Trends in Food Science & Technology 62 (2017) 215e220

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Trends in Food Science & Technology

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and-technology

Food fraud prevention shifts the food risk focus to vulnerability

John Spink a, *, David L. Ortega b, Chen Chen c, Felicia Wu c
a
1129 Farm Lane, B51, East Lansing, MI 48864, USA
b
446 W. Circle, East Lansing, MI 48824, USA
c
469 Wilson Rd, East Lansing, MI 48824, USA

a r t i c l e i n f o a b s t r a c t

Article history: Background: Food fraud e including the sub-category of economically motivated adulteration e is illegal
Received 28 October 2016 intentional deception for economic gain using food. The types of food fraud include adulterant-
Received in revised form substances (adulteration), substitution, dilution, stolen goods, tampering, diversion and gray market
19 January 2017
product, smuggling, unauthorized product or unauthorized re-filling, misrepresentation or mislabeling,
Accepted 13 February 2017
Available online 27 February 2017
and intellectual property rights counterfeiting. Key events include Sudan Red colorant, melamine in
infant formula and pet foods, species swapping of fish, counterfeit branded chocolate, and horsemeat in
packages labeled as beef. While most food fraud events do not have an immediate hazard, the food
Keywords:
Food fraud
supply is vulnerable. The issue involves intelligent human adversaries, so the response is uniquely
Economically motivated adulteration complex regarding mitigation and prevention.
Vulnerability Scope and approach: This commentary provides insight on the unpredictability and potential economic
Assessment gain to fraudsters; and presents food fraud as an emerging, unique and autonomous food research area.
Crime The need to assess a food fraud event shifts the focus from the traditional internal process controls and
Food safety human health risk assessment to prevention and vulnerability reduction. The goal is not to catch food
fraud but to prevent the event from ever occurring e food fraud prevention.
Key Findings and Conclusions: Often, traditional food safety or food defense countermeasures and
assessment methods are ill-fitting tools for the unique food fraud prevention goals. To address the root
cause of fraud, food science and technology research should expand to include social science, crimi-
nology, and business decision-making. This commentary provides insight that a shift from “risk”
“mitigation” to “vulnerability” “prevention” is necessary for food fraud prevention. We provide clarity on
important terms, which include event, incident, hazard, crisis, and threat.
© 2017 Elsevier Ltd. All rights reserved.

1. Introduction illegally added “adulterant-substance,” there was no identified

Food fraud events e illegal intentional deception for economic
gain using food - can occur in all stages of the supply chain and
often cross international borders (Everstine, Spink, & Kennedy,
2013; Moore, Spink, & Lipp, 2012). Under certain circum-
stances, food fraud can have significant health and economic
implications, but not always. In recent years, illegally added
horsemeat to beef products created economic and consumer
confidence crises across Europe (EC, 2015). Prior to detection, no
one except the fraudsters knew that the less expensive horse-
meat was in the beef product. While the horsemeat is clearly an
public health hazard. Yet this event had a massive economic
impact: widespread product recalls and costly authenticity
testing, and the effective halting of almost all ground beef sales
in the United Kingdom and across Europe.
In another food fraud event,1 several multinational food service
companies were victims of an alleged date-code tampering scheme
that led to the distribution and sale of illegal expired meat
(Premanandh, 2013; EC, 2015). There was technically no “adul-
terant-substance” in this event, and numerous tests confirmed that
there was no public health hazard. Nonetheless, this event had a

* Corresponding author.
E-mail addresses: spinkj@msu.edu (J. Spink), dlortega@msu.edu (D.L. Ortega),
chenc115@msu.edu (C. Chen), fwu@msu.edu (F. Wu).
1
This study uses the term ISO 31000 Risk Management term “event.” Later the
terms will be reviewed in more detail including “incident,” “threat,” and “hazard.”
This is not in conflict with other laws, regulations, standards and certifications. For
additional comments about following ISO 31000 see Leitch (2010) and Purdy
(2010).

http://dx.doi.org/10.1016/j.tifs.2017.02.012
0924-2244/© 2017 Elsevier Ltd. All rights reserved.
