Food Fraud

Prevention
24th Australian HACCP Conference
Sydney, Australia / Hosted by SAI Global
August 30, 2017 / 9:20 to 10:15 AM

John Spink, PhD

Director & Assistant Professor, Food Fraud Initiative
College of Veterinary Medicine/ Food Safety

www.FoodFraud.MSU.edu Twitter @FoodFraud and #FoodFraud

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 WARNING:
Counterfeiters Attend
Anti-Counterfeit
Conferences

www.FoodFraud.msu.edu © 2017 Michigan State University 2

 Global Trends
CRIMINAL LIABILTY FOR
CORPORATE LEADERS
• Health Hazards
• Financial Reporting

© 2017 John Spink 3

 Food Fraud Curriculum
Massive Open Online Course (MOOC – free, open, online)
• Free, open, online, open to everyone, includes a ‘certificate of completion’
• Food Fraud Overview MOOC -- May & November
• Food Fraud Audit Guide MOOC -- April, July, November
Executive Education (Short-Course)
• Food Fraud Strategy, Quantifying Food Risk with Vulnerably Assessments
Graduate Courses (Online, Three Credits)
• Anti-Counterfeit & Product Protection (Food Fraud)
• Quantifying Food Risk (including Food Fraud) Research
• Global Food Safety (including Food Fraud)
• Food Protection and Defense (Packaging Module)
• Packaging for Food Safety
Outreach Education
Graduate Certificate (Online, Four Courses Each)
• Certificate in Food Fraud Prevention (Food Safety)
Master of Science in Food Safety (Online)
• www.online.FoodSafety.msu.edu

© 2017 Michigan State

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 Defining Food Fraud
• Action: Deception Using Food for Economic Gain
– Including the FDA defined sub-category of Economically Motivated Adulteration (EMA)
– Consistent with GFSI, EC/EU, UK, ISO, and others…
• Motivation: Economic Gain
– “Food Defense” motivation is traditionally harm or terror
– “Intentional Adulteration (general)” is any substance purposely added for any reason
– “Intentional Adulteration (FSMA-IA)” is terrorist or large scale attack for health harm
• Effect:
– Economic Threat
– Public Health Vulnerability or Threat

Examples • Unauthorized unsanitary repackaging (up-labeling

• Horsemeat in ground beef
• Peanut Corporation selling known
contaminated product
• Diluted or extra virgin olive oil
• Melamine in pet food and infant formula
• Over-icing with unsanitary water
or origin-laundering)
• Cargo Theft reintroduced into commerce/ Stolen
products
• Expired product date code tampering or
“refreshing”
Reference: Spink & Moyer (2011). Defining the Public Health Threat of
Food Fraud, Journal of Food Science

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 The Food Risk Matrix
Prevent by Understanding the Motivation

Motivation
Food  Food 
Quality Fraud Gain: 
Economic 

Food  Food  Harm: 

Safety Defense Public Health, 
Economic, or 
Terrorism Terror
Unintentional Intentional
Action
Source: Adapted from: Spink (2006), The Counterfeit Food and Beverage Threat, Association of Food and Drug Officials (AFDO), Annual 
Meeting 2006; Spink, J. & Moyer, DC (2011) Defining the Public Health Threat of Food Fraud, Journal of Food Science, November 2011

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 GFSI v7 Definitions
• Food Safety
– A concept that food will not cause harm to the consumer when it is
prepared and / or eaten according to its intended use.
• Food fraud
– A collective term encompassing the deliberate and intentional
substitution, addition, tampering or misrepresentation of food,
food ingredients or food packaging, labelling, product information
or false or misleading statements made about a product for
economic gain that could impact consumer health.
• Food defence
– The process to ensure the security of food and drink from all forms of
intentional malicious attack including ideologically motivated attack
leading to contamination.
• Food Security (WHO, Global definition): safe, nutritious,
continuous supply of food (not protecting food from attack)

© 2017 Michigan State University 7

 GFSI Conference 3/2014

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 What is Food Fraud?
All Fraud
UK, EU, GFSI, China,
ISO…
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FDA/FR “Economically
Motivated Adulteration”
FDCA & FSMA-PC
Substitution

