Review of the UK Elliott Interim Report on Food Fraud

Written by: John Spink

Primary Source: Food Fraud Initiative

elliott reportThe UK is taking a serious look at Food Fraud laws and regulations.  It’s encouraging that many of the global agency and industry reports are focusing on the same broad concepts as well as having a distinct focus on prevention – from the start we are harmonizing the terminology and approaches.  This UK report was led by our colleague Professor Christopher Elliott of Queen’s University Belfast (QUB), and was funded by the UK’s Secretary of State for Health, and the UK Department for the Environment, Food, and Rural Development (DEFRA) to carry out an independent review of Britain’s food system regarding Food Fraud. This is a review of Professor Elliott’s December 2013 Interim report. The final report is due Spring 2014.

The UK Elliott Review – Interim Report

This report (https://www.gov.uk/government/publications/elliott-review-into-the-integrity-and-assurance-of-food-supply-networks-interim-report) was conducted to provide guidance and actionable recommendations to the UK government on combating Food Fraud.  The report was sparked by the horsemeat Food Fraud scandal but expands to all branches of government and all types of food crimes.  “The aim of the [UK Elliott] review is to advise the Secretary of State for the Environment, Food and Rural Affairs, the Secretary of State for Health, and also industry on issues which impact upon consumer confidence in the authenticity of food products. “

Summary.  This is probably the most comprehensive report written on a country’s Food Fraud threat in that it includes over 50 interviews from across agencies and industries.  There are in-depth insights as well as case studies that provide great detail on the Food Fraud threat.

There are forty-eight recommendations from across the food management system.  Major recommendations reviewed below include: Customers First, Zero Tolerance, Intelligence Gathering, Laboratory Services, Audit, Government Support, Leadership, and Crisis Management.   While many of the recommendations are already fully or partially implemented by agencies or industry, it is critical to reinforce that these activities do matter.  There is also an important emphasis on how all the recommendations should work together.  The report states that there is an efficiency gained by gathering Food Fraud intelligence and data that has already been gathered from Food Quality, Food Fraud, or Food Defense initiatives.  The report reiterates the constant challenge experienced by agencies from around the world — of receiving and sustaining resources for enforcement and prosecution of financial fraud, product fraud including intellectual property rights violations, and other food crimes.  The report started with a focus on adulteration and detection and quickly broadened to Food Fraud and prevention. “The systems approach I have recommended is intended to provide a framework to allow the development of a national food crime prevention strategy.”  Also, “Some of [The Elliott Review report recommendations] will require a change of culture within the industry and the Food Standards Agency so that they can work better together to protect consumers.”

Consumers First / Zero Tolerance. These sections stressed the importance of prioritizing the focus on public health, as well as confirming that the incidents should be prosecuted. The report included an emphasis on:

  • The importance of a systems approach and preventative measures – which is consistent with the EU draft resolution on Food Fraud, the USA FDA and the USA Congressional Research Service report.
  • Shared investment between industry and government.
  • A need for a “culture change.”  There is an industry shift to embrace and engage with Food Fraud prevention, and reports such as this provide sustained pressure.  The report encourages opportunities for agencies to collaborate with industry and non-governmental associations.  Although not directly mentioned, those partner entities include the Global Food Safety Initiative (GFSI), which is actually moving rapidly in developing new standardized processes, the Grocery Manufacturers Association (GMA), the US Pharmacopeia/ Food Chemicals Codex, and the Institute of Food Technologists (IFT). There are other broader activities focused on combating product fraud such as by the International Standards Organization’s Technical Committee 247 on Fraud Countermeasures and Controls.
  • Expanding the research focus from detection to collaborative prevention.  There is an important research need in understanding the fraud opportunity and beyond just gathering a list of incidents.  This section emphasized expanding from the detection infrastructure of laboratories to deterrence and prevention, working with industry and law enforcement. The report states that “[The Elliott Review Interim Report] to date has identified a worrying lack of knowledge regarding the extent to which we are dealing with criminals infiltrating the food industry.”

Education. This section addressed the needs of educating a wider range of stakeholders from across the public-private spectrum.  A key recommendation was  to provide education programs ranging from basic concepts for general practitioners to in-depth courses to assist auditors and intelligence analysis.  (To note, we at MSU also believe this is a key point and have continued to develop education programs such as our Graduate Certificate in Food Fraud Prevention and our Food Fraud MOOC.  See this link for more information:  http://foodfraud.msu.edu/resources/programs-courses/ .)

Intelligence Gathering.  This section of the report focused on data collection and intelligence gathering.  The report included an emphasis on:

  • The intelligence-gathering recommendations recognize the tremendous challenges when dealing with commercially sensitive information that could also have a public health threat.
  • As is consistent with many reports from around the world and from research, the report reiterates that Food Fraud is a unique threat that requires specific attention, and although distinctly different, the countermeasures should be integrated with Food Safety, Food Defense, and large scale organized crimes.

Audits. This section identifies an important role of food audits conducted by the government in conjunction with private/ industry/ third-parties, combined with a focus on engaging (and motivating) law enforcement.  It mentions audit and certification “steps already being taken by industry.”  Also, “I have found a great appetite within industry to improve and expand upon the standard audits developed by organizations…” For example: “In July 2013, Asda announced plans to introduce unannounced BRC audits for all of its Asda brand suppliers starting 1st October 2013.”

Laboratory Services.  There is a thorough discussion of the laboratory services and capacity-building.

Government Support/ Leadership.  This section emphasized the critical role of government support and leadership in Food Fraud prevention:

  • The report recommended clearer coordination and support from within the food agencies, as well as across law enforcement.  An additional missing link that was not covered in the report is prosecution and the courts prioritizing these cases – or at least not discarding them out of hand before they are even considered. The education recommendation above should include information to the prosecutors and judges.
  • The challenge for the government support and leadership is clarified when the report stated “Food fraud is a complex issue and it is not always clear, particularly when first uncovered, whether or not a food fraud problem might also be a public health problem.”

Crisis Management. This section recommended specific crisis management actions, including to basically be aware of Food Fraud incidents.  The report emphasized the important and unique collaboration between the food agencies and law enforcement.

This UK Elliott Review Interim Report is another example of Food Fraud rising on the legislative and regulatory agenda.  It’s encouraging that many of the global agency and industry reports are focusing on the same broad concepts and that those initiatives have a distinct focus on prevention.  From the start of Food Fraud becoming a global focus, the research and regulatory action we are taking is harmonizing the terminology and the prevention approaches.  With all these agency and industry groups working – and working together – there is a great potential for a global, integrated, efficient, effective, Food Fraud prevention plan.  Within your industry and within your country, stay aware of the activities and engage in the discussion.  Be part of the solution.  We will keep searching for and reviewing the latest Food Fraud reports and activities. Stay tuned!  JWS.

To be formally involved in the process please submit formal comments to: reviewfoodintegrityassurance@defra.gsi.gov.uk

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John Spink
Dr. Spink has been focused on product fraud since the Michigan State University’s Food Safety Program and the School of Packaging began research on the topic in 2006. This work expanded to the behavioral sciences and criminology and led to the establishment of the Anti-Counterfeiting and Product Protection Initiative in 2008. In 2009 the work shifted to the School of Criminal Justice where the Initiative evolved into a Program.