216 J. Spink et al. / Trends in Food Science & Technology 62 (2017) 215e220
massive economic impact; as after the discovery of the false expi-
ration dates, several multi-national restaurants had no meat
product to sell in several countries. Due to this event, one of the
victims of fraud, McDonald's Corporation, was estimated to have
had a stock price drop of more than $500 million on the day the
event was reported, and a monthly global sales loss of over $40
million2 (Forbes, 2014; Jargon, 2014).
Both events highlight the failure of traditional food safety and
food defense systems and processes to address food fraud vulner-
ability. The deception in food fraud cases can be adulterant-
substances (adulteration), substitution, dilution, stolen goods,
tampering (including date-code tampering), diversion and gray
market product (e.g. product sold outside its intended supply chain
or market), smuggling, unauthorized product or unauthorized re-
filling, misrepresentation or mislabeling, and intellectual property
rights counterfeiting (Spink & Moyer, 2011; DEFRA, 2014; EC, 2014;
GFSI, 2014). To successfully commit these acts, the fraudsters are
clandestine, stealthy, diligent in seeking opportunities, often well-
funded, and patient in waiting for fraud opportunities. A great
challenge is that food fraud acts occur outside the authorized
supply chain, and often do not involve adding a monitored sub-
stance (an adulterant or contaminant that is monitored). Addi-
tionally, fraudsters usually demonstrate technological expertise
and actively seek to avoid detection (Primrose, Woolfe, & Rollinson,
2010).
Although food fraud prevention is emerging as a unique food
research area due to the unpredictability and potential economic
gain to fraudsters, food fraud events are not new. From thousands
of years ago, there is evidence of fraudulence involving French wine
and olive oil deceptively represented as Roman Empire products
(Fortin, 2009). Many of the earliest food laws in the 1500s were
created to address food fraud such as the Reinheitsgebot related
Food Purity Laws (Fortin, 2009). There are also reports of laws to
address fraudulent acts during the Chinese Zhou Dynasty, which
spanned from 1056 to 256 BCE (Wu et al., 2017, p. 1).
Along the timeline of history, food fraud events have probably
not increased per consumer; but globalization and industrialization
have amplified the scope and scale of each event. Due to global-
ization of production and distribution, modern food fraud events
could be massive in scale and have regional or global impact. For
example, the 2007 melamine events in infant formula and pet food
from China had an international scope; whereas in time past, food
products would largely not have been distributed outside their
neighborhood, city, valley, province or country.
2. A new paradigm for managing food fraud risk
Addressing food fraud has led to a shift in focus from mitigation
to prevention. Prevention and mitigation try to accomplish the
control but from different directions. Mitigation assumes the event
will frequently occur, so we try to mitigate or reduce the negative
consequence. Prevention assumes that the root cause of the event
could be eliminated or at least greatly reduced in likelihood of
occurrence. Food fraud vulnerabilities may have never occurred
before, may never occur again, or may be a potential opportunity
that never leads to an actual food fraud event. For efficient man-
agement, this nature of food fraud necessitates a shift of the focus of
countermeasures and control systems from intervention and
response to prevention.
2
McDonald's market capitalization is approximately $90 billion and an approx-
imately 0.5e1% one day drop in stock price would be a loss of $450e900 million of
value; their annual sales are approximately $27.5 billion so one month loss of 2% is
$45 million.
Table 1
Summary of Terms with a statement of occurrence, harm and intentional.
Term Occurred Hazard or Crisis Intentional
Event Yes Maybe Maybe
Incident Yes Yes Maybe
Hazard No Yes Not usually for Food
Crisis Yes Yes Maybe
Threat No Yes Usually for Food
Vulnerability No Maybe No
Risk Maybe Maybe Maybe
There are many instances where e even in laws or regulations e
the most basic and fundamental terms are not defined explicitly or
included in a glossary. Where there were discrepancies in termi-
nology, this study follows the International Standards Organization
(ISO) practices (ISO, 2007; 2007a, 2007b). Usually discrepancies are
variations of common terms applied to a specific product or
application such as the US FDA food laws defining a “hazard” as
“any biological, chemical (including radiological), or physical agent
that has the potential to cause illness or injury.”3
The things that could, are likely to, or have happened are defined
as an event or a crisis. An event is essentially something that occurs
(Table 1) (ISO, 2002; CNSSI, 2010; Merriam-Webster, 2004). There
is no evaluation yet of the change in the consequence. A type of
event is an incident that has occurred and evaluated and that could
have a negative consequence (DHS, 2008; ANSI, 2009; CNSSI, 2010).
