Food Fraud Trends

a different intentional incident Food Defense Strategy Exchange (FDSE)

Session Global Food Supply Chains Chicago ndash May 20 2015 ndash 400 to 450pm CT

John Spink PhD

Director amp Assistant Professor Food Fraud Initiative Visiting Scholar Queenrsquos University Belfast (UK)

Foreign Subject Matter Expert Chinese National Center for Food Safety Risk Assessment Member Food Fraud Think Tank for GFSI

Member GMA Economic Adulteration Work Group Member USP Food Ingredient Intentional Adulteration Expert Panel

Chair US Delegation ISO TC 247 Product Fraud Countermeasures and Controls

wwwFoodFraudMSUedu -- Twitter FoodFraud and FoodFraud

Acknowledgements bull MSU Veterinary Medicine Dean Christopher Brown Chair Dan Grooms Chair Ray Geor Dr Wilson Rumbeiha

Cindy Wilson Dean John Baker

bull MSU Global Associate Provost Executive Director Christine Geith Jerry Rhead Gwyn Shelle Lauren Zavala Associate Provost EVP Dr Karen Klomparens Rashad Muhammad

bull Queensrsquos University Belfast (UK) Professor amp Director Christopher Elliott Dr Moira Dean Dr Michael Hollis

bull MSU Online Masterrsquos 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

bull MSU Food Science Chair Fred Derksen Les Bourquin Bradley Marks Felicia Wu VP of Research Ian Gray David Ortega Gale Strasburg

bull MSU Program in Public Health Director Michael Rip and Douglas C Moyer

bull 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

bull MSU Food Safety Policy Center Dr Ewen Todd

bull 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

bull MSU Communication Arts Consumer Behavior Dr Maria Lapinski and Dr Nora Rifon

bull MSU Criminal Justice Dr Jeremy Wilson Director Ed McGarrell Dr Justin Heinonen Roy Fenoff Zoltan Fejas Barbara Sayre and Sara Heeg

bull MSU Supply Chain Management Dr Cheryl Speier Dr Ken Boyer Dr John MacDonald Chair David Closs Dr Stan Griffis Dr Judy Whipple

bull MSU College Social Science Dean Marietta Baba and Assoc Dean Chris Maxwell

bull MSU College of Law Dr Neil Fortin and Dr Peter Yu

bull MSU Libraries Anita Ezzo Nancy Lucas Kara Gust

bull MSU International Programs Dr Mary Anne Walker Dr John Whimms

bull State of Michiganrsquos Ag amp Food Protection Strategy Steering Committee Dr John Tilden Brad Deacon Gerald Wojtala Byron Beerbower

copy 2015 Michigan State University 2

3

Massive Open Online Course (MOOC ndash free open online) bull May 19 amp 26 November 2 amp 6 Bi-Lingual English-Mandarin

bull Free open online open to everyone includes a lsquocertificate of completionrsquo

wwwFoodFraudmsuedu

Executive Education (Short-Course)

bull Food Fraud Quantifying Food Risk with Vulnerably Assessments

bull June 15-16 17-18 September 21-22 23-24

Graduate Courses (Online Three Credits)

bull Anti-Counterfeit amp Product Protection (Food Fraud)

bull Quantifying Food Risk (including Food Fraud)

bull Global Food Safety (including Food Fraud)

bull Food Protection and Defense (Packaging Module)

bull Packaging for Food Safety

Graduate Certificate (Online Four Courses Each)

bull Certificate in Food Fraud Prevention (Food Safety)

Master of Science in Food Safety (Online)

bull wwwonlineFoodSafetymsuedu

Food Fraud Curriculum

(c) 2015 Michigan State University

3

Massive Open Online Course (MOOC ndash free open online) bull May 19 amp 26 November 2 amp 6 Bi-Lingual English-Mandarin

bull Free open online open to everyone includes a lsquocertificate of completionrsquo

wwwFoodFraudmsuedu

Executive Education (Short-Course)

bull Food Fraud Quantifying Food Risk with Vulnerably Assessments

bull June 15-16 17-18 September 21-22 23-24

Graduate Courses (Online Three Credits)

bull Anti-Counterfeit amp Product Protection (Food Fraud)

bull Quantifying Food Risk (including Food Fraud)

bull Global Food Safety (including Food Fraud)

bull Food Protection and Defense (Packaging Module)

bull Packaging for Food Safety

Graduate Certificate (Online Four Courses Each)

bull Certificate in Food Fraud Prevention (Food Safety)

