Food Control 105 (2019) 233–241

Contents lists available at ScienceDirect

Food Control
journal homepage: www.elsevier.com/locate/foodcont

Introducing the Food Fraud Prevention Cycle (FFPC): A dynamic T

information management and strategic roadmap
John Spinka,∗, Weina Chenb, Guangtao Zhangc, Cheri Speier-Perod
a
Michigan State University, College of Veterinary Medicines, Food Fraud Initiative, 1129 Farm Lane, B51, East Lansing, MI, 48864, USA
b
Global Food Safety Center Mars Incorporated, Yanqi Economic Development Zone, Huairou District, Beijing, 101407, China
c
Global Food Safety Center, Mars Incorporated, Yanqi Economic Development Zone, Huairou District, Beijing, 101407, China
d
Michigan State University, Broad Business School, Department of Supply Chain Management,, 632 Bogue St. N520, East Lansing, MI, 48824, USA

A R T I C LE I N FO A B S T R A C T

Keywords: Food fraud – intentional deception for economic gain using food – is an emerging research field due to increased
Food fraud awareness of the health hazard, increased regulatory scrutiny, increased awareness of the costs, a seemingly
Vulnerability endless stream of identified incidents, and new compliance requirements. Beyond the laws and regulations that
Assessment are being more routinely applied, commercial standards have expanded to address food fraud. Specifically, since
Crime
January 2018 the Global Food Safety Initiative (GFSI) has required that Food Safety Management Systems
Prevention
Food fraud prevention cycle
include a Food Fraud Vulnerability Assessment (FFVA) and a Food Fraud Prevention Strategy (FFPS). When an
entity begins to address the topic, the first consideration is what is food fraud and includes is food fraud really a
problem, the focus then shifts to how to detect food fraud including the development of test methods. At that point,
there are more fundamental and practical implementation questions such as how to start, what to do, and how
much is enough, and how to measure success. The review of these questions has resulted in one unmet need for a
method to manage the information and activities in the FFPS. Consideration of these concepts provided the
realization that there was a need to connect the steps into an interconnected and dynamic system. The objective
was to connect everything to everything. The Food Fraud Prevention Cycle (FFPC) was developed to meet this
unmet need. This research paper includes four illustrative examples including a response to: new public policy
priorities, a new food fraud incident, and a review of a new countermeasure or control system. The adoption of a
holistic and all-encompassing information management cycle will enable a harmonized approach and the
sharing of best practices.

1. Introduction
Food fraud is an emerging food industry challenge that has started
to be a peer-review publication research topic. As the focus on food
fraud has shifted from defining the topic to assessing incidents, a stream
of research has provided a more comprehensive review of the under-
lying concepts (Everstine, Spink, & Kennedy, 2013; Moore, Spink, &
Lipp, 2012; Spink & Moyer, 2011; Spink, Moyer et al., 2015), and the
development of new methodologies for managing food fraud (among
others, see SSAFE 2015, USP 2015, Spink, Moyer et al., 2016a,b; Reilly,
2018, pp. I–21). The underlying concepts of risk versus vulnerability and
prevention versus mitigation were recently reviewed (Bréchon, Hanner, &
Mariani, 2016; DEFRA 2014; Lord, Flores Elizondo et al., 2017; Lord,
Spencer et al., 2017; Manning & Soon, 2016; Primrose, Woolfe, &
Rollinson, 2010; Spink, Ortega, Chen, & Wu, 2017; van Ruth, Huisman,
& Luning, 2017; van Ruth, Luning, Silvis, Yang, & Huisman, 2018).
As stakeholders, including companies and countries, begin to sys-
temize their approach to the food fraud problem there is an increasing
focus on management systems and methods. This article builds upon
hazard identification and risk assessment research components of the
risk analysis cycle, and shifts focus to the importance of building a
foundation for risk management and risk communication. There is an
evaluation of the acceptable/unacceptable level of risk or what is referred
to as risk tolerance or risk appetite during the Risk Management step in
the process of Risk Analysis (COSO 2012a, 2012b; ISO 2009; ISO 2017).
This project builds upon previous related Food Control Journal
articles including “Introducing the Food Fraud Initial Screening Model
(FFIS)” (Spink, Moyer, & Speier-Pero, 2016a), “The Economics of a
Food Fraud Incident Case Studies and Examples Including Melamine in
Wheat Gluten” (Moyer, DeVries, & John Spink, 2017). In addition to

∗
Corresponding author.
E-mail addresses: spinkj@msu.edu (J. Spink), Weina.Chen@effem.com (W. Chen), Guangtao.Zhang@effem.com (G. Zhang),
cspero@broad.msu.edu (C. Speier-Pero).

https://doi.org/10.1016/j.foodcont.2019.06.002
Received 6 April 2019; Received in revised form 31 May 2019; Accepted 1 June 2019
Available online 03 June 2019
0956-7135/ © 2019 Elsevier Ltd. All rights reserved.
