Food Forum 15 – Dr John Spink – Food Defence – What is it, why is it important, why now?
I don’t know if the interpreters are ready, but I don’t speak New Zealand. I’ll try to do my part, speak slowly. It’s fabulous to be here. There’s so much going on in the world and collaboration is key. These issues are too big for us to try to manage within a company or within a country. So it’s fabulous to be here. It’s my first time in the southern hemisphere and so far it’s been alright as well. My presentation is Food Fraud and so there’s 2 ways to start before I get started – to talk about some of the terminology and I have that — actually I’m going to set my timer because I can go all day if we don’t. The key is if you had to choose between intentional or unintentional, then food fraud is an intentional act. So many times that fits under some of your definitions of food defence. But then the response is really more preventative control. The FDA just put that under the Preventative Controls Act, which is more food safety. You’ve got these kind of conflicting definitions if you have a linear definition of it. And we’ll show you how, when focusing on prevention, it takes a fundamentally different approach, but it doesn’t have to be that big of a deal. That’s a big thing. There’s not going to be a separate agency for this. It’s looking It’s looking at this risk in a continuum of all food risks. So once we look at them together you’re probably doing 99% of everything you need to do to prevent food fraud already, under food quality, food safety or food defense: audits, inspections, regulations, things like that. It’s now looking at it through the bad guys’ eyes. Think like a criminal. So all I do every day my wife would say ALL day, is food fraud prevention. And policy and strategy is where we really focus. We don’t have a testing lab, but we look at trying to set up and understand how programmes should be put in place to prevent. And we’re really trying to get in the mind of the bad guy. Because think of the bad guy as a business competitor. They’re looking at the marketplace and looking for financial opportunities. It’s just the way you look at a market. Do you enter that market or not? They look at the same – with the same type of principles. If we understand that, we can disrupt it. So the biological organism in question is not a microbe. If it was we would naturally go to the field of microbiology. The biological organism in question is a human, so we go to behavioural sciences in criminology, crime science. And I was actually in the School of Criminal Justice for 4 years before moving back to food safety and fully being involved in the food safety approach. So that’s what we do, we have an initiative. We are starting to interact with colleagues here, researchers here in New Zealand and Australia, so you’ll hear more about that later. First off, we don’t just sit in Michigan and think we know everything and want you just to find our research articles. Dissemination of information and teaching is a core of what we do. So first is a massive open online course: free, open, online, near-infinite capacity, 2 two-hour webinars, so it’s not a big commitment. We offer these twice a year. And this is the 7th and 8th one will be the next year. And in November we’ll be bi-lingual and the mandarin speakers will be the CFSA, the China Food Safety Risk Assessment Centre. I’m an advisor for them this year, probably next year as well. I spend 6 weeks a year in Beijing with them. It’s quite an experience. But so we have this bilingual programme, so if you’re looking to learn about food fraud and what’s happening globally, this is a great way to start. Feel free if you get an email or see it, post it anywhere. Again it’s open. The second is executive education, so smaller courses to help train executives or govern– people that need something in a shorter time period. And then graduate courses. All of our graduate programmes are online 100%. These are real Michigan State graduate courses. It’s a real Masters of Science, but they are 100% online. 80% of our students are working professionals. They’re like you, out in the field. We have 4 of these that are related to food fraud in one way or another, protecting the product from harm. And then we have a graduate certificate in food fraud prevention. So if you start to look at — if you’re trying to help someone in your organisation become an expert, or education as Frank said versus training, the education component we put that together in a series of programmes or certificate. If you like that all the credits can roll into an online masters in food safety. It’s a real Masters. I pointed out here is on our website, we have a lot of information. We try to have that be a communication portal. One thing we have is a food fraud reference sheet. So we update that with links and videos and things like that. That’s a resource and where we really have our foundation. One of the things that we’ve been doing and getting more interest is translation into Chinese or our English articles translated into Chinese. And in this case the first article was introducing food fraud and is translated into Korean, Russian and Chinese. And the key with this as well is our co-authors were CFSA. Dr Yongning Wu, chief scientist for that centre, and so when we work with them on this translation, this becomes a reference document in China, because this is coming from a group that looks at these topics. The key is harmonisation of terms. So we’re sharing in other people’s cultures and languages these core concepts. Once we find the core concepts we can move forward on them. We look at translating by local scholars and food safety experts to hopefully it becomes a reference in their country, and we’re continuing to do this for more. We also just finished one of our Food Friday industry reports on preventative controls rule that’s specifically on food fraud for the US. That’s free on our website. And that’s being translated into Chinese as well for reference there. So defining food fraud first. This is a great one single slide. Our website