Organic Product Fraud – Gap Analysis in 20 Questions

Possibly due to the rapidly changing and growing food fraud vulnerability from COVID and now Ukraine-Russia related inflation, there are more questions coming up about what is ‘enough’ for a Food Fraud Prevention Strategy. Our ‘Organic Product Fraud Gap Analysis in 20 Questions’ is a great place to start.

Following up on our August 2021 announcement of the published ‘Primer on Organic Product Fraud Audit Guide’ this blog post is a reminder of the ’20 questions’ in that primer. By reviewing the ‘20 questions’ you identify gaps in your strategy. By responding to each question you are conducting a formal ‘gap analysis’ – a gap analysis is a structured method to review the full compliance requirements with the goal being to see where there might be a ‘gap’ in your full compliance.

A gap analysis is a great way to start – or restart – a food fraud prevention strategy. The gap analysis can clarify where you are and where you need to go.

The primer was created in support of our work with the Organic Trade Association (OTA) to co-create the USDA National Organic Program free video training on Organic Fraud and the Criminal Mind and Organic Product Fraud Prevention (see this link for more information or to registration).

Compliance and the Organic Product Fraud Training Courses

Before looking at the list of questions, let’s do a brief review of the organic fraud training courses to make sure that readers realize its important features:

USDA training created to train USDA Inspectors and Certifiers.
Published on the USDA.gov website and posted in the USDA Organic Integrity Learning Center training catalog.
This is how USDA Inspectors and Certifiers are trained.
If you want to know what the USDA Inspectors are looking for when they visit you, you can take the exact same training course.
The USDA organic product fraud training courses are free, online, and on-demand.

Primer on Organic Product Fraud Audit Guide

This is a basic starting point for a USDA inspection or compliance audit.

Organic product fraud has become a more important focus for USDA inspectors, USDA certifiers, auditors, and those companies complying with the requirements. This application to organic product fraud prevention builds upon previous food fraud prevention research. This is aligned with the Global Food Safety Initiative (GFSI) scope and a wide range of other compliance requirements such as the Sarbanes-Oxley Act and the Food Safety Modernization Act (FSMA). The first step for implementing a new management system such as fraud prevention is to “just get started” and create opportunities for continuous improvement. As with the GFSI requirements, a “yes or no” survey is an efficient and optimal way to start broad compliance and adoption efforts. This primer document includes the Organic Product Fraud Inspection Survey Questions.

For Considering “Organic Fraud and the Criminal Mind”

The role of the USDA inspector:
- Be clear and firm in asking for vulnerability assessments and product fraud prevention strategies.
- The depth of documents and inspections will refine over time.
Specific SOPs that will help an inspection:
- Define and share the questions and requirements.
- Use related product fraud and criminal investigation methods.
Awareness of best practices that are being implemented by industry.
- Many programs cover various aspects of a fraud prevention plan — consider how these other programs are defined to help reduce the fraud opportunity.

Optimal Inspection Plan: Part I – Simple Questions about the Scope

GFSI Food Fraud Compliance Requirements adapted for Organic Product Fraud (asking “yes or no” questions to start):

Have they conducted at least one organic fraud vulnerability assessment (Y/N)
Is this documented (written) (Y/N)
Have they developed an organic fraud prevention plan (Y/N)
Is this documented (written) and incorporated into the Organic System Plan (Y/N)
Can they demonstrate effective implementation (Y/N)
Do they have executive-level sign-off (Y/N)
Have they minimally conducted an annual organic product fraud incident review (Y/N)
Do they have a method to review their incidents and general market incidents (Y/N)
Do they address all types of organic product fraud (Y/N)
Do they address all products from both incoming goods (e.g., ingredients) and outgoing goods (e.g., finished goods) through to the consumer (Y/N)

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:

Do they have a map or inventory of their organic supply chain (Y/N)
Do they 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 they demonstrate an audit trace-back of a product selected by the inspector (Y/N)
Can they demonstrate sufficient organic inventory via mass balance audits (Y/N)
Have they 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:

Have they 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 they developed organic mitigation measures to mitigate organic vulnerabilities (Y/N)
Have they integrated and documented their organic fraud prevention activities in their Organic System Plan (Y/N)
Do they have a training program for their employees that includes organic fraud prevention (Y/N)
Do they have a process for reporting suspected organic fraud to certifying agents and the National Organic Program (Y/N)

Takeaway Points

This is just a simple set of yes or no questions. It is just a process check and no commitment of any kind.
If you cover food fraud but have not expanded to organic fraud, this is a great starting point to check your depth of implementation.
Finally, if you produce or use products that are Certified USDA Organic, then it is wise to check yourself against the basic USDA Inspection checklist.