Master of Science in Food Safety (Online)

bull wwwonlineFoodSafetymsuedu

Food Fraud Curriculum

(c) 2015 Michigan State University

Training Resources

Food Fraud Table Top Exercise

copy 2015 Michigan State University 4

copy 2015 Michigan State University

5

Spink J et al Introducing Food Fraud including

translation and interpretation to Russian Korean and

Chinese languages Food Chemistry 0 (0) pp 00-0

bull Translation by local

scholars and food safety

experts

bull Reference in their

language (country)

bull Future translations

httpwwwsciencedirectcomproxy1clmsuedusciencea

rticlepiiS0308814614014824

FoodFraudmsuedu

Defining Food Fraud bull Action Deception Using Food for Economic Gain

ndash Including the sub-category of ldquoEconomically Motivated Adulterationrdquo or EMA

ndash Note FDA currently defines EMA as a ldquosubstancerdquo for ldquoeconomic gainrdquo

bull Motivation Economic Gain ndash ldquoFood Defenserdquo motivation is traditionally harm or terror

bull Effect ndash Economic Threat

ndash Public Health Vulnerability or Threat

bull Examples ndash Horsemeat in ground beef

ndash Peanut Corporation selling known contaminated product

ndash Diluted or extra virgin olive oil

ndash Melamine in pet food and infant formula

ndash Over-icing with unsanitary water

ndash Unauthorized unsanitary repackaging (up-labeling or origin-laundering)

ndash Cargo Theft reintroduced into commerce Stolen products

ndash Expired product date code tampering or ldquorefreshingrdquo bull Reference Spink amp Moyer (2011) Defining the Public Health Threat of Food Fraud Journal of Food Science

copy 2015 Michigan State University 6

The Chemistry of the Crime

The Vulnerability Assessment Foundation

Detect

Deter

Prevent

copy 2014 Michigan State University

Food Fraud

Vulnerability

Assessment

Adulterants

Tampering

Theft

Over-runs

Diversion

Counterfeits

Food Fraud

Vulnerability

Assessment

Model

7

Enterprise Risk Priority

The Food Risk Matrix

Action

Intentional Unintentional

Harm

Public Health Economic or

Terror

Food Defense

Food Safety

Motivation

Gain Economic

Food Fraud(1)

Food Quality

Prevent by Understanding the Motivation

Source Adapted from Spink (2006) The Counterfeit Food and Beverage Threat Association of Food and Drug Officials (AFDO) Annual Meeting 2006 Spink J amp Moyer DC (2011) Defining the Public Health Threat of Food Fraud Journal of Food Science November 2011

Fo

od

Se

cu

rity

copy 2015 Michigan State University 8

copy 2015 Michigan State University 9

bull GFSI Guidance Document

ndash BRC Issue 7

copy 2015 Michigan State University

10

Standards Certifications and

Audits

FoodFraudmsuedu

`SEC 418 HAZARD ANALYSIS AND RISK-

BASED PREVENTIVE CONTROLS bull `(a) In General- The owner operator or agent in charge of a facility shall inhellip

bull accordance with this section evaluate the hazards that could affect food manufactured processed packed or held by such facility identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated under section 402 or misbranded under section 403(w) monitor the performance of those controls and maintain records of this monitoring as a matter of routine practice

bull `(b) Hazard Analysis- The owner operator or agent in charge of a facility shall--

bull `(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility including--

bull `(A) biological chemical physical and radiological hazards natural toxins pesticides drug residues decomposition parasites allergens and unapproved food and color additives and

bull `(B) hazards that occur naturally or may be unintentionally introduced and

bull `(2) identify and evaluate hazards that may be intentionally introduced including by acts of terrorism and

bull `(3) develop a written analysis of the hazards

copy 2015 Michigan State University

11 11 FoodFraudmsuedu

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

copy 2015 Michigan State University

5

Spink J et al Introducing Food Fraud including

translation and interpretation to Russian Korean and

Chinese languages Food Chemistry 0 (0) pp 00-0

bull Translation by local

scholars and food safety

experts

bull Reference in their

language (country)

bull Future translations

httpwwwsciencedirectcomproxy1clmsuedusciencea

rticlepiiS0308814614014824

FoodFraudmsuedu

Defining Food Fraud bull Action Deception Using Food for Economic Gain

ndash Including the sub-category of ldquoEconomically Motivated Adulterationrdquo or EMA

