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Preventing Food Fraud A webinar presented by: Dr Andy Bowles Attendee Notes
Preventing Food Fraud
A webinar presented by:
Dr Andy Bowles
Attendee Notes
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Preventing Food Fraud
Dr Andy Bowles
Introduction
Four webinars Introduction to food fraud Preventing food fraud Detecting food fraud Investigating food fraud
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This webinar will consider
Introduction
PAS 96
TACCP
Official controls
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Preventing Food Fraud
Introduction
PAS 96
TACCP
Official controls
Examples of food fraudKnowledge Centre for Food Fraud and Quality
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Why does food fraud happen
Key factors Economic Vulnerability Opportunity Criminality
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Preventing food fraud
Business PAS 96 Guidance to improve the resilience of supply chains to
fraud or other forms of attack.
Competent authorities Official controls
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Preventing food fraud
Preventative measures: Should focus on: Identifying vulnerabilities in supply chain Denying opportunities for fraud
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Vulnerabilities For a given product may include:
Factors inherent to the ingredient Market value History of fraud Composition Tax/duty status
Business pressure factors Demand for an ingredient Widespread use Price volatility
Factors under control of business Traceability Specification Purchase contracts
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Examples of vulnerable products
Food Integrity Handbook
Available https://secure.fera.defra.go
v.uk/foodintegrity/secure/downloadFile.cfm?id=659
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Opportunities
Opaque/complex supply chains
Informal purchase arrangements
Inadequate supervision of staff
Inadequate ingredient checks
Poor stock/waste management
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Examples of mitigation
Transparency in supply chains Formalise purchase arrangements Specifications Contracts Approved/accredited suppliers
Replace vulnerable ingredients Internal mass balance audits
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Preventing food fraud
Introduction
PAS 96
TACCP
Official controls
Preventative measures: Business
PAS 96:2017 “Guide to protecting
and defending foodand drink fromdeliberate attack” Non-statutory guidance
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PAS 96
Purpose Improve the resilience of supply chains to fraud or
other forms of attack. Aims to assure authenticity and safety of food by minimizing the chance of an attack and mitigating the consequences of a successful attack.
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Introduction
PAS 96 TACCP Threat Assessment Critical Control Points (TACCP) Systematic management of risk evaluation of threats, identification of vulnerabilities, and implementation of controls
materials/products, purchasing, processes,premises, people, distribution networks andbusiness systems
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PAS 96 Definitions
Food defence “procedures adopted to assure the security of
food and drink and their supply chains frommalicious and ideologically motivated attackleading to contamination or supply disruption”.
Food protection “procedures adopted to deter and detect
fraudulent attacks on food”
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PAS 96 Threats Threat “Something that can cause loss or harm which
arises from the ill-intent of people”. Types of threat Economically motivated adulteration (EMA) Malicious contamination Extortion Espionage Counterfeiting
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PAS 96 Understanding the attacker
Does the attacker have: Motivation Capability Opportunity
Is there an adequate deterrent? Likelihood of detection Severity of penalty
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PAS 96 Understanding the threat
Types of attacker Extortionist Opportunist Extremist Irrational individual Disgruntled individual Cyber criminals and other malicious digital actors Professional criminal
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Preventing food fraud
Introduction
PAS 96
TACCP
Official controls
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Introduction
PAS 96 TACCP Threat Assessment Critical Control Points (TACCP) Considers all significant threats (not just fraud) to: Organisation Systems Products
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TACCP – First Steps
TACCPTeam
Evaluateinformation
Identifythreats to
organisation
Identifythreats tooperation
Identifythreats toproducts
TACCP: Threat to productProcess flow
diagram
Identifyvulnerable
points
Identify threatsand mitigationat each step
Identify pointswhere threat most
damaging/detectionmost likely
Assess likelihood ofthreat detection byroutine procedures
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TACCP: Priority actionScore likelihood,
impact todetermine
priority
Identify highpriority areas
Identify andimplement
preventativeaction
Review
Continue toassess new
threats
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Threat evaluation threats are prioritised in terms of:
Severity (Effect) Likely occurrence (Probability)
Anti –fraud “pre-requisites”
The success of TACCP will depend on: Culture Training/Education Whistle blowing Effective management
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Preventing food fraud
Introduction
PAS 96
TACCP
Official controls
Role of local authorities
Primary responsibility lies with food industry
Article 9 (2) Regulation 2017/625 “Competent authorities shall perform official
controls regularly, with appropriate frequenciesdetermined on a risk basis, to identify possibleintentional violations of the rules … perpetratedthrough fraudulent or deceptive practices…”
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Preventing food fraud
Two key issues: Vulnerability Opportunity
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Suggested matters to consider
Routine inspection/communication Raise awareness Food fraud generally Current topics EU Food fraud newsletter
Encourage TACCP Food fraud prevention management system
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Suggested matters to consider
Discuss Developing appropriate culture Training/education of staff Alert and reporting procedures
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Supply chain
Has business Considered supply chain? Especially for high risk products
Taken steps to: Fully understand supply chain Simplify supply chain Formalise supply chain
Are supply chain contingency plans in place?
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Vulnerability assessment
Review vulnerabilities Factors inherent to the ingredient
Market value History of fraud Composition
Business pressure factors Demand for an ingredient Widespread use Price volatility
Factors under control of business Traceability Specification Purchase contracts Management/working arrangements
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Mitigation measures Specifications Relationship with suppliers Selection Contractual Audit
Management controls Purchasing Goods in/out
Sampling
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Prevention of food fraud
Official control sampling Targeted Publicised sampling programmes
Reporting
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Summary
Introduction
PAS 96
TACCP
Official controls
Dr Andy Bowles
www.abcfoodlaw.co.uk@abcfoodlaw
01603 319863
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