fredrickson take us on a journey through the world of food fraud, food defence and food integrity – what it is, what the issues are, what is being done, and what can be done in the future in order to help reduce and prevent food crime from occurring.

“Throughout history food crime has been a serious problem” says Adrian Sharp, President of SSAFE. “Working together with some of the best leading experts in the world on food fraud, food defence and food integrity SSAFE continues to help increase awareness and strengthen the food supply chain across the world. This lecture series should be very helpful and informative in helping the food industry, from farm to fork, reduce food crime for a better future.”

This free video series, which can be accessed through the SSAFE website (www.ssafe-food.org), will help people working across the food sector better understand what food crime is, the different types of crime that may occur, and what a food business can do about it. Through a broad series of short videos these global experts share their decades worth of knowledge and experience to help strengthen food supply around the world.

Dr. Chris Elliott says “The SSAFE Food Crime Prevention Series is the first of its kind and I hope that both industry and government agencies will find the videos informative and helpful in combatting the growing menace of criminal activity in our global food system.”

This video series complements other important tools from SSAFE such as the Food Fraud Vulnerability Assessment tool developed in 2016 available through the 'Tools' page of the Food Authenticity Network's Food Fraud Mitigation section. This tool (available for free in ten languages) enables any food company to self-assess their vulnerability to food fraud. The tool has been a great success with 40,000+ downloads and more than 7,500 online assessments completed across 70+ countries.

In addition to these tools, SSAFE will be launching a free Food Safety Culture assessment tool this summer. Please visit the SSAFE website next month (April 2021) for further information.

The SSAFE Food Crime Prevention Lecture Series has also been added to the 'Guidance' page of the Food Authenticity Network's Food Fraud Mitigation section.

The National Food Crime Unit (NFCU) has developed this food fraud resilience self-assessment tool to support businesses in developing and implementing their counter-fraud strategy.

The self-assessment tool covers different areas that businesses will need to be aware of so that they can better identify and address process issues.

The tool is made up of 7 sections and provides advice for countering food fraud. These questions will help you to evaluate your business and identify areas for improvement. The tool will not provide you with a final score.

This can be completed anonymously and any data submitted will not be collected in a way that could identify you. The tool should take no more than 15 minutes to use.

 If you have further questions for the NFCU Prevention Team, or would like support in building your business's fraud resilience, provide your email address at the end of the tool or contact us directly at NFCU.Prevention@food.gov.uk.

Access the NFCU's food fraud resilience self-assessment tool here.

The Canadian regulatory framework prohibits selling adulterated food or selling food in a false, misleading or deceptive manner. Although the number of prosecutions for food fraud cases in Canada has steadily decreased in the last decade, except for a spike in 2017, penalties are becoming more severe (i.e. 12-fold increase in fine amount between 2008 and 2018). The majority of cases are in violation with the Food and Drugs Act, Section 5(1), which prohibits “labelling, packaging, treating, processing, selling or advertising food in a manner that is false, misleading or deceptive or is likely to create an erroneous impression.” In the cases presented in this study, violators having been found guilty were fined between $25,000 and $1.5 million, but none were sentenced to imprisonment.

To improve control over food fraud incidents, the Canadian government should clearly define food fraud and include a definition and description of the different types of fraudulent activities. To support this, the Government of Canada should raise awareness about food fraud among members of the food industry, while requiring expanded testing of raw ingredients and final products for authenticity. A critical step is for the Canadian government to conduct a country-wide food fraud vulnerability assessment to identify the most problematic types of food fraud and then create a country-wide food fraud prevention strategy. Once the prevention strategy is in place, then the most efficient countermeasures and control systems can be considered. The holistic and all-encompassing food fraud prevention focus would be on a coordinated and optimized reduction of the entire fraud opportunity. The creation of government-industry-academia partnerships would also play an essential role in preventing and combating food fraud. It is possible that few – if any – additional government allocation will be required to put the plan in place and begin to make significant improvements.

Read full paper here.

Authenticate is a cloud based technology platform, developed by the British Retail Consortium (BRC), the Food and Drink Federation (FDF) and the Seasoning and Spices Association (SSA) in liaison with the Food Standards Agency (FSA) and Food Standards Scotland (FSS), which provides companies with a tool to help combat food fraud in herbs and spices.

Basic Membership to the Authenticate system is free.

Read more about it.