J. Spink, et al.
those articles, this new Food Fraud Prevention Cycle concept builds
upon many other related works such as “Defining the Public Health
Threat of Food Fraud” and “The role of the public private partnership in
Food Fraud prevention — includes implementing the strategy” (Spink
and Moyer, 2011, Spink et al., 2016b).
2. The Food Fraud Prevention Strategy development
Food fraud is an intentional deception for economic gain using
food1 (CFSA 2015a, 2015b; CODEX 2017; DEFRA 2014; European
Parliament 2013; GFSI 2014; ISO 2005; ISO 2011a; Spink & Moyer,
2011). This definition is correlated with the broader August 2018 ISO
definition of:
“Product Fraud: wrongful or criminal deception that utilizes ma-
terial goods for financial or personal gain; Note 1 to entry: Fraud means
wrongful or criminal deception intended to result in a financial or
personal gain that creates social or economic harm” (ISO 2018).
The types of food fraud include: adulterant-substance2 (e.g., adul-
terant, adulteration: including dilution, substitution, concealment, un-
approved enhancements), mislabelling or misbranding, tampering, grey
market or diversion, smuggling, stolen goods such as cargo theft and
organized retail theft, and counterfeiting (Intellectual Property Rights -
IPR) (GFSI 2018; Spink, 2019d). Food fraud can occur across all types of
products that include: raw materials, incoming goods, goods in manu-
facturing, goods in storage, products at retailers, and also through to
destruction or disposal. There are different industry stakeholders that
include: those within the immediate supply chain including brand
owners such as producers, manufacturers, food distributors, and re-
tailers; support and secondary stakeholders including research or gui-
dance service providers such as academics or management consultants;
and then contract research and testing services including technology
suppliers and including authenticity affirmation (e.g., test of the pro-
duct, transaction analysis, or external component), data management,
investigations, audits, market monitoring, and others (Spink, 2018;
Spink et al., 2019c). There are also different government stakeholders
such as the regulators and law enforcement who are required to im-
plement the laws and regulations, the prosecutors who decide which
cases are brought to the court, the criminal justice system which in-
cludes judges and prosecutors assigning penalties including incarcera-
tion, and finally, the entire process starts with the creation of new laws
and allocation of funds by legislative branches such as a parliament or
congress.
There are a breadth of laws and regulations that arbitrate food fraud
including food, public health, consumer protection, commercial trans-
actions, customs and smuggling. Given this breadth of agencies and
1
Note: The current, but not final, public draft of the Codex Alimentarius
Electronic Work Group on Food Integrity and Food Authentication definition of
food fraud is “Any deliberate action of organizations or individuals to deceive
others for economic gain or avoidance of an economic loss in regards to the
integrity of food to gain undue advantage. Types of food fraud include but are
not limited to: adulteration, substitution, dilution, tampering, simulation,
counterfeiting, and misrepresentation” (Codex, 2017). At this time Codex is also
defining food integrity but does not have a definition of adulterant or adul-
teration.
2
From Spink, Hegarty, Fortin, and Elliott (2019a), “The term “adulterant-
substance” is used here to be clear that this is referring to a “substance” not the
broader class of “adulteration” or “adulterated foods” which often does not
necessarily require an “adulterant.” There is often confusion since the US Food
Drug & Cosmetics Act “Adulterated Food” section applies to concepts such as
spoiled products or stolen goods. Spoiled products and stolen goods are gen-
uine, authentic products and do not include an “adulterant.” In 2017, the US
Pharmacopeia defined “adulterant” as “any undeclared biological or chemical
agent, foreign matter, or other substance in food that may (though not ne-
cessarily) compromise food safety or suitability” (USP 2017). Codex Ali-
mentarius does not have a definition of adulterant, adulterated, or adulteration
(CODEX, 2018).
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Food Control 105 (2019) 233–241
activities, there is usually no single law that directly addresses food
fraud in isolation. Thus, it is possible that some aspects of food fraud (as
defined), are not holistically covered from a regulatory standpoint, and
it is important to delineate that all types of food fraud are clearly illegal.
a. The Food Risk Matrix and Compliance Requirements
To understand the scope of food fraud it is useful to review the topic
in relation to all food risks including (and see glossary for other related
terms) (Fig. 1) (Spink & Moyer, 2011):
• food safety: unintentional acts that cause public health harm;
• food quality: unintentional act that does not cause public health
harm;
• food defense: intentional act with the intent of causing public health,
terror, or economic harm.
The focus of the Food Risk Matrix is on the root cause motivation for
why the human adversary identified and acted upon a fraud opportu-
nity. The focus on the intricate detail is a primary Criminology re-
quirement for Situational Crime Prevention which seeks to reduce that
fraud opportunity. A food safety or food quality risk is unintentional
and the adversary did not try to create this problem. The root cause is a
lack of awareness or an unknown system problem. A food fraud risk is
intentional and the adversary is tryng to NOT get caught while ex-
ploiting a perceived system weakness. Similarly, a food defense risk is
intentional and the adversary is trying to create harm that is economic,
public health, or terror. Food fraud prevention requires a fundamen-
tally different approach that for food safety since there is an intelligent
adversary who actively seeks to avoid detection.