Dilution Contaminant

Food Fraud Grey Market/

Counterfeiting Theft/ Diversion

Over-Runs Unapproved Tampering

Mislabeling
Enhancements

Source: Food Fraud Think Tank Presentation, GFSI, 2012, 2013, 2014

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 GFSI Issue 7 Published
Food Fraud Terms
FSM AI 21 Food fraud vulnerability assessment
• The standard shall require that the organisation has a documented food
fraud vulnerability assessment procedure in place to identify potential
vulnerability and prioritise food fraud mitigation measures.
FSM AI 22.1 Food fraud mitigation plan
• The standard shall require that the organisation has a documented plan in
place that specifies the measures the organisation has implemented to
mitigate the public health risks from the identified food fraud
vulnerabilities.
Every ‘vulnerability’ does NOT need a control plan.
FSM AI 22.2 Food fraud mitigation plan
• The standard shall require that the organization's Food fraud mitigation
plan shall cover the relevant GFSI scope and shall be supported by the
organisation’s Food Safety Management System.
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 Inspection or Investigation
• Inspection (Compliance):
– No active incident
– Function: regulatory compliance, audit inspection
– Convince an auditor or inspector that you meet the requirements
– Q: Explain the process is in compliance
• Investigation (Prosecution):
– Active incident: e.g. a baby just died
– Function: Legal liability, criminal investigation
– Present evidence to an investigator or prosecutor to prove no
willful blindness or neglect
– Q: Explain why this incident was NOT a “hazard that
required a preventive control”

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 Criminology: The Chemistry of the Crime
Business Decision: Enterprise Risk Management
Review Incidents Enterprise-Wide
Enterprise-WideRisk
Risk
Assessment
Assessment

Detect
Initial Screening
Vulnerability Rank
Deter (FFIS) (FFVA)
Assessment
Prevent
Adulterants
Tampering
Theft
Over-runs
Diversion
Counterfeits

Countermeasures

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 I. Implementation Steps for
Government Agency or Industry
• Concept One: Formally, and specifically,
mention food fraud as a food issue and
– “This statement confirms that AGENCY expects the food industry to
conduct risk or vulnerability assessments, including mitigation or
prevention plans where warranted, on all incidents that could lead to
a health hazard or the violation of a food law such as the FSMA or
the FD&C. This includes all Food Fraud such as adulterant-
substances, tampering, theft, illegal diversion or gray markets, illegal
mislabeling, and intellectual property rights or product counterfeiting,
and others. Consistent with existing Federal and State laws and
regulations, third-party certifications play an important role in
supporting this type of food supply chain protection.”
• Concept Two: Create an enterprise-wide
Food Fraud prevention plan
Source: Spink, J., Fortin, N. D., Moyer, D. C., Miao, H., & Wu, Y. (2016). Food Fraud Prevention: Policy, Strategy, and Decision-
Making–Implementation Steps for a Government Agency or Industry. CHIMIA International Journal for Chemistry, 70(5), 320-328. (ISI
Impact Factor = 1.349; Scopus SJR = 0.55) (With translation to Mandarin/ Chinese)
II. Food Fraud Prevention Strategy
Implementation Series of Activities
1. Convene a Food Fraud Task Force
2. Create an Enterprise-wide Food Fraud Policy/Mission Statement and
begin drafting a Food Fraud Prevention Strategy/ Plan
3. Conduct the pre-filter Food Fraud Initial Screening (FFIS)
4. Review additional needs including additional information or a more
detailed Food Fraud Vulnerability Assessment (FFVA)
5. Review specific Food Fraud vulnerabilities in an enterprise risk map
(Enterprise Risk Management)
6. Consider countermeasures and control systems to address the 'very
high' and 'high' vulnerabilities
7. Propose a Food Fraud Prevention Strategy including the calibration
of the Food Fraud risks on the enterprise risk map
 III. Ongoing Management
1. Implement Food Fraud Prevention Strategy
A. Document and refine the process
B. Utilize the Food Fraud Prevention Cycle
A. Assign ‘accountability’ and ‘responsibility’ for key actions
C. At least annual vulnerability assessments (actually
set by your needs and emerging incidents)
D. At least annual review of the best practices and
overall system – this is an emerging field.

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 Food Fraud Compliance
Requirements: Scope
“Food Fraud Compliance Requirements — The general compliance
requirements for Food Fraud prevention are:
1. Conduct a Food Fraud Vulnerability Assessment (Y/N)
2. Written (Y/N)
3. Implement a Food Fraud Prevention Strategy (Y/N)
4. Written (Y/N)
5. Minimally conduct an annual Food Fraud Incident Review (Y/N)
6. Note: Address all types of Food Fraud (Y/N)
7. Note: Address all products from both incoming goods (e.g.,
ingredients) and outgoing goods (e.g., finished goods) through to
the consumer.” (Y/N)
• Reference:
• Food Safety Magazine, Feb 2017, “Food Fraud Vulnerability Assessment and Prefilter for FSMA, GFSI and SOX
Requirements”, http://www.foodsafetymagazine.com/magazine-archive1/februarymarch-2017/food-fraud-vulnerability-
assessment-and-prefilter-for-fsma-gfsi-and-sox-requirements/
• New Food Magazine, Feb 2017: Food Fraud Prevention – how to start and how much is enough?”,
http://www.newfoodmagazine.com/33890/new-food-magazine/past-issues/issue-1-2017/issue-1-2017-digital-version/
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 Takeaways: Focus on…
• Preventing all Food Fraud
– not only adulterant-substances

