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Wednesday, 23 May 2018

Response to Prof. Alan Reilly's Whitepaper on Food Fraud

In his whitepaper, “FOOD FRAUD:UNDERSTANDING THE IMPACT OF FOOD FRAUD IN ASIAProfessor Reilly has provided an excellent discourse from the perspective of mitigating the effects of fraudulent practices in the food industry. The premise and points correctly reflect the general understanding, experience and suggestions for mitigation action, although certain realizations are not reflected. For example, the detection and avoidance of fraudsters and their products largely remains an after-the-fact approach by the industry.

Professor Reilly suggests that: “The onus is now on food companies to develop documented systems for Food Fraud Vulnerability Assessment (FFVA) and to implement measures to mitigate the public health, economic and reputational risks that may result from the food fraud”. Although this suggestion has some preventive overtones, it does not sufficiently address the root-cause (the almost insatiable appetite for economic gain).

The appetite for profit spreads to more institutionalized activities than what is done directly to, or with, food for economic gain. I have often maintained that we should be talking about “industry fraud” instead of the narrow focus on “food fraud”.  I have also mentioned elsewhere that the emerging business of selling partial food fraud mitigation solutions expands the very problem that the purveyors are purporting to address. By their own admission, those who sell partial and ineffective solutions, particularly through the 3rd-party certification route, agree that their solutions do not solve the problem. So, why do they continue to sell them? It requires very little imagination, if at all, to know that a company can complete a documented Food Fraud Vulnerability Assessment (FFVA), implement measures that it sees as sufficient to mitigate food fraud that affects its operation, get certified, then commits fraud. In fact, under current 3rd-party certification arrangement, it is very likely that one company may judge another company as presenting a low risk of committing food fraud if that second company is certified against the same scheme. In other words, the food fraud mitigation solutions that have been suggested under the certification arrangements are not only short in their anticipated effectiveness. They could actually be counter-productive instead of being preventive.

Truly preventive measures should address all root-causes. As such, even the “catch-and-punish” approach taken by the industry needs the necessary intelligence force and instruments that only law enforcement and judicial authorities have. The industry must therefore rely on these authorities and actively work with them.

It is really unfortunate that it comes down to this because of human greed. The industry must actively seek and participate in the necessary collaboration with law enforcement agencies among other parties that have helpful contributions like the academia, private consulting organizations, etc.  This collaboration must be done concurrently with any approach taken by the industry if any effectiveness is to be achieved with the adopted deterrent measures. It is not at all out of place for the industry to also have an enforced obligation to report identified incidents of fraud to the authorities once confirmed.

Also, as we know, elaborate deterrent operations have been undertaken by various law enforcement agencies, including the Interpol. While such operations must continue in attempts to curb the activities of subversive elements, the frequently reports about fraudulent activities in the industry show the insufficiency of all of the deterrent efforts. Something else is needed that is often not fully addressed. While it is important to educate food businesses on methods for catching fraudulent activities, it is equally important to educate would-be fraudsters on what could be done to avoid committing fraud, as well as on the need, advantages and merits of complete business integrity.

I still maintain that a holistic approach to solving the fraud problem is the only thing that warrants the effort. Insular solutions within individual silos, particularly in the forms of vulnerability assessment and mitigation action implemented by individual establishments will not do the job. Such solutions merely lead to finger-pointing and give the appearance of relevance, particularly when what is suggested can be done to gain certification or unwarranted trust with hidden intentions to commit fraud. Keep in mind that often when one finger points outward, three fingers point inward.

Let's be honest. In reality, only one solution exists for food fraud and fraud in general if everyone is committed to it. Anyone selling anything for fraud prevention that does not lead to this solution is either a fraudster or an accomplice.

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Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

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