Food fraud prevention has become a management requirement for
food standards such as those organized by the Global Food Safety
Initiative (GFSI) (GFSI 2017). GFSI was created in 2002 by a group of
global companies under the Consumer Goods Forum and now is a re-
quirement for their members which reportedly equate to approximately
65% of the world food trade. GFSI initially focused on large multi-na-
tional companies, whilst also expanding to smaller enterprises through
organizations such as Codex Alimentarius (Codex), World Health Or-
ganization (WHO) and the United Nations Food and Agricultural Or-
ganization (FAO). GFSI published their Guidance Document stating the
expected requirements of a Food Safety Management System (FSMS).
As of January 2018, there is a GFSI requirement for a written Food
Fraud Vulnerability Assessment and a written Food Fraud Prevention
Strategy (or also referred to as a Food Fraud Mitigation Plan) – this is
NOT an optional component of a GFSI-endorsed food safety certifica-
tion (GFSI 2017) [for more on prevention versus mitigation see Spink
et al., 2017]. The GFSI definition and scope include all types of fraud
(see list above) and all products (see list above) (GFSI 2014; GFSI 2017;
GFSI 2018). The GFSI types of fraud are consistent with other global
activities such as CODEX, who in their food fraud related electronic
working group state “Types of food fraud include but not limited to:
adulteration, substitution, dilution, tampering, simulation, counter-
feiting, and misrepresentation” (CODEX 2017).
2.1. New research perspectives
There are four new perspectives when considering how to address
food fraud prevention holistically which differ from a traditional
HACCP (Hazard Analysis and Critical Control Point plan) and food
safety or TACCP (Threat Analysis and Critical Control Point plan) and
food defence approach. These new perspectives include: (1) when fo-
cusing on the diagnosis or root-cause, food fraud is a fundamentally
different problem than food safety, food quality, or food defense; (2) the
need to shift focus from incident risk mitigation to strategic vulnerability
prevention (Spink et al., 2017); (3) shifting the mindset from only Food
Science to an interdisciplinary approach; and finally (4) applying
J. Spink, et al.
Food Food (4)
Quality Fraud (1) Gain: Economic
Harm:
Food Food Public Health,
Safety Defense (2)
Economic, or Terror
(3)
Fig. 1. The Food Risk Matrix (Spink & Moyer, 2011) [Notes: (1) Among others,
includes the subcategories of economically motivated adulteration (EMA) and
food counterfeiting; (2) Among others, includes the subcategory of terrorism;
(3) the act of a stakeholder whether an accidental act by a legitimate stake-
holder or an intentional deception by a fraudster or an intentional harm by an
attacker, and (4) the objective of the intentional action].
decision analysis and business risk assessment to examine food fraud in
the same way as all enterprise-wide issues (Fig. 2). It is important to
identify the range of disciplines that contribute to an improved un-
derstanding of food fraud and hence capability to address it but ela-
boration of each is beyond the scope of this paper. To address the
complex nature of food fraud prevention, the interdisciplinary ap-
proach includes, but is not limited to: Food Science/Food Authenticity,
Criminology, Managerial Accounting, Financial Accounting, Public
Policy, Law, Supply Chain Management, Packaging Science, Informa-
tional Technology, Social Anthropology.
It is important to note that the importance of food science and food
authenticity may seem under-represented here but it is because they are
considered a constant and thoroughly established resource. Once the
specific problem is identified, and the type of fraud defined, there are
resources and capabilities to address the problems. An example is the
Euro 13 million that was allocated by the European Commission to the
Food Integrity Project (food authenticity) in 2014 shortly after the 2013
Europe-wide horsemeat incident. The resources and focus on detection
Risk to Vulnerability
• Diagnosis: Monitor the system weaknesses not probability of
occurence.
• Treatment: There is a range of weaknesses that required a
unique countermeasures and control systems beyond
Focus on the Final Decision to Act
• Prognosis: The final breakthrough was considering the
Fig. 2. Hierarchy of theoretical new perspectives.
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Food Control 105 (2019) 233–241
Food Fraud
Food Fraud
Screening/
Food Fraud Vulnerability
Strategy
Fig. 3. The Food Fraud Vulnerability Assessment (and the simpler Food Fraud
Initial Screening tool) is a vital part of the Food Fraud Prevention Cycle (FFPC),
which is the management method for the Food Fraud Prevention Strategy.
are evidenced in the call for projects including: Standardisation and
harmonisation of untargeted food integrity methods, Innovative ap-
proaches to assure the integrity of complex foods, A feasibility study of
how information can be shared along the supply chain to identify risks
to the integrity of food, and Rapid, on-site, cost-effective methods for
feed/food fraud detection (ref fip fera).