• All compliance
– not just FSMA-PC, FSMA, FDCA, or Securities Laws

• Reducing recall potential

– do your job… your CFO and Board of Directors care

• Reducing liability
– Corporate, legal, regulatory, and criminal…
for Executives, employees and YOU.
© 2017 Michigan State University 17
 MSU Engagement 2017
Outcome Benefit Commitment
Graduate Share your Plus Graduate Certificate 14 Weeks, online, May to
knowledge and set in Food Fraud August, ~$2200
Course direction of research Prevention

Executive Share your Develop the internal talent
knowledge and set to support initiatives in the
Education direction of research AC space, meet other
thought leaders (“invitation
only” sessions for brand
owners)
2 Days on-campus ($1950)
Feb 7-9 (9-10 FFIS)
July 18-20/20-21 (FFIS)
Sept 26-28/28-29 (FFIS)

Multi- Research the why’s Uncovering the drivers Teleconference Meetings with
of AC/D, understand may lead to new option for on-campus
Client underlying drivers strategies to combat e.g. Veterinary and Animal
Studies Counterfeiting Product Fraud

MOOC Engage global Two, 2-hour on-line Overview: Nov 7&14

network of Food webinar format with Audit Guide: July 6& 13
Fraud thinkers.. assessment. Students Oct 11& 18
earn an MSU “credential”. 2017: Mar, July, Nov
www.FoodFraud.msu.edu
© 2011 Michigan State
© 2017 Michigan State University 18
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Contact: John Spink, SpinkJ@Msu.edu – 517.381.4491 – http://FoodFraud..msu.edu/
 Acknowledgements
• MSU Veterinary Medicine: Dean Christopher Brown, Chair Dan Grooms, Chair Ray Geor, Dr. Wilson Rumbeiha,
Cindy Wilson, Dean John Baker
• MSU Global: Associate Provost/ Executive Director Christine Geith, Jerry Rhead, Gwyn Shelle, Lauren Zavala,
Associate Provost/ EVP Dr. Karen Klomparens, Rashad Muhammad
• Queens’s University Belfast (UK): Professor & Director Christopher Elliott, Dr. Moira Dean, Dr. Michael Hollis
• MSU Online Master’s of Science in Food Safety: Director Melinda Wilkins, Ex-Director Julie Funk, Kristi Denbrock,
Heather Ricks, Peggy Trommater, Heidi Chen, Dr. Gary Ades, Chair Ray Goer
• MSU Food Science: Chair Fred Derksen, Les Bourquin, Bradley Marks, Felicia Wu, VP of Research Ian Gray, David
Ortega, Gale Strasburg
• MSU Program in Public Health: Director Michael Rip and Douglas C Moyer
• MSU NFSTC: Dr. Scott Winterstein, Trent Wakenight,, Dr. Kevin Walker, Sandy Enness, Jen Sysak, Dr. Rick Foster,
to name a few critical contributors and supporters.
• MSU Food Safety Policy Center: Dr. Ewen Todd
• MSU School of Packaging: Dr. Bruce Harte, Dr. Robb Clarke, Dr. Laura Bix, Dr. Paul Singh, Dr. Diana Twede, Dr.
Gary Burgess, Dr. Harold Hughes, Dr. Mark Uebersax, Dennis Young, and Director Joseph Hotchkiss
• MSU Communication Arts/ Consumer Behavior: Dr. Maria Lapinski and Dr. Nora Rifon
• MSU Criminal Justice: Dr. Jeremy Wilson, Director Ed McGarrell, Dr. Justin Heinonen, Roy Fenoff, Zoltan Fejas,
Barbara Sayre, and Sara Heeg
• MSU Supply Chain Management: Dr. Cheryl Speier, Dr. Ken Boyer, Dr. John MacDonald, Chair David Closs, Dr.
Stan Griffis, Dr. Judy Whipple
• MSU College Social Science: Dean Marietta Baba and Assoc Dean Chris Maxwell
• MSU College of Law: Dr. Neil Fortin and Dr. Peter Yu
• MSU Libraries: Anita Ezzo, Nancy Lucas, Kara Gust
• MSU International Programs: Dr. Mary Anne Walker, Dr. John Whimms
• State of Michigan’s Ag & Food Protection Strategy Steering Committee: Dr. John Tilden, Brad Deacon, Gerald
Wojtala, Byron Beerbower
• The Citadel: Dr. Roy Fenoff

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 Discussion
John Spink, PhD

SpinkJ@msu.edu

Twitter: Food Fraud and #FoodFraud

www.FoodFraud.msu.edu

Video on YouTube: Search “Food Fraud” and “New Zealand”

<< to be determined >>

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