ndash Note FDA currently defines EMA as a ldquosubstancerdquo for ldquoeconomic gainrdquo

bull Motivation Economic Gain ndash ldquoFood Defenserdquo motivation is traditionally harm or terror

bull Effect ndash Economic Threat

ndash Public Health Vulnerability or Threat

bull Examples ndash Horsemeat in ground beef

ndash Peanut Corporation selling known contaminated product

ndash Diluted or extra virgin olive oil

ndash Melamine in pet food and infant formula

ndash Over-icing with unsanitary water

ndash Unauthorized unsanitary repackaging (up-labeling or origin-laundering)

ndash Cargo Theft reintroduced into commerce Stolen products

ndash Expired product date code tampering or ldquorefreshingrdquo bull Reference Spink amp Moyer (2011) Defining the Public Health Threat of Food Fraud Journal of Food Science

copy 2015 Michigan State University 6

The Chemistry of the Crime

The Vulnerability Assessment Foundation

Detect

Deter

Prevent

copy 2014 Michigan State University

Food Fraud

Vulnerability

Assessment

Adulterants

Tampering

Theft

Over-runs

Diversion

Counterfeits

Food Fraud

Vulnerability

Assessment

Model

7

Enterprise Risk Priority

The Food Risk Matrix

Action

Intentional Unintentional

Harm

Public Health Economic or

Terror

Food Defense

Food Safety

Motivation

Gain Economic

Food Fraud(1)

Food Quality

Prevent by Understanding the Motivation

Source Adapted from Spink (2006) The Counterfeit Food and Beverage Threat Association of Food and Drug Officials (AFDO) Annual Meeting 2006 Spink J amp Moyer DC (2011) Defining the Public Health Threat of Food Fraud Journal of Food Science November 2011

Fo

od

Se

cu

rity

copy 2015 Michigan State University 8

copy 2015 Michigan State University 9

bull GFSI Guidance Document

ndash BRC Issue 7

copy 2015 Michigan State University

10

Standards Certifications and

Audits

FoodFraudmsuedu

`SEC 418 HAZARD ANALYSIS AND RISK-

BASED PREVENTIVE CONTROLS bull `(a) In General- The owner operator or agent in charge of a facility shall inhellip

bull accordance with this section evaluate the hazards that could affect food manufactured processed packed or held by such facility identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated under section 402 or misbranded under section 403(w) monitor the performance of those controls and maintain records of this monitoring as a matter of routine practice

bull `(b) Hazard Analysis- The owner operator or agent in charge of a facility shall--

bull `(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility including--

bull `(A) biological chemical physical and radiological hazards natural toxins pesticides drug residues decomposition parasites allergens and unapproved food and color additives and

bull `(B) hazards that occur naturally or may be unintentionally introduced and

bull `(2) identify and evaluate hazards that may be intentionally introduced including by acts of terrorism and

bull `(3) develop a written analysis of the hazards

copy 2015 Michigan State University

11 11 FoodFraudmsuedu

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

Defining Food Fraud bull Action Deception Using Food for Economic Gain

ndash Including the sub-category of ldquoEconomically Motivated Adulterationrdquo or EMA

ndash Note FDA currently defines EMA as a ldquosubstancerdquo for ldquoeconomic gainrdquo

bull Motivation Economic Gain ndash ldquoFood Defenserdquo motivation is traditionally harm or terror

bull Effect ndash Economic Threat

ndash Public Health Vulnerability or Threat

bull Examples ndash Horsemeat in ground beef

ndash Peanut Corporation selling known contaminated product

ndash Diluted or extra virgin olive oil

ndash Melamine in pet food and infant formula

ndash Over-icing with unsanitary water

ndash Unauthorized unsanitary repackaging (up-labeling or origin-laundering)

ndash Cargo Theft reintroduced into commerce Stolen products

ndash Expired product date code tampering or ldquorefreshingrdquo bull Reference Spink amp Moyer (2011) Defining the Public Health Threat of Food Fraud Journal of Food Science

copy 2015 Michigan State University 6

The Chemistry of the Crime

The Vulnerability Assessment Foundation

Detect

Deter

Prevent

copy 2014 Michigan State University

Food Fraud

Vulnerability

Assessment

Adulterants

Tampering

Theft

Over-runs

Diversion

Counterfeits

Food Fraud

Vulnerability

Assessment

Model

7

Enterprise Risk Priority

The Food Risk Matrix

Action

Intentional Unintentional

Harm

Public Health Economic or

Terror

Food Defense

Food Safety

Motivation

Gain Economic

Food Fraud(1)