2.2. First: addressing food fraud is Fundamentally Different from addressing
food safety
As research in food fraud continues to develop, it is increasingly
clear that food fraud and food safety are very different issues. Relative
to food safety, one identified gap when investigating food fraud relates
to the processes of managing information and making decisions. One
capability that has been developed to address this gap is the Food Fraud
Vulnerability Assessment, which provides a basic overview of the pro-
blem and facilitates decision-making on the scope and depth of the
Food Fraud Prevention Strategy. The information and activities in the
Food Fraud Prevention Strategy are managed by the Food Fraud
Prevention Cycle (FFPC) (Fig. 3).
2.3. Second: the shift from incident risk mitigation to strategic vulnerability
prevention
The second new perspective was the realization that incident re-
sponse methods are not usually efficient or effective to support the goal
of overall strategic prevention. A current food fraud event requires an
J. Spink, et al.
immediate incident response. These actions focus on finding and then
removing the illicit product that is in the marketplace. Detecting frau-
dulent product is critical – however, it is neither prevention nor is it a
firm strategy to address food fraud. The focus on strategic prevention is
a longer-term perspective that shifts the focus from catching bad pro-
duct to preventing the incident from occurring in the first place.
To provide richness to these new perspectives, consider a food fraud
incident when pets became sick in the United States. The first step was to
determine the root cause. The overall adulterant-substance motivation
was to deceive protein tests. The tests were deceived by reducing the
amount of authentic protein with the melamine molecule. Once illeg-
ally added melamine was identified as the problem3 which is more di-
rectly referred to as the “fraud opportunity,” the key next step was to
detect the adulterant-substance for the products in the marketplace. The
continuing melamine detection tests would deter melamine from con-
tinuing to get into the marketplace. The incident response was specific
for detecting melamine that was in product. The response is not pre-
vention and the countermeasures were not specifically focused on re-
ducing the overall fraud opportunity of perpetrators even considering
attacking the pet food and high-value ingredients. The fundamentally
different approach is to first consider the root cause of the entire fraud
opportunity using criminology theories. This is followed by a review of
the resource-allocation decision-making process, which might include
understanding a firm's supply chain and cost accounting as well as
regulatory/public policy issues within and across countries. This step
includes a vulnerability assessment identifying which problems are
above a pre-defined risk tolerance. After those three steps, an optimal,
efficient, and effective set of countermeasures and control systems can
be proposed, approved, implemented, and managed. The FFPC com-
prises each of these steps, including the ongoing management and re-
calibration up or down of the risk treatments.
The new insight from the FFPC starts in the intervention step after a
food fraud event. Building upon the United States Food and Drug
Administration (FDA) Food Protection plan (FPP), an intervention step is
a response to a problem. For example, in the case of melamine in infant
formula, the intervention step was to identify the root cause of the public
health threat and then establish detection methods to identify the
adulterant-substance. After the problem is defined, then the next stage
is the response step. For example, for the melamine incident, the re-
sponse was recalling a product from the market and treating the public
health incident. Finally, to reduce or mitigate the root-cause, there is a
need to shift from being reactive to proactive, implementing counter-
measures and control systems that support the prevention step (Spink &
Moyer, 2011). After the intervention and response, a prevention strategy
to address the problem is needed. For example, in the melamine ex-
ample, prevention might include: conducting routine adulterant testing,
researching for new or different types of food fraud, assessing system
weaknesses that enabled the fraud, finally, a more general considera-
tion of the root-cause that could apply to other adulterant-substances or
to other types of products.
2.4. Third: expanding to include social sciences and criminology
The third new perspective was to develop an inter-disciplinary
mindset shift extending beyond Food Science and food authenticity
testing to include Social Science and Criminology. This shifts the focus
from microbes and microbiology to humans and social science. It has
been said, “if the biological organism in question is a microbe then it is
natural to apply Microbiology; since the biological organism in question
3
The term “problem” is used in Criminology. Problem: “… the basic units of
police work rather than a crime, a case, calls, or incidents. A problem is
something that concerns or causes harm to citizens, not just the police. […]
Addressing problems means more than quick fixes: it means dealing with
conditions that create problems” (Clarke et al., 2005).
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Food Control 105 (2019) 233–241
is human then it is natural to apply Social Science and Criminology”
(IUFoST 2016). In retrospect, this Social Science view is entirely logical,
but when food fraud was considered only a food safety problem, it was a
novel concept. When extending food safety to food fraud, one must
consider an intelligent human adversary is purposely engaging in crime
in order to generate economic gain, thus Criminology becomes the most
applicable science.
Criminology involves two primary perspectives: traditional crimin-
ology that focuses on the criminal, and environmental criminology that
focuses on the physical space where the crime occurs. Regardless of the
perspective, both types of Criminology emphasize reducing the oppor-
tunity for crime to occur (Felson, 2013, pp. 92–99; Felson & Clarke,
1998). The specific environmental criminology concepts that were
presented in seminal works such as “Crime in Everyday Life” are Si-
tuational Crime Prevention which, itself, is a combination of Routine
Activities Theory and Rational Choice Theory (Felson, 1998; Felson &
Boba, 2010). These concepts were developed in the 1970s, and a 2017
scholarly literature database keyword search for situational crime pre-
vention resulted in over 10,000 peer-review journal articles since 2000.