has this PowerPoint so if you go to the website you can pull it, and feel free to use this as the definition or a reference slide for you. If you’re trying to explain it to someone, this is one slide. First off, it’s deception using food for economic gain. Pretty simple. That’s it. They’re using food for this cheating. And then to go down to look separately, the motivation is economic gain. And that’s important when we’re trying to disrupt the bad guy. Traditionally food defence has been harm, more large-scale harm. FDA under the Intentional Adult– they moved EMA out of the Intentional Adulteration rule saying that the IA rule covered catastrophic events. Traditionally that’s a food defence definition. Here’s a real key. Horsemeat did not have a public health threat. If you’re the public health agency, you said, “Not me.” So who is it? And that’s a real key. And the problem we had is people were looking like this. The same with testing as well. The state of Michigan, we have laws that are 20 years old that we’re supposed to be doing species tests. But when you take a food safety risk-based approach, you would stop doing those tests because a food safety risk-based approach is looking at outbreaks. There’s no public heatlh threat. So they logically, scientifically-based stopped doing species tests. We don’t need new laws in the state of Michigan for us. We just need to now prioritise that the risk is different. The key is hazard vs vulnerability. Every time there’s a food fraud incident, there’s an economic hazard. The country, the brand, tax, everybody does have an economic threat from it happening. There’s not always a public health hazard, such as with horsemeat, but there could have been. And if the bad guys on the next load didn’t put the good horsemeat in, or they had a normal thaw/refreeze problem, we would have no way to trace it. We didn’t know it was in there. So there’s always a vulnerability, and that vulnerability is what’s really the important piece and what’s really coming with governments to be a major problem. And then we give some examples,
so I won’t go into those. But this is a great one slide.
Screenshot it, put it into your PowerPoint, leave our logo in the corners. Give us some credit there. What is Food Fraud? This is from the Global Food Safety Initiative. What’s key about this is that this is the type of definition and scope that is being implemented and required of industry. So if you want to sell into GFSI type companies you will be compliant with this. GFSI and the Food Fraud Think Tank – I was on the Food Fraud Think Tank – they created this definition, and it’s now been stated that the next guidance document will require a food fraud vulnerability assessment and a food fraud mediation plan. For companies to be compliant with GFSI – not part of GFSI – GFSI they must do this. So the key is looking at the broad scope of what they cover. And they covered it because it’s not only health hazards, it’s economic hazards. I can tell your country knows more than anybody what some of these hazards can do to an economy. So this is not a [unintelligible], it’s just being aware of it. But it’s all these different type of things that go on around. You wouldn’t think of maybe grey market or diversion as something – that’s genuine product. How do you do food authenticity testing on stolen genuine product? Date code tampering. So a key is that they cover all those – all lead to recalls and problems in your country. We also added in here over-runs and tampering. And up here in this area, this is where FDA in the US still hasn’t redefined economically motivated adulteration. In the federal register they define it as a substance for economic gain. So it’s still in this area up here. And then really all food fraud is covered broadly and this is more common with the UK definition, the EU, GFSI, China with their traditional and non-traditional risks, ISO, and even with the preventative controls rule – we could talk about a day on that – The key is: the FDA says whatever the hazard is we’re holding you accountable for preventing it. Period. So call it what you want. If there’s a hazard, you’re accountable. We’re seeing this generally it’s covered in this broad frame. So to define it we were originally working in food safety and food defence, really on the reaction side. Once something occurs, those were the kind of responses for an incident. But we really saw that preventing food fraud was fundamentally different because, as John said too, the bad guys are actively seeking to avoid detection. They’re studying what we do. They study GFSI and test methods and read every document to try to get around it. So it’s fundamentally different from the motivation. And then food quality’s important to put in there as well because that’s a major cost, and most times these groups report upwards under food quality assurance, food quality, a SVP of food quality. So that’s where the frame is. On one side we’ve got unintentional acts and intentional acts. They know what they’re doing: harm occurs down here for food defence. That’s public health economic or terror. Someone that’s “good” at food defence we’ll know pretty quickly because people will start dying or they’ll tell us. They reveal who did it. With food fraud they’re actively seeking to avoid detection. We don’t know. They’re going to get better and better. Some of the science that’s gone on in food fraud is absolutely mind-boggling. So the goal is economic gain. A real key is that we can deal with that. That’s really crime science 101, is situational crime prevention. Changing the space of crimes. If someone looks at your company or country and says “You know what? Don’t try to deal with their product. We’ll probably get caught.” That’s the key. We can leverage that. And then overall to look at GFSI as well – GFSI has defined this – it’s shown up in EU, UK, and others as three separate types of assessments. Because HACCP – I would never propose we change HACCP to broaden scope. To keep HACCP HACCP: Food Safety. And then TACCP or Food Defence – whether it’s Carver Shock or other