Food Quality

Prevent by Understanding the Motivation

Source Adapted from Spink (2006) The Counterfeit Food and Beverage Threat Association of Food and Drug Officials (AFDO) Annual Meeting 2006 Spink J amp Moyer DC (2011) Defining the Public Health Threat of Food Fraud Journal of Food Science November 2011

Fo

od

Se

cu

rity

copy 2015 Michigan State University 8

copy 2015 Michigan State University 9

bull GFSI Guidance Document

ndash BRC Issue 7

copy 2015 Michigan State University

10

Standards Certifications and

Audits

FoodFraudmsuedu

`SEC 418 HAZARD ANALYSIS AND RISK-

BASED PREVENTIVE CONTROLS bull `(a) In General- The owner operator or agent in charge of a facility shall inhellip

bull accordance with this section evaluate the hazards that could affect food manufactured processed packed or held by such facility identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated under section 402 or misbranded under section 403(w) monitor the performance of those controls and maintain records of this monitoring as a matter of routine practice

bull `(b) Hazard Analysis- The owner operator or agent in charge of a facility shall--

bull `(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility including--

bull `(A) biological chemical physical and radiological hazards natural toxins pesticides drug residues decomposition parasites allergens and unapproved food and color additives and

bull `(B) hazards that occur naturally or may be unintentionally introduced and

bull `(2) identify and evaluate hazards that may be intentionally introduced including by acts of terrorism and

bull `(3) develop a written analysis of the hazards

copy 2015 Michigan State University

11 11 FoodFraudmsuedu

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

The Chemistry of the Crime

The Vulnerability Assessment Foundation

Detect

Deter

Prevent

copy 2014 Michigan State University

Food Fraud

Vulnerability

Assessment

Adulterants

Tampering

Theft

Over-runs

Diversion

Counterfeits

Food Fraud

Vulnerability

Assessment

Model

7

Enterprise Risk Priority

The Food Risk Matrix

Action

Intentional Unintentional

Harm

Public Health Economic or

Terror

Food Defense

Food Safety

Motivation

Gain Economic

Food Fraud(1)

Food Quality

Prevent by Understanding the Motivation

Source Adapted from Spink (2006) The Counterfeit Food and Beverage Threat Association of Food and Drug Officials (AFDO) Annual Meeting 2006 Spink J amp Moyer DC (2011) Defining the Public Health Threat of Food Fraud Journal of Food Science November 2011

Fo

od

Se

cu

rity

copy 2015 Michigan State University 8

copy 2015 Michigan State University 9

bull GFSI Guidance Document

ndash BRC Issue 7

copy 2015 Michigan State University

10

Standards Certifications and

Audits

FoodFraudmsuedu

`SEC 418 HAZARD ANALYSIS AND RISK-

BASED PREVENTIVE CONTROLS bull `(a) In General- The owner operator or agent in charge of a facility shall inhellip

bull accordance with this section evaluate the hazards that could affect food manufactured processed packed or held by such facility identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated under section 402 or misbranded under section 403(w) monitor the performance of those controls and maintain records of this monitoring as a matter of routine practice

bull `(b) Hazard Analysis- The owner operator or agent in charge of a facility shall--

bull `(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility including--

bull `(A) biological chemical physical and radiological hazards natural toxins pesticides drug residues decomposition parasites allergens and unapproved food and color additives and

bull `(B) hazards that occur naturally or may be unintentionally introduced and

bull `(2) identify and evaluate hazards that may be intentionally introduced including by acts of terrorism and

bull `(3) develop a written analysis of the hazards

copy 2015 Michigan State University

11 11 FoodFraudmsuedu

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

The Food Risk Matrix

Action

Intentional Unintentional

Harm

Public Health Economic or

Terror

Food Defense

Food Safety

Motivation

Gain Economic

Food Fraud(1)

Food Quality

Prevent by Understanding the Motivation

Source Adapted from Spink (2006) The Counterfeit Food and Beverage Threat Association of Food and Drug Officials (AFDO) Annual Meeting 2006 Spink J amp Moyer DC (2011) Defining the Public Health Threat of Food Fraud Journal of Food Science November 2011

