By Samantha Cooper

Food fraud has been affecting the food industry for thousands of years. Olive oil, tea, wine, and spices were early victims of fraudsters who attempted to defraud customers for economic gain without getting caught. Many of the tactics used thousands of years ago to achieve fraud, such as substitution, dilution, or misrepresentation, are still used today.

However, an expanding wealth of knowledge and awareness, along with advancements in technology, have provided manufacturers with a better understanding of food fraud and solutions to move toward a goal of food fraud reduction. Following is a brief Q&A and references for additional resources that will help you to increase your knowledge of food fraud.

1. What is food fraud?

As defined by John Spink and Douglas Moyer in Backgrounder: Defining the Public Health Threat of Food Fraud, “Food fraud is a collective term used to encompass the deliberate and intentional substitution, addition, tampering, or misrepresentation of food, food ingredients, or food packaging; or false or misleading statements made about a product, for economic gain.”

The goal of those committing the fraudulent act is to get away with the crime and earn a financial gain. Unfortunately, many of the food fraud incidents are not detected because the majority of the incidents do not create a food safety hazard, and consumers typically do not notice a quality problem.

2. What is economically motivated adulteration (EMA)?

EMA is a category within the larger definition of food fraud. In an April 2009 public meeting, FDA adopted a working definition for EMA as: the “fraudulent, intentional substitution or addition of a substance in a product for the purpose of increasing the apparent value of the product or reducing the cost of its production, i.e., for economic gain. EMA includes dilution of products with increased quantities of an already present substance to the extent that such dilution poses a known or possible health risk to consumers, as well as the addition or substitution of substances in order to mask dilution.”

3. Why aren’t more food fraudsters caught?

It’s difficult to catch those responsible for food fraud because their business thrives on avoiding detection. However, the number of documented incidents is increasing and being captured in several databases, such as the United States Pharmacopeia Convention (USP) Food Fraud Database and the Food Protection and Defense Institute (FPDI) EMA and Intentional Adulteration Incidents Database.

4. Is EMA addressed in any of FSMA’s final rules?

EMA is addressed in both of the Preventive Controls rules – for human food and for animal food. The regulations require consideration of hazards in ingredients that have a past pattern of economically motivated adulteration, but it is limited to include only those agents that can cause illness or injury. Thus, while EMA incidents only affecting product integrity or quality are of concern to food facilities, these should not be addressed in a facility’s FSMA-required Food Safety Plan.

5. What resources are available for companies to fight food fraud?

The SSAFE Food Fraud Vulnerability Assessment tool is another resource which can help food businesses of any size or geographic location identify how they may be vulnerable to fraudulent activity. With SSAFE, the company can prepare mitigation plans and determine vulnerability of an ingredient, product, or entire company.

In addition to such online resources, companies can stay ahead of the growing knowledge on food fraud by attending conferences and seminars. One such conference is the GMA Science Forum, April 18-21, 2017, in Washington, D.C., (www.GMAscienceforum.com) which will include a session addressing EMA and how companies can take multiple approaches to tackling food fraud.

SUMMARY. Increases in knowledge and awareness, and advancements in technology, are providing manufacturers with a better understanding of food fraud and solutions to move toward a goal of food fraud reduction. There are many resources companies can use to help build their knowledge and awareness on food fraud, and teams are continuing to develop tools to help companies assess their food fraud vulnerability. The industry may not be able to pinpoint the fraudsters just yet, but with the advancements in technology, traceability, and knowledge, we’re getting closer.

The author is GMA Food Safety and Quality Assurance Manager.

The food safety risk to global brands has never been higher, which means one pillar in the mission of AIB International will never change: We will continue to help our clients build solid food safety programs for their entire supply chain. At the end of the day, it’s all about protecting food brands and the trust companies have with their customers.

In 2017, AIB plans to capitalize on our momentum from last year and help the industry with the ever-changing regulatory climate by renovating and expanding our service portfolio. That ranges from advancing food safety fundamentals to complying with complicated regulations like FSMA.

FOOD SAFETY FUNDAMENTALS. On the fundamentals, we recently updated our Consolidated Standards for Inspection. Since these are global standards, we plan to reach as many clients as possible early in the year to educate them on the changes and how their food safety programs will be impacted.

We also have renovated our Food Defense Coordinator course and launched a course on FDA Preparedness Inspection. In the near future we will have new offerings to address the sanitary transport requirements and an online HARPC course that will address qualified individual training requirements at the supervisory level.

The kill step validation research, conducted in partnership with the American Bakers Association, Kansas State University, and the University of Georgia, has generated six calculators for the baking industry. Three more are planned to be launched in 2017.