Situational Crime Prevention is most efficient for companies or
countries because target hardening can lead to a direct and immediate
impact. For example, to reduce the concern of being pick-pocketed
someone can hold their wallet in their hand. In this example, the
countermeasure or control system can be immediate, can be initiated by
the user, has very limited if any financial cost, and has an immediate
reduction in the potential for a crime to occur.
Situational Crime Prevention is often presented visually in the form
of the Crime Triangle which consists of three major components which
are: victim, fraudster, and guardian and hurdle gaps (Fig. 4) (Spink &
Moyer, 2011).
Situational Crime Prevention is based on other criminology theories
that help to explain the fraud opportunity and identify crime-reducing
activities. These include understanding the type of criminals and of-
fender organizations (Spink, Moyer, Park, & Heinonen, 2013), applying
victimology theories (Lanier & Henry, 2004), and more applied problem-
oriented policing such as is presented in “Crime Analysis for Problem
Solvers In 60 Small Steps text”) (Clarke & Eck, 2005). This concept of
identifying the types of criminal and offender organizations is being
codified in works such as the International Organization for Standar-
disation (ISO) Technical Committee 292 on Security Management and
Resilience (ISO 2017). Specifically, this is introduced in ISO 22380
Security and Resilience – “Authenticity, Integrity, and Trust for Pro-
ducts and Documents – General Principles for Product Fraud Risk” and
ISO 12931 “Performance criteria for authentication solutions used to
combat counterfeiting of material goods” (ISO 2018).
2.5. Fourth: correlating the food fraud risks with all enterprise-wide risks
The fourth new perspective was the realization that there was a lack
of a methodological and standardized approach to the resource-allo-
cation decision-making for addressing food fraud. While there are often
acceptable/unacceptable thresholds defined in laws or regulations for
food safety and public health incidents (e.g., a 5-log kill step is required
for FDA Juice HACCP compliance), the same type of specifications do
not always apply to or exist for food fraud. Just as the prior perspective
discussed incorporating an interdisciplinary perspective when looking
at food fraud, there is similar value in drawing on guidance from other
disciplines when guiding resource allocation decisions. More specifi-
cally, food safety and food fraud decisions can be more broadly ex-
amined and informed by drawing on enterprise risk management
(ERM), a rich research stream drawn from different business fields (e.g.,
accounting, management, strategy, etc.). Enterprise risk management
has been widely adopted by firms. One widely used approach for op-
erationalizing ERM emerged out of firm compliance to the U.S.
Sarbanes-Oxley Act in 2002 that increased firm financial regulatory
requirements in response to Enron and other financial improprieties
J. Spink, et al.
Environmental Criminology
ps
Ga
le
rd
Hu
nd
na
The Fraud
dia
ar
Gu
Opportunity
Fraudster
Fig. 4. The Fraud Opportunity is presented here as defined in the Crime
Triangle with a differentiation between Environmental and Traditional
Criminology ((Spink & Mace, 2007) and (Spink & Moyer, 2011) Adapted from
(Felson, 1998)).
(COSO, 2014). It is especially efficient to apply ERM concepts because
the formal systems are already defined, harmonized, implemented,
supported with officially recognized training, and provide decision-
making support in the Internal Control–Integrated Framework (COSO
2013).
Enterprise Risk Management is implemented by all companies in
one way or another, however, the ERM process and ways of oper-
ationalizing the process (e.g., COSO) are not widely known by food
experts. As ERM has grown into a regulatory requirement for all public
companies, it is an increasing useful framework for food experts to be
aware of and to understand. While a requirement for companies, ERM is
also widely adopted by Governments, for example, in 2014 the U.S.
Government Accountability Office first expanded the “Standards for
Internal Control in the Federal Government” guidance to include COSO
principles of Internal Control – Integrated Framework adapted to the
federal government environment (GAO 2014).
The “COSO Cube” provides a simple visual for how and where to
apply food fraud vulnerability assessment in “Risk Assessment” and
then enter at any level of the organization, but usually from a “Business
Unit” such as a Quality Assurance group working to meet GFSI com-
pliance or “Entity-Level” such as a Chief Risk Officer or Chief Financial
Officer considering brand equity vulnerability (Fig. 5). Any risk that
rises to the level of “enterprise risk” is then documented, monitored and
managed. These risks are managed by an ERM committee, shared with
the Board of Directors to ensure that management is making decisions
to minimize negative consequences from each risk, and increasingly key
ERM risks are included in annual reports so that all stakeholders un-
derstand threats to the company.
In addition to the enterprise-level approach to managing food fraud
risk (elevating food fraud to the level of other risks in the firm), the
COSO cube can all be applied at a more operational level to review a
food fraud incident or suspicious activity. For example, when a new
food fraud incident or suspicious activity is first identified, the new
event should be shared with the group that is assigned to manage food
fraud incidents. In addition, this incident should also be shared with the
ERM committee and other key organizational stakeholders (e.g., top
leadership, Board of Directors, etc.) as appropriate based on the severity
of the incident. By addressing the event (food fraud committee) and
more fully incorporating lessons learned from the event at the ERM
committee, the firm is better able to identify and prepare for new, odd,
complex, or novel risks of any kind. Over time and repeated engage-
ments, the formal reporting and response process should become more
refined and methodical.