Fo

od

Se

cu

rity

copy 2015 Michigan State University 8

copy 2015 Michigan State University 9

bull GFSI Guidance Document

ndash BRC Issue 7

copy 2015 Michigan State University

10

Standards Certifications and

Audits

FoodFraudmsuedu

`SEC 418 HAZARD ANALYSIS AND RISK-

BASED PREVENTIVE CONTROLS bull `(a) In General- The owner operator or agent in charge of a facility shall inhellip

bull accordance with this section evaluate the hazards that could affect food manufactured processed packed or held by such facility identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated under section 402 or misbranded under section 403(w) monitor the performance of those controls and maintain records of this monitoring as a matter of routine practice

bull `(b) Hazard Analysis- The owner operator or agent in charge of a facility shall--

bull `(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility including--

bull `(A) biological chemical physical and radiological hazards natural toxins pesticides drug residues decomposition parasites allergens and unapproved food and color additives and

bull `(B) hazards that occur naturally or may be unintentionally introduced and

bull `(2) identify and evaluate hazards that may be intentionally introduced including by acts of terrorism and

bull `(3) develop a written analysis of the hazards

copy 2015 Michigan State University

11 11 FoodFraudmsuedu

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

copy 2015 Michigan State University 9

bull GFSI Guidance Document

ndash BRC Issue 7

copy 2015 Michigan State University

10

Standards Certifications and

Audits

FoodFraudmsuedu

`SEC 418 HAZARD ANALYSIS AND RISK-

BASED PREVENTIVE CONTROLS bull `(a) In General- The owner operator or agent in charge of a facility shall inhellip

bull accordance with this section evaluate the hazards that could affect food manufactured processed packed or held by such facility identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated under section 402 or misbranded under section 403(w) monitor the performance of those controls and maintain records of this monitoring as a matter of routine practice

bull `(b) Hazard Analysis- The owner operator or agent in charge of a facility shall--

bull `(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility including--

bull `(A) biological chemical physical and radiological hazards natural toxins pesticides drug residues decomposition parasites allergens and unapproved food and color additives and

bull `(B) hazards that occur naturally or may be unintentionally introduced and

bull `(2) identify and evaluate hazards that may be intentionally introduced including by acts of terrorism and

bull `(3) develop a written analysis of the hazards

copy 2015 Michigan State University

11 11 FoodFraudmsuedu

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

bull GFSI Guidance Document

ndash BRC Issue 7

copy 2015 Michigan State University

10

Standards Certifications and

Audits

FoodFraudmsuedu

`SEC 418 HAZARD ANALYSIS AND RISK-

BASED PREVENTIVE CONTROLS bull `(a) In General- The owner operator or agent in charge of a facility shall inhellip

bull accordance with this section evaluate the hazards that could affect food manufactured processed packed or held by such facility identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated under section 402 or misbranded under section 403(w) monitor the performance of those controls and maintain records of this monitoring as a matter of routine practice

bull `(b) Hazard Analysis- The owner operator or agent in charge of a facility shall--

bull `(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility including--

bull `(A) biological chemical physical and radiological hazards natural toxins pesticides drug residues decomposition parasites allergens and unapproved food and color additives and

bull `(B) hazards that occur naturally or may be unintentionally introduced and

bull `(2) identify and evaluate hazards that may be intentionally introduced including by acts of terrorism and

bull `(3) develop a written analysis of the hazards

copy 2015 Michigan State University

11 11 FoodFraudmsuedu

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

`SEC 418 HAZARD ANALYSIS AND RISK-

BASED PREVENTIVE CONTROLS bull `(a) In General- The owner operator or agent in charge of a facility shall inhellip

bull accordance with this section evaluate the hazards that could affect food manufactured processed packed or held by such facility identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards and provide assurances that such food is not adulterated under section 402 or misbranded under section 403(w) monitor the performance of those controls and maintain records of this monitoring as a matter of routine practice

bull `(b) Hazard Analysis- The owner operator or agent in charge of a facility shall--

bull `(1) identify and evaluate known or reasonably foreseeable hazards that may be associated with the facility including--

bull `(A) biological chemical physical and radiological hazards natural toxins pesticides drug residues decomposition parasites allergens and unapproved food and color additives and

bull `(B) hazards that occur naturally or may be unintentionally introduced and

bull `(2) identify and evaluate hazards that may be intentionally introduced including by acts of terrorism and