Also, a hazard is an event that has not occurred and could cause
harm if not addressed (ISO, 2007b; PAS 96, 2014, NRC, 1996; 21 CFR,
Merriam-Webster, 2004) e this includes damaging potential (ISO,
2007b). For food this is often applied to unintentional events that
have potential to harm. A crisis is an event that has occurred e or is
occurring e that has a confirmed harm (ANSI, 2009) e this includes
imminent hazard (21 CFR), attack, emergency (ISO, 2007b; 21 CFR,
FDA. 2016), disaster, etc.
The assessment of the thing that happens is expressed as risk or
threat. Risk is an uncertainty of an outcome that is assessed in
terms of likelihood and consequence (ISO, 2007a; NIST, 2002;
CNSSI, 2010; DHS, 2013). Often the consequence is sub-divided to
other factors such as onset, severity, or other. Risk is a based on
factors of the probability of the threat and the susceptibility from
vulnerability (NRC, 2009). In other applications it is an unwanted
outcome (DHS, 2008, Codex Alimentarius, 2014, 21 CFR 50 (A)
(.3)(k), Merriam-Webster, 2004). A threat is the cause of an un-
wanted event that includes generally known variables or attributes
of the source of the negative consequence (“threat source”) (ISO,
2012; ISO 2002; 21 CFR 121, ANSI, 2009; PAS 96, 2014, FSMA,
2016; NIST, 2002; CNSSI, 2010; UNODC, 2010; DHS, 2013) e this
includes incident, hazard, damaging potential, etc. In crime and
security science this is often a person(s) who have the intent and
capability to cause harm. This is often applied to intentional acts
with the intent to harm. The result of a threat assessment is usually
a quantitative probability that the event to occur e but not an
assessment of the consequence.
Vulnerability is a weakness or flaw that creates opportunities
for undesirable events related to the system (“system design”)
(ISO, 2007a; ISO 2002; ISO, 2012; DHS, 2013; NIST, 2011; CNSSI,
2010; NRC, 2009; COSO 2014; Merriam-Webster, 2004). The
result of a vulnerability assessment is usually a qualitative state-
ment of the susceptibility of the system e this influence the
likelihood (NRC, 2009). FSMA uses the term vulnerability
3
The summary definitions are based on extensive review of a wide-range of
sources summarized and referenced in the supplemental materials.
 J. Spink et al. / Trends in Food Science & Technology 62 (2017) 215e220
specifically as it applies a vulnerability assessment to food defense
(21CFR 121, 21 USC).
The countermeasures include mitigation and prevention. Miti-
gation is intended to reduce the consequence of the event (ISO,
2007a; ISO, 2007; ISO, 2007b; DHS, 2013; Merriam-Webster,
2004). This assumes the hazard event will occur so the goal is to
mitigate or reduce the negative consequence. This focuses on
reducing the risk that cannot be eliminated. Prevention is intended
to reduce or eliminate the likelihood of the event occurring (ISO,
2007; ISO, 2007a; ISO, 2007b; ISO, 2008; Merriam-Webster,
2004). This focuses on identifying and eliminating or reducing
vulnerability.
Therefore, we could consider food fraud vulnerability, food
fraud threat, and food fraud risk differently. Food fraud vulnera-
bility is the susceptibility of a system to food fraud (e.g., milk is
not tested for adulterants such as water). Food fraud threat is the
cause of a food fraud event; e.g., a criminal could dilute milk with
water and then sell to a deceived customer. Finally, food fraud risk
is the combined likelihood and consequence e that considers the
threat and vulnerability e of food fraud. This is a function of the
vulnerability and threat; e.g., an estimate of the likelihood and
consequence of milk diluted with water, sold to a deceived
customer. Following these definitions, it is important to note that
there could be a vulnerability assessment, separate from a risk
assessment, for food fraud or for food defense (food safety risk is
traditionally addressed in a Hazard Analysis and Critical Control
Point HACCP plan).