237
Food Control 105 (2019) 233–241
ST
AR
T
Fig. 5. The “COSO Cube” which presents the Enterprise Risk Management
concepts (COSO 2014a,b).
The new event enters the ERM system at the location of “Event
Identification” and at the “Strategic” category and initially only at the
“Entity-Level” of the business functions. The new event now has a
formal and systematic place to enter the overall decision-making
system. The preliminary or initial screening is usually conducted at a
very high level, but the ERM team may expand their focus from
“Strategic” into the “Operations” or “Reporting” and “Compliance.”
Also, the ERM team could expand their considerations from the Entity-
Level down into the business such as to division, business unit, sub-
sidiary, or others. An ERM risk assessor could now review the in-
formation needed to conduct the next step (one step down) of a “Risk
Assessment.” Later, as an assessment of the acceptable/unacceptable
level, the “Risk Response,” “Monitoring” and other formalized re-
sponses are determined.
An important facet of ERM is to map each corporate risk to the
magnitude of the vulnerability (COSO, 2012a). To accomplish this, each
risk is evaluated to determine the potential likelihood of occurrence and
the consequences to the firm if an event were to occur (COSO, 2012b).
An enterprise must assess all risks and either disclose or reduce those
risks above a specified risk tolerance for compliance with ERM and
regulations such as the Sarbanes-Oxley Act. An example is included of
food fraud vulnerabilities that are plotted on a Corporate Risk Map
(Fig. 6) (COSO 2013, Spink, Moyer et al., 2016a,b; MSU-FFI 2017a,
2017b).
While this approach to the management and control of food fraud
may be a novel concept for Quality Assurance or Food Safety groups,
the ERM process identifies key enterprise risks across the entire firm.
This process is widely used and has increasingly well-defined methods
for implementation by organizations.
These four new perspectives can be integrated to create a theoretical
foundation for managing and preventing food fraud in a much more
strategic manner incorporating top leadership throughout the organi-
zation. At the same time, these integrated perspectives provide a
stronger method for proactively identifying potential risks and taking
necessary actions (prevention, detection, incident response) as needed.
When considering these concepts, it was recognized that there was a
realization that there was a need to connect these steps into an inter-
connected and dynamic system. The objective was to “connect every-
thing to everything” (IUFoST 2016). This series of new perspectives
built upon a range of other basic project and resulted here in the de-
velopment of the FFPC.
J. Spink, et al.
Fig. 6. An example of a Corporate Risk Map that is populated with risks (Threat
levels are represented as red/very high, orange/high, yellow/medium, green/
low and blue/very low. The color-coding is presented in each cell, but in reality
would be bands or striations. The letters identify specific case study problems
that are referenced in the text.).
3. Food Fraud Prevention Cycle (FFPC)
The Food Fraud Prevention Cycle (FFPC) connects the new per-
spectives into an interconnected system that expands across all other
business functions (Fig. 7). The content in the FFPC is presented as
overall principles which are general concepts (e.g., A, B, & C) and steps
that are the activities that are conducted (e.g., 1, 2, 3, 4, 5 & 6). The
FFPC is expanded on and adapted from previous works from basic ISO
31000 Risk Management principles, the applied total quality manage-
ment principle such as in Six Sigma, the food fraud Chemistry of the
Crime foundation, and also previously unpublished teaching materials
(ISO 2009; ISO 2011b; MSU-FFI 2017a; Spink, 2014).
The FFPC is the map of how the activities integrate and connect. The
FFPC is a systematic way to consider new insights or information and
connect it to understanding the fraud opportunity, re-evaluating the
vulnerability, and then the final assessment of acceptable/unacceptable
within the enterprise-wide assessment.
This entire cycle is based on several concepts including “Academic
Disciplines” (Principle A) that are specific fields of study such as Food
Fig. 7. Food Fraud Prevention Cycle (FFPC) (expanded on and adapted from
previous works by (ISO 2009; MSU-FFI 2017a; Spink, 2014).
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Food Control 105 (2019) 233–241
Science/Food Authenticity, Criminology, Managerial Accounting,
Financial Accounting, Public Policy, Law, Supply Chain Management,
Packaging Science, Informational Technology, Social Anthropology.
There are “Fundamental Concepts” (Principle B) that integrates a multi-
disciplinary insight and other business activities into food fraud pre-
vention processes. As an aside, the multi-disciplinary perspectives and
activities involve combining and integrating these disciplines into one
over-arching project (Gray, 2011; Pain, 2003; Sharp et al., 2011). A
multi-disciplinary team would include a group where each member has
expertise in all the key disciplines – together they have many holistic
perspectives on the same problem. The inter-disciplinary approaches
focus on applying fundamental concepts from these diverse disciplines
separately or in sequence. An inter-disciplinary team would include a
group where each member has expertise in one of the key disciplines –
together they have perspective on the entire problem.