things — is a separate assessment. And then food fraud needs to be separate assessment – not a big deal but a separate assessment. Because if we use something like CARVER shock to look at a food fraud event it would be very low on the shock factor. We had the Tylenol incident in the US. That was 8 people died. It was about a billion dollars in loss for Tylenol. That would be a 1-2 or maybe 2-3 on the shock scale out of 10. So it’s a great tool, but it would be an ill-fitting tool for food fraud. And let me tell you, horsemeat you’ve got to deal with, right? Those type of food fraud incidents you must deal with, so it’s just a different type of hierarchy. And so GFSI is putting this under that overall framework and umbrella. A key is that once you have one of these risks that’s defined as “high”, how do you compare a food safety risk in your countermeasures? If it’s high compared to food defence or food fraud? So if you’re on the decision-making side, resource allocation of company, this is where you start to get really uncomfortable, because you’ve got people in your organisation doing these vulnerability assessments telling you that it’s a High. What if you don’t deal with it? These people in the front row are going to give you a call and ask you why. They key is calibrating that across your enterprise. And that can happen, that’s not rocket science. This is business 101. Accounting 101 is enterprise risk management. It’s a central structured programme that they teach in business school, certifications, programmes. It’s a way to calibrate risks across an enterprise. And an enterprise can be a company or country even, of looking at these risks, finite amount of resources. What we did first is – the core is the fraud opportunity. This is crime science, situational crime prevention, fraud opportunity. So you first look at your own fraud opportunity. It’s unique to you, to your country, to you, to your product, to maybe even your specific supply chain. You got the victim on one side. If you’re good at it, your brand is growing, then every day that goes by, you’re a bigger victim. And then you’ve got the fraudster on the bottom. We say fraudster, not criminal, because it might not be a violation of a criminal statute. Those law enforcement officers, and those attorneys, they’re pretty particular. If you call something a crime, and they ask what criminal statute is it a violation of, well it’s not a criminal statute violation – [speaker makes buzzer noise] You could be out. So the key is fraudster. If it’s civil violation, violation of a contract, that’s fraud. So that’s that leg of the triangle. The key is, the side we can work on, is the guardian in the hurdle gaps. The guardians are the forklift driver watching that product come in and saying, “Hey – one of those bags of frozen meat looks different.” To have a way to report that variation. And then the hurdle gaps like hurdle technology and food is putting then tests in place. In this case it would be species tests. Make it harder for the bad guy to operate. The way we reduce crime is increase the risk of getting caught and the cost of conducting the crime. You don’t have to have your system or country be perfect. You just need to increase the risk of getting caught. They are not just dying to knock off your product. They’re patient. And they’re looking to make money. So if you just become a bit of a harder target, then you can reduce that. A key with that there’s 3 components here. Detecting: you must be able to detect it or we don’t know what’s going on. Then deter it. Once you know it’s horsemeat, then you can put tests in place for species of horse. But really the question isn’t just horsemeat. It’s what else? What’s the next horsemeat? The next melamine? That gets to be preventing your system. And that gets to be truly prevention. So there’s a hierarchy here. With prevention if the bad guys don’t know you’re testing for horsemeat or anything all you’re going to do is catch them. Not prevent it. And contrary to popular belief, the goal is not to catch food fraud. The goal is to prevent it. So you want to actually leak out information about what you’re doing. You don’t tell exactly the tests or the frequency or where you’re doing it, but they should know that you have a food fraud strategy, a food fraud centre, a food fraud network. Ireland. They need to know something’s going on. Because first they’ll think, “Ooh I should take a look.” It’s called anticipatory benefit. You say you’re doing something, the bad guys will hold off. But anticipatory benefit [speaker makes downward motion with his hand] goes away. They’ll start looking, and they send stuff through to see if that horsemeat – how much horsemeat gets caught? They might send it to a lab to see how much that lab can find. So we want to look at the prevent in the continuum here. So once you look at the fraud opportunity, the next step, and what’s occurring now, is developing these vulnerability assessments. We need to have a harmonised way to look at this. And that’s our role as academics as well, with the associations to look at how we can present to you a science-based, theoretically sound way to do this new type of assessment, as well as how it fits into the overall system. Once you do the vulnerability assessment, a key is that you need to cover all types of fraud, most likely separately. This is not a big deal. If you try to have one model that covers all types of fraud, we’ll have to bring in the PhDs of mathematics and statistics to figure that one out. Because even theft – cargo theft vs employee theft – each individual risk assessment for those are simple, but you put it together in a big model it’s complex. So there may be a series of these smaller vulnerability assessments that help you look at the big picture. Might sound complex, it’s really not. Start slowly. But that’s the overall vulnerability assessment. And then the thing that we haven’t had in the past, we get the models and get the result, we haven’t had in the past is the crossover into the resource allocation decision. Priority setting across the