3. Developing a risk, threat, and vulnerability framework
A new paradigm is needed to assess and manage the vulner-
ability of food fraud events. As mentioned above, if there is an
adulterant-substance such as melamine, it is often not a tradi-
tional food contaminant for which monitoring systems exist. Food
safety early warning systems address common food contaminants
that are known and regularly occur in even well managed food
supply chains. The underlying issue is that industries and new
products are growing or changing faster than regulations, detec-
tion methods, or academic studies can address. The food industry
is responding, and is making efforts to do even more, to transform
from prescriptive, internally focused process controls to address-
ing food fraud separately from food safety and food defense. The
Food Risk Matrix (Fig. 1) is provided to help clarify the differences
in the key terms.
Risks in food safety are typically unintentional, and are a
generally known set of common chemicals or pathogens in food
Motivation:
Food Food Economic Gain
Quality Fraud
Harm including
Food Food health,
Safety Defense economic, terror
Unintentional Intentional
Fig. 1. Food Risk Matrix used to differentiate Food Quality, Food Safety, Food Fraud and
Food Defense (Spink & Moyer, 2011).
217
that carry a public health hazard (WHO, 2016). Risks in food de-
fense come from intentional acts with the intent to harm. Risks in
food fraud are also intentional, but without an intent to harm hu-
man health; often a novel method or adulterant-substance, yet
compromising the integrity of the food products, and may have
unintended health related consequences in some cases.
4. Government challenges
This prevention and vulnerability-focused approach provides
challenges for regulators, as most food governance agencies e and
law enforcement in general e focus on and respond to events and
emergencies. The priority for government agencies and law
enforcement is first to protect public safety and health, followed by
economic impacts and technical legal violations. To optimize scarce
resources, food agencies have logically taken a public health risk-
based approach, but not all food fraud events actually jeopardize
public health. By prioritizing public health hazards (food safety) or
catastrophic events (food defense), food fraud events would usually
be at the bottom of those two risk-based priority lists.
Another difficulty for regulators to manage food fraud is that
food laws and inspections usually focus within very defined and
physical systems, such as a manufacturing plant or an authorized
supply chain. Food fraud often occurs outside the known and
trusted system. Even if food fraud occurs within a known plant or
supply chain, the fraudsters create a fraud opportunity by finding
ways to circumvent and deceive the countermeasures and control
systems.
Yet another reason that food fraud has not been holistically
addressed is that, at first, there were too few recognized events to
detect a pattern. When more and bigger events were identified,
there was a novel application of criminology to understand the root
cause or motivation. This is a focus on reducing the “crime oppor-
tunity” or for food fraud, the “fraud opportunity.” Applying
knowledge from criminology may be logical in detecting and
reducing the vulnerability of food fraud events, as the biological
organism being addressed is not a microbe in this case, but a human
or group of individuals with fraudulent intent.
5. Integrated risk assessment and risk-based inspections: the
example of melamine
As previously discussed, usually food fraud events do not have a
public health hazard. However, exceptions such as the melamine
adulterant-substance, which provide evidence that some events
may develop into an international health panic, do occur. In-
vestigations showed that melamine had been deliberately added to
raise the apparent protein content of pet food and infant formula in
analytical tests (FAO, 2008).
In the 2007 incident of melamine addition to pet food, deaths
were reported from acute kidney failure in cats and dogs in the
United States (Lancet, 2009). These deaths were caused by vege-
table proteins imported from China that were contaminated with
melamine and incorporated into pet food (FDA, 2016). Following
the pet food event, several national and regional authorities around
the world, including the World Health Organization (WHO),4 per-
formed preliminary food safety risk assessments on melamine and
established a toxicological reference dose, as a first attempt for
public health and animal pet protection (Chan, Griffiths, & Chan,
2008). Moreover, two Chinese nationals and their businesses, as
well as a US company and its president and chief executive officer,
4
Currently the International Food Safety Authorities Network (INFOSAN,
managed by WHO and FAO) does not address food fraud prevention.