While the scope of this paper is on organizing the initial and most
basic concepts, regarding food fraud prevention, an initial listing of
multi-disciplinary concepts for future further application might include:
• Criminology of Situational Crime Prevention for the fraud oppor-
tunity
• Criminology to understand the nature of the criminals
• Intelligence analysis for new information
• Management, decision sciences, and psychology to understand de-
cision processes
• Strategy, risk analysis, and finance for the process of assessing risks
• Strategy and managerial accounting to more fully incorporate en-
terprise risk management
• Food science including authenticity testing
• Public policy for how laws and regulations are developed and im-
plemented
• Law enforcement challenges and priorities
• Judicial and prosecution limited resources and priorities
• Supply chain management including traceability
Other business functions that apply include:
• Key account management or sales management
• Crisis management or continuity planning
• Corporate communications including messaging to the fraudsters
• Procurement review of fluctuating market prices or economic
anomalies
• Corporate quality and food safety review of incidents and material
goods risk assessments
• Human resources including background checks on purchasing and
corporate security employees
• Corporate security to investigate criminal activity
• Corporate compliance with laws and regulations, but also with
standards and certification
• Horizon scanning and intelligence gathering
The FFPC is coordinated for the overall objective of reducing the
fraud opportunities, linking to the Criminology concepts of guardians
and guardianship and is identified as “Application – The Guardian”
(Principle C).
The functions in the FFPC are connected and identified by numbers
and letters. An important function is the consideration of new
“Information” (Step 1) which is divided into several categories in-
cluding “Review Incidents” (Step 1A, specific food fraud incidents in-
ternally or externally), “Scanning” (Step 1B, considering broad changes
such as fluctuating market prices), and then “Public Policy” (Step 1C,
which includes new laws, regulations or priority setting such as in-
vestigations).
The core of the FFPC is the Crime Triangle which defines the factors
that influence the “Fraud Opportunity” (Step 2) and the “Enterprise
Risk Rank” (Step 4). The connection between the two is the
J. Spink, et al.
“Vulnerability Assessment” (Step 3) presented along with a continuum
from an “Initial Screening” (Step 3A) and more detailed “Detailed
Vulnerability Assessment” (Step 3B) and then assessed in “Enterprise
Risk Management” (Step 5). After considering those steps, there is a
resulting “Rank” (Step 5). The “Countermeasures and Control Systems”
(Step 6) influence the “Fraud Opportunity” to connect back into that
point (Step 2).
4. Illustrative examples: a review of new information
This section will provide a few application examples of the FFPC.
a. Illustrative example 1: “(1) Information” – “(1C) Public Policy”: One
example is the Negative List of the Chinese National Center for Food
Safety Risk Assessment (CFSA). The Negative List address the food
fraud adulterant-substances that result in the most significant health
concerns and therefore are a high priority for the Chinese govern-
ment to test in the marketplace. A new chemical added to the
Negative List can impact the fraud opportunity and thus, the en-
terprise-wide risk as government increases the testing of specific
food products.
i. FFPC Entry Point: Step 1C – New Information/Public Policy
(Fig. 7).
ii. FFPC Activity: The new information is applied to the under-
standing of the Fraud Opportunity (Step 2).
iii. FFPC Decision: If this chemical is already included in substance
testing in an early warning system, then the new information
does NOT fundamentally change the way we understand the fraud
opportunity. If the chemical is not included in the testing then it
DOES change the fraud opportunity, and the “Vulnerability
Assessment” (Step 3) is updated and plotted on the Corporate
Risk Map. If the result is in the yellow, green or blue zone (e.g.,
medium, low, or very low which is presented as letter “E”
through “H”), then the new vulnerability is still within the risk
tolerance. A company may still decide to implement a new or
adjusted “Countermeasure or Control System,” but that would
further reduce a problem that is already within the acceptable
risk tolerance. For example, the new information may shift the
vulnerability from blue (point “G”) to yellow (point “E”).
b. Illustrative example 2: “(1) Information” – “(1A)” Review
Incidents”: A new food fraud incident is found, and details are
gathered by the risk assessor. An example could be peanut filler used
in ground cumin that includes a peanut allergen.
i. FFPC Entry Point: The new information is applied to Step 1A –
New Information/Review Incidents (Fig. 7).
ii. FFPC Activity: The new information is applied to the under-
standing of the Fraud Opportunity (Step 2).
iii. FFPC Decision: The presence of the peanut allergen raised the
likelihood of detection and the consequence of an incident. The
vulnerability could rise to an unacceptable risk tolerance in the
orange (point “E”) or red zones (e.g., high, or very high which is
presented as letter “E” to “B”). Now a very specific assessment
can be conducted to consider “Countermeasures and Control
Systems.” To note, the red and orange zones are within the un-
acceptable risk tolerance range. The resource-allocation decision-
makers must take action to reduce the resulting vulnerability or
they would need to disclose this hazard to regulators.
