Food Standards Scotland and UK FSA Conference Summary: “Food Authenticity and Crime”

This conference summary provides important insight on enforcement and prosecution of food fraud prevention. Leaders from the Food Standards Scotland (FSS) and UK Food Standards Agency (UK FSA) provided specific strategies and priorities. I presented a country-level vulnerability assessment method.

The UK Global Food Safety Incidents and Emergency Response Conference was hosted by Food Standards Scotland and the UK Food Standards Agency on October 13-15, 2021. I presented in Breakout Session 3: Food Authenticity and Crime. Free video on demand is available at:

I am honored to have been on a panel with such esteemed thought leaders. Our session was chaired by Professor Chris Elliott (Queen’s University Belfast). My other speaker colleagues included Steve Barras (the UK Publicly Available Standards – PAS), Giles Chapman (Head of Analysis, National Food Crime Unit UK = UK NFCU), Ron McNaughton (Head of Food Crime and Incidents, Scottish Food Crime and Incidents Unit), and Peter Whelan (Director of Audit and Investigations, Food Safety Authority of Ireland – FSAI).

Summary of Our Session: Food Authenticity and Crime

  • There is a continuing evolution in standards such as “Food and Drink Defense — UK Publicly Available Standard 96 (PAS96)”. This standard focuses on malicious attacks (food defense) with a deepening focus on hazards and threats. Beyond identification, they are expanding the insight on the hazard and threat characteristics and response.
  • The UK and Scotland gave a joint presentation of their coordinated approach. Their focus is “serious fraud and related criminality in food supply chains.” It was important to note their categories since this correlates with their enforcement and investigation priorities. Two very specific categories were waste diversion and document fraud (e.g., their full list was: “Theft, waste diversion, substitution, document fraud, unlawful processing, adulteration, and misrepresentation.”)
  • The FSAI provided an update on European Union court cases and the evolving needs for investigation and prosecution. The burden of proof is increasing as the prosecutors are shifting from commercial to criminal laws. The burden of proof increases from a “balance of probability to beyond a reasonable doubt.”
  • Professor Elliott moderated a discussion that covered the role of consumers in food fraud prevention and the ever-present EU/ UK subject of Brexit. There are specific challenges on the Island of Ireland with the land border between Ireland and Northern Ireland (for those of you who may not know, while the Ireland/ Northern Ireland border is now again an international divide, in practice, it is more like the border between two states in the USA).

 Other Breakout Sessions Included:  

  • Breakout session 1: Surveillance with topics of how surveillance can be used, how data can be used, and how horizon scanning can be used.
  • Breakout session 2: New technologies in incident management with topics of what are the new technologies? What are the challenges? And What can we learn from behaviors?
  • Breakout session 4: Outbreak investigations with topics of outbreak investigations, the use of whole genome sequencing, and harmonisation of practice.
  • Breakout session 5: Risk communication with topics of outbreak investigations, the use of whole genome sequencing, and harmonisation of practice.

Summary of My Presentation: Food Fraud Prevention – A Country-Level Approach

My presentation provided more general insight on how to combine all the information presented in the session into a country-level food fraud vulnerability assessment. The best practices include leveraging COSO/ Enterprise Risk Management for the overall strategy. Then, the first step is conducting an initial screening or pre-filter to get started.

Recommendations for Countries (or Companies):

  1. Seek a method and training to conduct a basic vulnerability assessment and critical control point plan (VACCP) and a food fraud vulnerability assessment (FFVA)
  2. Consolidate information on incidents
  3. Consolidate information on the root cause of system weaknesses (vulnerabilities).
  4. Shift focus to crime prevention
    1. Conduct a country-level food fraud initial screening
    2. Apply the vulnerabilities to a supply chain map to conduct the criminology “hot spot analysis”
    3. And after completing those steps, consider countermeasures and control systems in a food fraud prevention strategy

Our breakout session was an excellent update on the international food fraud prevention activities. We provided some foundation, key new considerations, and a method to get started through this breakout session. Now that there are resources dedicated to governments’ food fraud prevention problem, it is a good time for collaborative process improvement.

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