218 J. Spink et al. / Trends in Food Science & Technology 62 (2017) 215e220
were indicted by a federal grand jury for their roles in importing
products falsely labeled as wheat gluten into the US that were
contaminated with melamine (FDA, 2016).
A separate melamine scheme was uncovered after an outbreak
of illnesses among babies in multiple Chinese provinces, linked to
consumption of contaminated powdered infant formula. Over
294,000 children experienced adverse renal effects, over 50,000
were hospitalized for renal complications, and at least six died
(Ingelfinger, 2008). It was discovered that the melamine
adulterant-substance had been added for many months since
December 2007. Although infant formula companies had received
complaints from parents saying their formula-fed children's urine
was discolored, these companies did not report these complaints to
the local government until August 2008 (Chan et al., 2008).
In response, a new risk assessment statement on melamine in
food with updated information of contaminated samples was
carried out by national and regional authorities worldwide.
Several countries proposed regulatory limits for melamine in food
and feed, mainly based on traditional chemical risk assessment
methods. The US FDA's risk assessment of melamine in food
intended for humans was published in 2008 following this scandal
(FDA, 2008). Fortunately, there were very few positive test results
for melamine in infant formula reported by authorities outside of
China, which may be attributed to rapid actions such as import
bans and regulatory limits (Gossner et al., 2009). The Chinese
government has since adopted a new Food Safety Law in 2009 and
then expanded the food protection in the Protection of Consumer's
Rights and Interests in 2014 (Wu et al., 2017, p. 1). An important
addition is Article 143 which states “strict liability” for a food
safety event allowing a maximum of three year prison sentence
and up to life imprisonment for “serious harm to human health”
(Wu et al., 2017, p. 1). A “negative list” of the most concerning
substances was also created to prioritize detection of adulterant-
substances.
This event highlights the effectiveness when countries routinely
monitor food fraud in the market and the growing importance of
timely responses to take appropriate actions based on risk assess-
ment to limit the spreading of tainted product. The response to this
food fraud crisis has demonstrated that food safety is enhanced if
all the stakeholders across the food supply are sharing information
and data in an effective and timely manner. Conversely, if com-
panies fail to report consumer complaints, as in the case of the
contaminated infant formula, many tragic illnesses and even deaths
may result from food fraud.
6. Shifting focus to food fraud and prevention
In response to the melamine adulterant-substance and other
fraudulent activities in recent years, food fraud is becoming ever
more integrated into food laws and industry practices. Academic
journals e including in the fields of food science and criminology
e are starting to address food fraud. While food fraud has occurred
throughout history, the term was only defined in an academic
journal in 2011 in Defining the Public Health Threat of Food Fraud
(Spink & Moyer, 2011). Building upon that literature, industry
groups are defining and now collectively addressing the subject.
Several of the key government activities include the European
Commission adopting a common definition of food fraud and a
focus on prevention, the United Kingdom Elliott Review of Food
Crime adopting the broad term and supporting the establishment
of the National Food Crime Unit (NFCU), and other countries like
China are beginning to broadly address the topic (DEFRA, 2014; EC,
2014; IFT, 2015). The FSMA addressed food fraud and economically
motivated adulteration within the Preventive Controls Rule (FDA,
2015). The FSMA scope includes all “agents” that could lead to a
“hazard” from acts that are “economically motivated” e so it covers
all types of food fraud explicitly including stolen genuine goods that
have been mishandled leading to a health hazard from mishandling
spoilage (FFI, 2015). The US Government Accountability Office
(GAO) and the US Congressional Research Service (CRS) have
emphasized an expectation that the US FDA broadly prevent food
risks including EMA and food fraud (Gao, 2011; CRS, 2014). With
the current exception of the USA, governments are evolving to an
inter-agency task force based approach to preventing food fraud
rather than just catching adulterant-substances.
