Food Fraud & Food Defence

By Santhosh Jayaram, Partner & Head - Sustainability & CSR, and Aviekal Kakkar, Associate Director ­ Sustainability ­ Food Safety, KPMGSanthosh has over 19 years of experience and is a regular speaker on important platforms on Sustainability in the country. He is recognized as a thought leader in the South-Asian region in the areas of sustainability and climate change.

Aviekal is the Associate Director at KPMG and being a food critic and reviewer, he also speaks at Amity University, Noida as a visiting faculty to talk about food safety trainings. He previously worked at various organizations at New Zealand and UAE.

We knew the world would not be the same. Some people laughed. A few cried. Most people were silent - J. Robert Oppenheimer.

Yes; today, the world has changed indeed, from the world we knew a few decades back. Even if I compare it from my childhood, the changes I have witnessed are flabbergasting. One of such changes I have witnessed is the people's mind, the attitude, and the greed for success & money. The greed to rise higher than the rest. And this greed of success, power and money has somewhere led man towards committing frauds, and cheating our own people. These frauds today are in all walks of our life. And that has not even left-out the fuel we need to even think to commit a fraud – ‘Food'.

Competitive markets for valued raw materials, global supply chain with increasing length & complexity, and inconsistent global regulatory requirements have made us shift our focus from risk to vulnerability. We have always talked about HACCP (Hazard Analysis Critical Control Point), a tool used for food safety and prevention from contamination. However today, with the shift of our focus from just food safety risks from unintentional contaminations from Biological, Physical, and Chemical factors, to vulnerable factors for intentional contamination, we have to use other tools like TACCP (Threat Analysis Critical Control Point) and VACCP (Vulnerable Analysis Critical Control Point), in addition to HACCP to have a sound Food safety system in our Food businesses.

Economically Motivated Adulterations, Malicious threats, Extortions, Espionage, and Counterfeiting are the types of supply chain threats & frauds that are evident today. Motives behind such attacks could be many, such as money, sabotage, revenge and more.
To make this clearer, let us see some of the examples of 'Food Frauds' that have taken place in the recent past:

One of the most common has been in the labelling; as some products labelled as ‘Organic', but the product in actual not being organic. Use of prohibited artificial colours in 'Dal', use of Argemone oil that can cause severe health issues, pesticides found in food leading to fatalities, and many more... the list can go on and on. Many consumers have suffered because of these adulterants in terms of minor to major health issues, and in some cases, deaths.

So, to understand a fraud, we need to understand the true motives behind an attack, and identify the kind of attackers who could shape these frauds. These attackers could be Extortionists, Opportunists, Extremists, Disgruntled individuals, Hacktivists and Cyber criminals, or could be professional criminals. Therefore, to stop a fraud and defend our food from being intentionally contaminated, we need to identify the threats in our supply chain, in our own management systems, our infrastructure, and our layouts. This identification of threats, and analyzing them to control any kind of intentional or unintentional contamination is TACCP. This is the first step towards preventing fraud. At times, we need to go further deep and think out-of-the-box to identify the true threat. This leads us to the next step of identifying the Vulnerable factors around each threat identified; keeping in mind the kind of motives of an attack and the attackers around us. These vulnerable factors could be responsible for the intentional contamination, which may lead to an unsafe product. This is VACCP, done towards Food defence.

Let's take an example to understand it better. Take a kitchen where a chef is preparing some of his creation for his guests. He is alone in the kitchen, or the preparation area, and had to leave the kitchen for some reason mid-way, leaving the under-processed food unattended. This is a threat, where any intentional or unintentional contamination may occur, without the knowledge of the chef. Now, a disgruntled employee of the firm, who wants to teach the management a lesson, becomes the vulnerable factor, who may intentionally contaminate the food; again without the knowledge of the chef. Hence, you see how threat and vulnerability lead to food being contaminated ‘intentionally', making it unsafe. In this case, you may think that a CCTV may be enough to keep an eye, but the answer is no. CCTV is a preventive measure and not a corrective measure. In true sense, a CCTV could be preventive, when being monitored 24/7, and there are no blind spots in the room, so that you could stop any crime on the spot. Later, watching the footage after the crime has taken place has no meaning. In addition to this, we would need to understand the disgruntled individuals in the organization, and the reasons behind it; so that the management could take a corrective action in analyzing the root cause for him to be disgruntled, to take further required actions.

With this example, we could conclude that having control measures is one thing and having the right implementation of it is another. Hence, we need to think out-of-the-box to have a sound system to prevent food frauds and defend our food. We have a standard `PAS 96', that talks about Food Defence. Other ISO and GFSI standards today have incorporated the idea of TACCP and VACCP to have a sound Food safety in an organization. Having a certificate of such standards alone would not prevent any food from being contaminated, but the right knowledge and implementation will. We could see many more examples in the past, where big brands have at times failed, despite of having all standards in place, with regular audits being done. We must look into such cases to take a lesson, to improve our future.

I would end on this note with a saying that comes to my mind once said by Winston Churchill – ‘The farther backward you look, the farther forward you can see'.