These tools enable bakeries to address the FSMA requirement to validate that the commercial baking process does indeed kill pathogens. We also continue to assist bakeries with their onsite needs, a trend we anticipate will carry through 2017.

NEW PARTNERSHIPS. In 2016, we established partnerships in Mexico, China, and Europe where we can leverage good lab facilities to provide local hands-on training. In the U.S., we will continue to leverage our upgraded Manhattan, Kan., facilities for client-based R&D and quality assurance projects.

We are also positioned to help the food and beverage industry comply with the new FDA labeling regulations. This not only includes generating labels under the new protocol, but also educating exporters to the U.S. and training labeling specialists who need a higher level of technical capability.

In 2017, our commercial team is focusing on strategic multinational clients across the U.S., Latin America, and Europe. It is imperative for us to listen carefully to them.

The challenges are different in different parts of the world. FSMA is a great example. It has been and will continue to be front and center for many companies operating in and exporting to the U.S. In many developing markets the needs are around the basics — GMPs, HACCP, integrated pest management, and hygiene practices.

The food safety service industry is highly competitive. We have to reach the influencers and decision makers through multiple media vehicles. Otherwise, “if we are out of sight we are out of mind.”

We have a lot of momentum to make 2017 a break-out year for AIB International.

Andre Biane is AIB President & CEO.

By Earl Arnold

There are many decisions to be made before you begin developing a food defense plan for your facility:

• What are you trying to protect?
• What type of threats do you face?
• How do you build a strong food defense team?
• What type of training is needed?
• Where do you start?

As you build a strong food defense team, you’ll be able to answer these questions and more.

But, before you can begin to build a strong team you will need to determine what you will protect at your facility. Things to consider in this decision include the type of food defense plan you will build. If your facility is required to register with FDA and you manufacture, process, pack, or hold food that will be consumed in the United States, you might be required to comply with 21 Code of Federal Regulation 121 Mitigation Strategies To Protect Food Against Intentional Adulteration.

This regulation is the first of its kind. It was created by FDA as part of the Food Safety Modernization Act (FSMA). There are compliance exemptions to this regulation, so be sure you understand whether or not the requirements apply to your operation.

This new regulation requires you to have a qualified individual that is trained in how to conduct a vulnerability assessment, which is similar to the type of assessment conducted for HACCP. You are required to assess biological, chemical, physical, and radiological contaminants for each ingredient or raw material and processing step.

You also must consider and evaluate three elements when conducting your assessment:

1. The potential public health impact (e.g., severity and scale) if a contaminant were added.
2. The degree of physical access to the product.
3. The ability of an attacker to successfully contaminate the product.

Finally, if you are conducting a vulnerability assessment according to this new regulation you need to consider if intentional adulteration could be carried out by someone welcomed into the facility. If you are required to comply with the FSMA regulation for food defense, there are several more requirements you must follow, but this article’s focus is on building a strong food defense team.

SETTING THE PLAN. The new regulation does not require you to include programs that cover workplace violence, asset protection, or brand protection. However, you can include these important items in this food defense plan or in other SOPs or policies. Again, you must decide what is important to protect your facility and include in your plan.

If your facility is not required to comply with the FDA regulation you still might be required to have some type of program in place. If you follow a Global Food Safety Initiative (GFSI) certification audit, you are required to have some type of food defense plan. If your facility is located in a country outside the U.S., you might be required to follow a regulatory rule from that country. Or you may want to establish a voluntary program to protect your facility and assets from intentional harm.

Once you’ve identified what you’re trying to protect, you need to identify the potential threats and aggressors that you need to be concerned about. There are many different ways to accomplish this. The best recommendation is to invite local law enforcement into your facility for a tour. They will become familiar with your facility in case they need to assist in a future emergency situation, and will be able to make informed decisions because they know your facility layout. While they tour, ask them about potential threats in the area, like break-ins, vandalism, protesters, and other acts of violence.

Another resource you can use to assess potential threats is the internet. There are great websites that provide information such as crime statistics in an area, the types of crimes committed, and how close these types of activities were to your facility.

A few of these websites are: city-data.com, crimereports.com, and Neighborhoodscout.com. Other websites that can help build a great food defense plan and offer information about intentional adulteration and other threats include: foodshield.org, fda.gov/food/fooddefense, and http://foodfraud.msu.edu/2014/05/08/gfsi-direction-on-food-fraud-and-vulnerability-assessment-vaccp. These online resources can help you determine potential threats and aggressors.

