Written by: John Spink
Primary Source: Food Fraud Initiative
With my co-author, MSU’s Doug Moyer, we are grateful for the opportunity to publish this article in New Food Magazine. This post is an overview of that article, as well as a review of some of the key underlying concepts.
From our article: “Food Fraud is a very hot topic at the moment and the development of a ‘Food Fraud Vulnerability Assessment’ is the next important step. … A key point is that the assessments need to cover all food fraud, not just adulterants. The assessments also need to provide analysis that supports clearly defined decision-making for companies and countries.”
“The scope of the assessments should include:
- Who will use the assessment?
- How will they use it and to make what decisions?
- What format is needed for the analysis to be directly applied?”
These seem like very basic – too basic – questions… but the most basic questions are often the hardest to answer. Also, through ISO, business, or other project development, we’ve experienced great differences in “common knowledge.” Beyond developing the models, an even more basic value is just getting together and writing down our goals, objectives, expectations and needs (see our past blog post about the confusion created from “The Four Definitions of Food Quality”).
Vulnerability or Risk
Framing the foundational concepts are important BEFORE we start developing models or tools because it sets our entire thought process, expectations, and methodology. With my MSU colleagues Hannah Distinguished Professor Felica Wu (Food Science and Food Safety Risk Assessment) and Professor David Ortega (Biological and Agricultural Economics and willingness to change or comply) we are finishing two scholarly articles that address this question in great detail.
Model or Tool
This is another academic discussion, but a model usually provides insight on how a system responds to different stimuli or treatments (with higher oxygen content C. Botulinum growth is slowed) and a tool provides insight on how to make a decision (when you find 3 colony-forming units the batch is “unfit for commerce”).
Prevention or Mitigation
“The goal is crime prevention, not just crime reduction or the reduction of the impact of an adverse event.” It might seem like a purely academic discussion as to whether the optimal term is “prevention” or “mitigation.” Many times there are common terms based on the practices of the discipline of those who started the process. Food Safety professionals are accustomed to addressing “risks” and you “mitigate” a risk. When combating Food Fraud we aspire to “prevent.”
“From as early as the mid-1700s, criminology has had a focus on ‘prevention’ (to keep from happening) not ‘mitigation’ (to make less harsh). For example, 300 years ago the criminology scholar Bentham once stated “the ultimate goal is the prevention of all crime”. Another source stated that “if the peace has been kept, crime has in effect been prevented” and that the focus is to “eliminate potentially dangerous or criminal situations”. And to quote another early crime scholar, Beccaria: “Laws and punishment [and now countermeasures] should be as restrictive as necessary to deter those who would break them by making it not in their best interests to do so.” Some – admittedly not all – crimes can be prevented.”
Enterprise Risk Management: The How to Decide
Fortunately, although you probably weren’t trained on ERM in food science or food safety classes, there is a solid and widely accepted methodology for businesses to make financial resource allocation decisions. ERM is regulated – mandated – in the finance and insurance industries. There is wide agreement on harmonized methods and practices, as well as extensive resources for reference and training. There is beginning to be a large body of academic articles on the subject. Actually, with MSU’s Professor Cheri Speier-Pero, we have several research projects on “risk mindfulness” and the application to Food Fraud. “We are spending more of our time researching how companies achieve ‘risk mindfulness’ and then studying how companies assess and manage those risks. We have been conducting research on managerial accounting practices and Enterprise Risk Management (ERM).”
ERM is a logical and rigorous system that we can definitely be applied to the food industry – actually your CFO’s have probably already implemented these practices but they haven’t expanded directly into the operation side of the business. “A foundation of COSO-based ERM principles are first achieving risk mindfulness and then implementing programs “so that risk levels are managed within defined tolerance thresholds without being over-controlled or forgoing desirable opportunities.”
Public Health vs. Financial Decisions
We focus on public health and foodborne illnesses because citizens have established a minimum expectation. Consumers influence companies by making purchasing decisions. Citizens influence public policy decisions by helping their elected officials prioritize public funding. The elected officials have to balance limited human and financial resources. “Even a public health agency such as the US FDA is focused on human health outcomes but must compete for resources.”
Our Food Industry is collaborating at unprecedented levels across public-private partnerships — and globally – to combat Food Fraud. We at MSU are honored to be a part of the process. As we are all collaborating at the starting line it is important to harmonize the terminology and work toward a common understanding of the frame and ultimate objective. Stay engaged and contribute to the work, whether it is in your work-group, company, industry, country, or globally. Engage our governments when they ask for comment or insight on the overall policy, strategies, programs, and processes. Our Food Industry is on a firm theoretical foundation that focuses on prevention. Prevention is the most efficient and effective strategy. That is, efficient and effective from the perspectives of time, human resource, financial resource, and positive impact. JWS.
Spink & Moyer (2014). Food Fraud Prevention – Beyond Adulterants and to Decision-Making, New Food Magazine, Volume 17, Issue 5, pp. 18-22.
Latest posts by John Spink (see all)
- Presentation – Food Fraud Prevention Strategy for 24th HACCP Australia Conference, Sydney - August 31, 2017
- Food Fraud Prevention Compliance – What is Really Required? - August 2, 2017
- Review of FDA Presentation on Food Fraud and Economically Motivated Adulteration – FDA Deputy Commissioner for Foods Dr. Stephen Ostroff - May 31, 2017