organisation. This is enterprise risk management. These basic principles can be put into the ERM system. I’ve been in numerous client meetings where they said, “No we don’t have the ERM.” The next meeting they say, “We actually have the ERM” but they didn’t tell us, that there’s some kind of adjusted decision-making process. But truly at the core ERM is used for Sarbanes-Oxley type financial reporting. The financial analysts look at it. It’s done at that level. And that can be done as well the enterprise being a country to judge this risk against all other risks. Basically for us and for in front of Congress. When Congress says, “How big is the problem, and what should we do about this?” We can compare it to the other risks as well. So this is actually – each individual concept is not rocket science. This is criminal justice 101 in the fraud opportunity. Accounting 101 in enterprise risk. Risk 101 or decision sciences 101 with vulnerability assessments. When we look at the countermeasures it’s packaging 101, supply chain 101. They problem is it’s about 10 different disciplines that have to come together. And a key that you’ll see here – once you go from the risk assessment, the red box, and you think about countermeasures that feeds back in to the fraud opportunity. It’s a cycle and a system. So you have a systems-based approach. It constantly recalibrates itself when you have more information. How different is this than Six Sigma to quality management? It’s a system and an approach, it self-corrects. One thing that’s been interesting is to look at how this is happening around the world. And I’ve specifically added these because I know China is a very important customer of yours. China’s been moving forward with their new food safety law, and we’re fortunate that a team from CFSA came over to Food Safety Summit. And on that panel also was Queen’s University Belfast, we have a visiting scholar there, so Katrina Campbell came over. Michelle Lees from Eurofins spoke about GFSI, Susan Brown spoke about US Pharmacopeia, that work there, and then Eve Ray is Dannon and a number of other items. A group came together to talk about food fraud, specifically what’s going on in China with their laws. And the key to the slide at the right is pointing out that China’s using this basic infrastructure or hierarchy that looks at all types of fraud. Specifically – so they’re talking, this is China’s words on the slide – food fraud incident type. But then they’re focusing on high public health threats first, and that’s adulteration, adulterated substances, and counterfeiting. So that what’s going on, and so I’ve been over a couple times with them. Also something I found very interesting, and this I added because I think it adds emphasis. Again, as your one of your biggest export customers and what’s happening around the world, is how China is looking at and taking food fraud prevention, not just detection, very very seriously. So Junshi Chen – Dr Chen – was presenting at the Institute of Food Technologists, and I was very excited to hear him talk about the new food safety laws. I was actually kind of shocked – and I’m a food fraud researcher – but shocked that the title of his slide had Fight Against Food Fraud. That’s a pretty big deal. He’s talking about China’s food safety law, the new entire law, and he’s emphasizing food fraud. So it’s important. They have a number of issues with that, but food fraud is front and centre. Also they have a food risk matrix there, and funny those colours look familiar. They are properly referenced. But the key is that first article – remember the first article introducing food fraud with the co-authors? Dr Wu from CFSA is a co-author. So this is months after that article came out. These are common concepts that they’re already integrating into their terminology, their nomenclature, their system. They’re explaining where food safety fits into this overall food risk matrix because it’s a common concept that they do understand. Also they do point out is that a lot is the social aspect of it. A very big concern for them. And this was Dr Wu that was at the Food Safety Summit, and again similar slide. A key there is he points out how the different food fraud – or food safety related laws and amendments fit under that one hierarchy. I think this is a sound way to look – I say country-wise as well – food risk matrix – that you’re responsible for all food risks – and this is a way to look at each of those types of structures. Look at what laws are covered in there. A key for you as a country and a company, every food risk really needs to fit in clearly into one box, because if it doesn’t – if you just say “Not me! Not me!” then it’s in a gap. And so the person that’s accountable for food fraud might not be responsible for implementing every programme. But they’re accountable for making sure anti-diversion and things like that are covered. And then he covered that same definition. So I’d like to say also we consider that a lot of people have been really helpful along the way. Hopefully we won’t add more of you. One thing is it that I consider myself the food fraud librarian. I gather the information, and you’re the books in the library. I’ve learned a lot these last couple days, so help us gather that information. If you have challenges or questions or evolution of concepts, communicate with us. We want to write about it, we want to think about it. And only if you really do tell us “This point I like,””This point I didn’t understand”or “We’re really not doing it that way anymore.” We need to know that so that we can work it back into the literature, publish on it, and then it’s a science-based resource. So please engage with us, and as we grow our New Zealand and Australia footprint, please do that as well. I’ve got 15 seconds. SO. In all seriousness. Thank you, it’s been interesting. Hopefully, if you were on a ledge and worried about this, it’s definitely something to pay attention to, but there’s a lot of work going on in the strategy and policy [beeping noise]. There we go. Step forward, and I will say thank you. [applause]