Food Fraud Prevention Strategy Annual Review – Start with a Food Fraud Gap Analysis

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For a number of reasons – including inflation and global supply shortages – food fraud is becoming a hotter topic. Five years after the GFSI requirements were required, companies are realizing they should take another look at their food fraud prevention strategy. Now is a great time to conduct a ‘food fraud gap analysis.’

In the undergraduate business course that I teach each semester, I constantly talk about the quality management process of ‘Plan-Do-Check-Act’ (PDCA). If you are more focused on Six Sigma, then the concept is ‘Define-Measure-Analyze-Improve-Control’ (DMAIC). In both systems, a key step is to review the current process, which is either to ‘check’ or ‘improve.’

A crucial step in any management system is to ‘check’ or ‘improve’ through a strategic review of a program. One way to review the program is to conduct a gap analysis to see where you are, where you should be, and then to define the steps to close the gap. Once you define the steps to close the gap then you have a very clear path to updating your strategy.

Now is a good time of the year to conduct a gap analysis or strategic program review because we are past the busy start of the year, it is still before next year’s budget planning that usually starts at the end of summer, and there is still time to implement in this calendar year.

A gap analysis can be as simple as a set of survey questions – actually, to start, the simpler the better.

Food Fraud Gap Analysis Survey Questions

In our ‘Food Fraud Gap Analysis,’ there are some simple ‘yes or no’ questions to get you started [1]. This is summarized in our Primer on Food Fraud Compliance.

Food Fraud Compliance Requirements — The general compliance requirement questions for Food Fraud prevention are:

  1. Have you conducted a Food Fraud Vulnerability Assessment? (Y/N)
  2. Is it written – how soon could you show it to me? (Y/N)
  3. Have you created a Food Fraud Prevention Strategy? (Y/N)
  4. Is it written – how soon could you show it to me? (Y/N)
  5. Can you Demonstrate Implementation? (Y/N)
  6. Do you have Executive Level Sign-off (an officer of your company)? (Y/N)
  7. Have you minimally conducted an annual Food Fraud Incident Review? (Y/N)
  8. Do you have a method to review your incidents and general market incidents? (Y/N)
  9. Plus: Confirm this does address all types of Food Fraud. (Y/N)
  10. Plus: Confirm this does address all products from both incoming goods (e.g., ingredients) and outgoing goods (e.g., finished goods) through to the consumer. (Y/N)

If you want to take this survey to another level deeper, then you could add a 1 to 5 ranking for maturity.

  • ‘Level 1’ could be that the task is documented and complete, but it is not very refined and does not have an explanation of the methods or completion dates. 
  • ‘Level 3’ could be a refined document that is more in the format of a formal report but there are no references or statements from your c-suite or legal department.
  • ‘Level 5’ could be a document that is ready – as-is – for anyone to immediately review and you already have the authorized release statements (e.g., who can release what level of detail to what specific entities).

Organic Product Fraud Audit Guide

We developed training video and materials for the Organic Trade Association (OTA) and the US Department of Agriculture/ National Organic Program. There are an additional ten questions to meet the organic product fraud compliance requirements (and see the Primer on Organic Product Fraud Prevention.) This covers all organic products, not just organic food. Whether you are reviewing organic products or not, these additional questions could be valuable:

Optimal Inspection Plan: Part II – A. Documentation and Methods

Building upon the broader product fraud and food fraud concepts, there are more specific organic questions:

  • Part II – A: Documentation
  • Do you have a map or inventory of their organic supply chain? (Y/N)
  • Do you have a supplier and product verification process to confirm, on an ongoing basis, the approved organic status of any product they use? (Y/N)
  • Can you demonstrate an audit trace-back of a product selected by the inspector? (Y/N)
  • Can you demonstrate sufficient organic inventory via mass balance audits? (Y/N)
  • Have you utilized an organic industry private initiative, method, or tool (e.g., GFSI Requirements, OTA Organic Fraud Prevention Solutions)? (Y/N)

Optimal Inspection Plan: Part II – B. Implementation

Building upon the broader product fraud and food fraud concepts, there are more specific organic questions:

  • Part II – B: Implementation
  • Have you identified organic critical control points in their organic supply chain where organic fraud or loss of organic status is most likely to occur? (Y/N)
  • Have you developed organic mitigation measures to mitigate organic vulnerabilities? (Y/N)
  • Have you integrated and documented their organic fraud prevention activities in their Organic System Plan? (Y/N)
  • Do you have a training program for their employees that includes organic fraud prevention? (Y/N)
  • Do you have a process for reporting suspected organic fraud to certifying agents and the National Organic Program? (Y/N)

Takeaway Points

  • A gap analysis is a routine and strategy management activity – it’s a proactive way to confirm you are still compliant and efficient.
  • There are many resources and gap analysis surveys – for example, see our gap analysis survey in our Primer on Food Fraud Compliance.
  • A basic food fraud gap analysis can be a pretty simple with just a ten yes or no questions – or expand the answers to give yourself a rating such as 1 to 5.

Reference:

Additional Resources

For more on the GFSI related food fraud prevention requirements, see:

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