The first step to prevention is developing a common starting
point and the developing and sharing of best practices for
vulnerability assessments. As the proactive food fraud prevention
concepts have been defined, industry is responding. Several of
the industry activities include workshops by the Grocery Man-
ufactures' Association, the Institute of Food Technologists, Food
Drug & Law Institute, European Union Food Integrity Project,
INTERPOL Operation Opson, and others (FDLI, 2015; GMA, 2010;
INTERPOL, 2012; EC, 2015; IFT, 2016). The most comprehensive
activity is by the Global Food Safety Initiative's (GFSI) including
their position paper on food fraud (GFSI, 2014). GFSI will require
unique compliance requirements for addressing by requiring a
Food Fraud Vulnerability Assessment and a Food Fraud Preven-
tion Strategy (GFSI, 2016). GFSI has also created a Food Fraud
Technical Working Group to continue to address the issue. Since
most of the food companies in the world comply with GFSI
guidance in one way or another, this pending requirement is
already impacting the world. Industry is clearly focusing broadly
on food fraud and prevention.
Some additional next steps include that Certification and Stan-
dards bodies are also starting to address food fraud. The US Phar-
macopeia/Food Chemicals Codex has several ongoing Expert
Panels, is creating several guidance documents, has developed a
“Food Fraud Database,” and had developed a food fraud vulnerably
assessment guidance for food ingredients (USP, 2013). In related
activities, the International Standards Organization (ISO) is broadly
addressing food fraud which includes standardized definitions and
work processes (ISO, 2010). In 2016, a Codex Alimentarius group is
working on a “Proposal for Food Integrity/Food Authenticity
Guideline.” Also in 2016, food fraud has been a topic for the Inter-
national Food Safety Authorities Network (INFOSAN) (a global
network of national food safety authorities, managed jointly by FAO
and WHO with the secretariat in WHO).
Recent food standards and certifications have split intentional
events out of the base Food Safety Risk Assessment into a separate
Food Fraud Vulnerability Assessment and a Food Defense Threat
Assessment (for US FDA this is a Food Defense Vulnerability
Assessment). Separating the assessments e under an overall Food
Safety Risk Assessment e is logical and efficient. For prevention,
Food Safety, Food Fraud and Food Defense are very different root
causes. Separating and refining the assessments is efficient and
effective. The application of these assessments leads to a hazard
assessment for Food Safety (HACCP), a vulnerability assessment for
food fraud (or Vulnerability Analysis and Critical Control Point plan
- VACCP) and then a threat assessment for food defense (Threat
Analysis and Critical Control Point plan - TACCP).
7. Conclusion
Addressing food fraud can be inefficient and elusive if efforts are
focused on the traditional food safety and food defense systems and
programs. The methods for addressing those other hazards are ill-
fitting tools for addressing food fraud.
 J. Spink et al. / Trends in Food Science & Technology 62 (2017) 215e220
For food fraud prevention, the challenge is simplified once there
is a fresh look at the event from the perspective of the fraudster and
the fraud opportunity. The countermeasures become clear when
the focus shifts from the problem outwards to the countermeasure
rather that from current technologies or laws inward to the prob-
lem. When looking at it from the problem outward there are
fundamental concepts and basic attributes that are revealed when
trying to apply inappropriate or ill-fitting tools or models. Since the
problem is created by an intentional intelligent human adversary
the next step is to focus on food fraud as a crime and apply crime
prevention theories.
For companies or countries to address the root cause of fraud,
food science and technology research should expand to include
social science, criminology, and business decision-making. The root
cause or motivation involves human decision-making. Criminology
provides theories to understand the problem and to evaluate
countermeasures to preserve food integrity. Business decision-
making e and decision-science e helps to address the question of
“how much is enough?”
Researching and understanding the food fraud focus on pre-
vention has led to a shift in focus on vulnerability in our food
systems. Addressing food fraud has led to expanding food science to
include criminology and business decision-making. Overall, the
complexity of food fraud vulnerabilities will lead to a fresh and
important focus to food protection: shifting from “risk” “mitiga-
tion” to “vulnerability” “prevention.”
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