c. Illustrative example 3: “(6) Countermeasures” – New
Countermeasure and Control System (Countermeasure): A new
countermeasure, such as more advanced species test for North
Atlantic Cod fish, is considered.
i. FFPC Entry Point: The new information applied to the
“Countermeasure” (Step 6) (Fig. 7).
ii. FFPC Activity: The new test is considered in the “Fraud
Opportunity” (Step 2) and the value is judged in the
“Vulnerability Assessment” (Step 3) and again on the “Corporate
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Food Control 105 (2019) 233–241
Risk Map” (Step 5).
iii. FFPC Decision: If the current North Atlantic Cod Fish vulner-
ability is currently above the risk tolerance (point “C”) and the
new test reduces the vulnerability to the green zone (point “F”)
then this new countermeasure DOES shift the vulnerability to an
acceptable risk tolerance. If the current position is the green zone
(point “F”) and the new countermeasure reduces the vulner-
ability to the blue zone (point “H”), while this is an improvement
it is not a high priority. In this scenario, this new counter-
measure does NOT address an unacceptable risk, so there is NOT
an ERM-based justification for implementing the risk treatment.
d. Illustrative example 4: “(6) Countermeasures” – New
Countermeasure and Control System (Countermeasure): A more
secure enhanced traceability system, such as reducing the oppor-
tunity for documents to be altered or forged, is considered.
i. FFPC Entry Point: The new information applied to the
“Countermeasure” (Step 6).
ii. FFPC Activity: The new test is considered in the “Fraud
Opportunity” (Step 2) and the value is judged in the
“Vulnerability Assessment” (Step 3) and again on the “Corporate
Risk Map” (Step 5).
iii. FFPC Decision: If the current traceability document security is
under the risk tolerance (point “F”,”G,” or “H”) then this new
countermeasure addresses a vulnerability that is already accep-
table. As, above, in this scenario, this new countermeasure does
NOT address an unacceptable risk, so there is NOT an ERM-based
justification for implementing the risk treatment. Of course, it
would be valuable to add the risk treatment if it was free in
terms of financial and human resource costs.
These illustrative examples demonstrate how the FFPC creates a
systematic way to understand new information and supports resource-
allocation decision-making.
5. Conclusion
The primary food protection trend related to food fraud has shifted
from what is food fraud and is it really a problem to defining an efficient
and effective system to reduce the fraud opportunity. Following general
risk analysis concepts such as ISO31000 – including the applied total
quality management principle such as in Six Sigma, or others – the steps
to address Food Fraud include (Spink, 2019b):
1) What is Food Fraud?
2) Is it a problem?
3) How to detect specific fraud acts? Are new tests needed? And then
validate the test methods.
4) Do I need to act?
5) How to start addressing food fraud?
a) What to do (such as countermeasures or control systems in-
cluding food authenticity testing)?
b) How to measure success?
c) How much is enough?
6) Ongoing review and process improvement.
It is logical that many of the early scholarly publications focus on
the basics of “what is food fraud?” and “is food fraud a problem?” The
next step is to explore how to respond to and detect the known in-
cidents including a review of test methods, publishing results and va-
lidation. Once the foundation is constructed and the countermeasures
and control systems developed, it is natural that the research focus
further evolves to better understand more fully managing these risks
proactively and shift focus to prevention strategies.
The compliance requirements of new regulations and standards
address the question “Do I need to act?”. Before defining “How to start?”
there is a need to at least understand the methods to establish “How
J. Spink, et al.
much is enough?” and “How to measure success?”. These questions are
all addressed by building upon a Food Fraud Vulnerability Assessment
within the FFPC and within the overall Food Fraud Prevention Strategy
(FFPS). As more companies fully meet GFSI and Sarbanes-Oxley type
food fraud related compliance, there will be further development of
harmonized methods and opportunities to benchmark activities. These
concepts will continue to evolve and be refined. The FFPC is the first
step in this evolution.
There are several key areas for further research including more
detailed application of the range of disciplines (noted as “A – Academic
Disciplines”), the refinement of the applied learnings (noted as “B –
Fundamental Concepts”), and further case study research which will
provide refinement and process development of the FFPC use-case.
Funding sources
This work was conducted under the key job responsibilities of the
authors. No outside funding was provided.
Glossary
Other important related terms include:
• Food security which is the consistent, safe, continuous, supply of food
(WHO 2009),
• Economically motivated adulteration which is defined by FDA as a
“substance” for “economic gain” (FDA 2009),
• Food authenticity which is a confirmation that the “product is what it
says it is” (DEFRA 2014),
• Food protection which is a combination of food safety and food de-
fense activities (FDA 2007),
• Food integrity which is a combination of many terms and includes
statements about ethical production and ecological practices
(DEFRA 2014),
•
Food crime for which there are two definitions, one being the vio-
lation of a criminal statute using food, and the other a serious food
fraud incident (NFCU 2017; van Ruth et al., 2017).
Conflicts of interest
We declare no conflict of interest.
Acknowledgment
The authors alone are responsible for the views expressed in this
article, and they do not necessarily represent the views, decisions or
policies of the institutions with which they are affiliated.
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