bull `(3) develop a written analysis of the hazards

copy 2015 Michigan State University

11 11 FoodFraudmsuedu

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

copy 2015 Michigan State University

12

Michael Taylor Office of Foods FDA

November 2014

Opportunities for Collaboration and Progress

on Verification

bull ldquoSo one of the most important questions we

are grappling with at FDA is how we can

enhance our role in verification and strengthen

our public and private partnerships to better

assure consumers that our food safety

systems are working hellip

bull First in our domestic inspection and

compliance program our focus will be on

achieving and verifying that private food

safety management systems are working

effectively to prevent problems hellip

bull Second private verification and audit

activities already play a central role in food

safety systemshelliprdquo bull httpwwwfdagovFoodGuidanceRegulationFSMAucm421685htm

FSMA and Third-Party Audits

FoodFraudmsuedu

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

Global Activities ndash April 2015 bull UK Elliott Review (Food Fraud Food Crime)

ndash FSA-UK FSA-IRE

bull EC Resolution EP Focus (Food Fraud) ldquotop -5rdquo issue

bull Interpol Operation Opson I II III (Food Crime IP)

bull GFSI Guidance Document plus ldquotop-5rdquo issue ndash Food Fraud Think Tank Food Fraud Mitigation Position Paper

ndash Food Fraud Vulnerability Assessment Workshop

bull PAS 96 Food Defence (Intentional) plushellip

bull ISO TC 247 Fraud Countermeasures and Controls plushellip

bull GMA Brand Protection Consumer Product Fraud plushellip

bull US Pharmacopeia Food Chemicals Codex (Adulteration) plus

bull US Food Safety Modernization Act (FSMA) plushellip ndash Requesting comments on ldquoEconomically Motivated Adulterationrdquo

bull Chinese Food Safety Laws traditional and non-traditional prevention

bull Corporate Processes and Systems ndash Quality Six Sigma

ndash Enterprise Risk Management Chief Risk Officer COSO principles

copy 2015 Michigan State University 13

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

copy 2015 Michigan State University 14

China Food Safety Law

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

China Law Addressed Food Fraud

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

China Food Fraud Incident Type

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

China Criminal Law Deal with

the Food Risk

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

Call to Action bull Academia

ndash Shift from intervention and response to prevention

ndash Define the value of technology and countermeasures in terms of the impact on prevention (re lawsuits enforcement prosecution)

ndash Lead with the behavioral sciences and criminology

bull Industry ndash Food Fraud Prevention focus ndash holistic consumer confidence

ndash Engage Governments in request for comments

ndash Risk assessment vulnerability frame

bull Governments ndash Focus broadly on product fraud not just adulterants

ndash Define Food Fraud in laws not just in regulations or guidance documents

ndash Create and engage public-private partnership forum

ndash Risk assessment risk summing for all population-wide risks

bull State and Local Agencies ndash Collaborate to define the risk- and science-based approach

ndash Evaluate safety of food inspectors

copy 2015 Michigan State University 18

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

copy 2015 Michigan State University copy 2011 Michigan State

University 19

MSU Engagement 2015 Outcome Benefit Commitment

Graduate

Course

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space

14 Weeks online May to

August ~$2200

Executive

Education

Share your

knowledge and set

direction of research

Develop the internal talent

to support initiatives in the

AC space meet other

thought leaders (ldquoinvitation

onlyrdquo sessions for brand

owners)

2 Days on-campus ($1950)

June 15-16

June 17-18 QFR

Sept 21-22

Sept 23-24 QFR

Multi-

Client

Studies

Research the whyrsquos

of ACD understand

underlying drivers

Uncovering the drivers

may lead to new

strategies to combat

Counterfeiting

Teleconference Meetings with

option for on-campus

eg Veterinary and Animal

Product Fraud

MOOC Engage global

network of Food

Fraud thinkers

Two 2-hour on-line

webinar format with

assessment Students

earn an MSU ldquocredentialrdquo

May 19 amp 26

Nov 2 amp 6 (Bi-lingual

Mandarin)

Contact John Spink SpinkJMsuedu ndash 5173814491 ndash httpFoodFraudmsuedu 19

copy 2015 Michigan State University

Discussion

John Spink PhD

SpinkJmsuedu

Twitter Food Fraud and FoodFraud

Food Fraud Reference Sheet httpfoodfraudmsuedufood-fraud-reference-sheet

wwwFoodFraudmsuedu

20