‘Enabling the shift to prevention’ is challenging because, usually, there have been years of measuring success by the number of arrests, length of incarceration, or pounds of products seized. Shifting from reaction to prevention requires a new set of proactive success metrics.
When creating a new food fraud prevention strategy you could start with quality management-type principles. These principles include success metrics that address the root causes of problems that create the incidents. The traditional reactionary approach of an investigation or inspection function is often tasked with ‘catching’ or ‘detecting’ product fraud. Those reactionary efforts have success metrics based on interventions that result in arrests, prosecutions, and seizures of products. Those are effective success metrics for those reactionary interventions but they are not proactive and they only have an indirect impact on prevention. Crime catching is a very different process than crime prevention.
When legacy systems attempt to shift to prevention, there are inefficiencies with the previous success metrics (e.g., how they define, measure and reward success).
While the vision of changing to proactive, prevention-focused metrics sounds easy, there are often many insurmountable challenges.
First, the intervention resources often cannot shift to crime prevention activities. Catching ‘bad guys’ is very different from identifying system weaknesses and controlling the root causes. There is a fundamental difference between a threat assessment and a vulnerability assessment. For example, when considering food safety, the interventions focus on catching manufactured product that has a pathogen. In contrast, prevention is monitoring the consistent temperature of refrigerators or ovens (since temperature variation could be a root cause of a food safety incident).
Remember, we’re not trying to catch food fraud; we’re trying to prevent it from occurring in the first place.
Second, it is extremely challenging for an organization to shift the success metrics radically. The entity and individuals have spent their careers optimizing one set of parameters. Now everything changes. Two critical components are top-down commitment to make the change, and brave managers who will craft and implement the change. I say brave because these managers will be changing the status quo. These brave managers will be going outside what is familiar and what is the comfort zone of everyone.
The food industry implemented these concepts in food safety and HACCP programs. In the mid-1990s, the sector expanded quality management from just measuring manufacturing operations defects to reducing the root causes. Based on amazing results and competitive pressures, quality management expanded to all parts of business and further and further into prevention. Now thirty years later, in the 2020s, students are taught that quality management and prevention are critical to the success of everything.
Soon – hopefully, we don’t need to wait thirty years – food fraud prevention will be a common focus for the industry, food regulators, and law enforcement.
- Be aware that shifting to prevention is often very challenging since it confronts the status quo – the shift requires radically changing work processes for organizations, teams, and individuals.
- When shifting from intervention to prevention strategies, there is a need for agreement (or mandate) from the top-down to create new success metrics. This also requires buy-in regarding the success metrics from the oversite bodies, such as a group vice-president, division president or even the Board of Directors.
- Within companies, the quality management principles and value are well-known. For a government agency trying to shift to a proactive focus, the application of quality management prevention concepts will leverage a history of successful implementation. When shifting the success metrics, explain the new focus in familiar terms and quality management.
Excerpt from Food Fraud Prevention, 2019, Page 101:
Sidebar: Shift to a Prevention Focus
Food fraud prevention is similar to other food safety management concepts such as Hazard Analysis and Critical Control Point plan (HACCP) and the broader business quality management concepts such as Total Quality Management (TQM) or Six Sigma (“6S”). While both HACCP and quality management faced resistance when first implemented, they are widely accepted and understood. Quality is not only part of the corporate culture but even is often now a core company value.
Considering the quality management commitment, the core philosophies of the control systems are fundamentally similar to other food safety programs. The same concepts are the idea of identifying hazards, determining critical control points that should be monitored, and then a process to make sure the countermeasures and control systems are implemented. When developing and then implementing a new system, for getting buy-in and speed understanding, it is effective to start with a known concept to explain the value to the resource-allocation decision-makers. For food fraud prevention, the concept has been a “Vulnerability Assessment and Critical Control Point plan” or “VACCP” (GFSI FFTT 2013; GFSI 2016; FSSC 2018). Addressing food fraud in VACCP is identified as different as addressing food safety (HACCP) but yet utilizing very similar methods and systems. Food fraud starts with the highly regarded and familiar HACCP concepts and then refines the process to apply to the vulnerability uniquely.