SELECTING THE TEAM. The next thing to determine is who to select as food defense team members. This is probably one of the most important decisions you will make in regards to your food defense program. You want the team to be multi-disciplined and have personnel representing different departments, because the team will review SOPs and policies to ensure they are sound in preventing intentional adulteration and protecting employees, assets, and your brand. For example:

• Does your visitor policy ensure all visitors understand your basic food defense program?
• Does it allow visitors to go alone throughout the facility?
• Do visitors understand the importance of signing in and out of the facility?

This is just one policy or procedure that needs to be reviewed. How many others are in your facility? Can you do this alone or is a team approach better?

The team also will complete the vulnerability assessment. Again, having a fully functioning, multi-disciplined team is beneficial. The qualified individual or food defense coordinator is required to conduct or oversee the development of the vulnerability assessment. Depending on your current role in the facility, you will be able to fully examine facility operations when conducting the vulnerability assessment.

However, if you are the quality manager, you might not understand the true vulnerabilities associated with maintenance issues or procedures that could allow intentional adulteration to occur or if some type of vulnerability exists. So having a team comprised of different departments of the facility ensures that your assessment looks at all areas and procedures inside the facility.

TRAINING IS KEY. Once the vulnerability assessment is complete and controls or mitigation strategies to reduce or prevent the vulnerability are established, employees need to be trained. All employees, visitors, and contractors should know the basics of the food defense program.

BUILDING THE TEAM. Now let’s take a closer look at potential team members, important traits they can offer, and benefits of including them. It’s important to understand these are just potential team members, not an all-inclusive team makeup.

• Team Leader. The first member to select is the team leader. This individual will be ultimately responsible for managing your food defense plan. If you are required to comply with regulatory requirements this person may require special training. Even if you are not required to comply with regulatory requirements, it’s still a best practice to get additional training for this individual as he or she will lead this program. This individual should have management or leadership skills as he/she will be giving tasks and managing the entire process and team. Additionally, other responsibilities should be limited so they do not take away from the time spent on this program.
• Facility Manager. The next team member to consider including is the facility manager. This individual is beneficial because he or she will show all employees the importance of this program by being involved on the team. He/she can provide the financial and operational support required to implement control measures, such as adding or changing equipment to reduce identified vulnerabilities, or adding tasks to processes or procedures to reduce identified vulnerabilities. If the facility manager is not on board with recommendations, procedure changes or funds might not be available.
• Human Resources Manager. Another good addition to the team is the human resources manager. Usually, this department already conducts one of the most important functions related to the food defense program, which is employee background checks. It also acts as the primary enforcer for all company policy and procedure issues, as well as disciplinary actions. So the manager of this department can assist in identifying potential disgruntled employees, or notify the team of potential issues. This individual would be very beneficial in reviewing policies and training new employees in food defense procedures.
• Production Manager. The production manager is another individual to consider adding to the team to communicate the importance of the food defense program to employees. This person will be beneficial in conducting the vulnerability assessment to identify vulnerabilities and establish reasonable controls, and will help ensure the food defense plan is followed by all employees and educate team members in the production process.
• Quality Manager. The quality manager is another individual to consider adding to the team since this person is usually required to conduct or monitor all tests conducted on ingredients and finished products and monitor or conduct tests on equipment and the environment. Additionally, this manager monitors and conducts investigations on all customer complaints. Having a quality manager on the team will assist in ensuring all test results and customer complaints that reflect potential intentional adulteration activities are communicated and explored by the food defense team. And the relationships already established with outside laboratories, that might be needed if testing is required to rule out intentional contamination, will be of benefit.
• Maintenance Manager. The maintenance manager is another individual to add to the team. No one knows the equipment and maintenance requirements better than the maintenance group. They can assist in identifying potential vulnerabilities with equipment that might be otherwise overlooked. Additionally, They usually are responsible for managing contractors that are required to work inside the facility and can assist in reviewing policies and developing controls for identified vulnerabilities with contractors.
• IT Manager. The IT manager is another person to consider adding to the team. In today’s manufacturing environment, computer programs are key to running an efficient system: automation software for ejecting potential finished product that contains metal; servers that house all production documents to manage traceability of ingredients and packaging; and websites, emails, and databases that hold vital information on the manufacturing process or customer communications. Protecting these programs and equipment is as important as preventing intentional adulteration. The IT manager is key in identifying potential vulnerabilities related to these systems and programs.
• Senior Frontline Employee. A trusted senior frontline employee should be considered as a member of the team. He/she can identify employee habits that could lead to potential vulnerabilities. For example, all employees on third shift turn off the alarm for the back door to make it easier to go to the smoking area even though the policy says all doors must remain locked and alarmed at all times. It might even be beneficial to have members of the union on the team, if your facility has one, to assist in training individuals about why certain measures are required.
• Legal Advisor. A legal advisor is also another person to consider adding to the team. This individual can let you know if the process or procedural changes can be made and will not result in breaking the law. For example, maybe you and your food defense team are considering requiring all bags being brought into the facility to be searched. Is it legal? Can you do it? The legal advisor would be able to find out and let you know.
• Security Manager. The security manager is a great additional team member to consider. Since this person is responsible for managing security at the facility, he/she can assist in reviewing policies and procedures related to parking, entrances, and weapons policies. Additionally, security can inform the team in trending information of security violations and other issues.

As I mentioned earlier, these individuals do not make up an all-inclusive list. They are just recommendations on who you might want to include on the food defense team and some of the benefits each individual can bring to the team.

The key thing is to choose the right individuals for the right program based on what you are protecting and what type of threats exist. Additionally, consider the type of vulnerability assessment.

• Are you required to comply with regulations?
• Do you comply with a Global Food Safety Initiative audit?
• What are those requirements?

Knowing these things in advance will help you comprise a strong food defense team.

TRAINING. The last thing to address when forming the team is training. What type of training is required to be a team member? This will depend on a few factors. Questions to consider include: What type of program are you building? Are you required to comply with regulatory rules? GFSI initiatives? Best practices?

Each of these types of programs will require different training. For example, if you are required to comply with the FDA regulation 21 CFR 121 Mitigation Strategies to Protect Food Against Intentional Adulteration, the training requirements are quite clear: You are required to have a qualified individual responsible for developing or overseeing the vulnerability assessment. And any individual who has a responsibility for the food defense plan must be qualified to fulfill that role. Meaning that team members need to be trained.

Those responsible for monitoring a control must be trained to do so. Those required to verify control measures must be trained on how to verify. This same concept should be used for GFSI, or best practice food defense programs.

SUMMARY. To build a strong food defense team you need to make a few decisions. What do you need to protect? What type of threats does your facility face? Answering these questions will allow you to determine who to include on the food defense team. You can then select your food defense team by choosing individuals you trust and who can provide additional tools and resources to benefit the program. Then you need to identify the correct education and training for all team members to make it as strong as possible.

The author is Earl Arnold, Global Manager, QA Food Defense and FSMA, AIB International.

Are we guilty of seeing, hearing and speaking no evil in our daily lives as quality and food safety leaders?

Instead of wearing blinders, earplugs, and muzzles (figuratively or literally), we need to be doing everything we can to build our relationships with company executives as well as line workers — seeing, hearing, and speaking.

SEE NO EVIL? Do we wear blinders? We must be constantly diligent and have our eyes wide open in the production environment as well as in the board room. In operations areas, we cannot let our eyes be averted from the potential evil that could be lurking in every action and in every piece of equipment.

• We must not let ourselves get complacent with substandard equipment, actions or processes.
• We must see this evil and work to correct it every time.
• We must look in different places each time we walk the floor.
• We must ask different questions each time we talk.
• We must speak with different people — and listen to their responses.

Although daily changes may keep our minds open to new evils, they can prevent us from seeing the everyday evils. Same goes for the board room. We must not let fellow leaders become complacent about their tasks.

Our job is to be the conscience of the company and assure that all the right things are being done, and that they are being done in a timely manner, to protect the company image, the employees, and the consumers.

Seeing no evil in this case will undermine the good work that is done every day by every member of operations as well as by executives.

We cannot filter the message or minimize the bad to accentuate the good. The evil must be heard and it must be responded to. Don’t fall into the trap of hearing only what you want to hear.

SPEAK NO EVIL? Do we lead by example? If we are to be leaders, we must mentor our teams toward “doing the right thing, the right way, every time.” It is important to ensure staff and fellow leaders understand the importance of doing a task in the prescribed manner.

To do this, we must sometimes speak evil. But, any time that we present what can be considered to be bad news to anyone, we also must learn to do it in a manner that is constructive.

The recipient may be an employee who needs assurance that the correct way is the only way that can be allowed. Or it may be management who has taken a shortcut leading employees to believe that shortcuts are acceptable.

In either case, it is wise to remember that a few words of praise are a great motivator. Using praise along with the corrective action will help everyone remember that correction is needed and the result valued.

SEE, HEAR, SPEAK. Let’s be leaders in this new year and be aware of the evils that can corrupt our workplaces. Use them to improve the operation, the company image, our employees, our processes, and our management.

Bruce Ferree is Senior QA Manager, HP Hood.