This is an extension of our previous blog post on a food safety contaminant Early Warning Systems (EWS). Catching problems (detection of risks and mitigation) is essential, but the focus should be on the proactive approach (reducing vulnerabilities and prevention). Remember, the goal is not to catch food fraud but to prevent it from occurring in the first place.
When taking action to address a risk or vulnerability, there are two starting points that include responding to an event or conducting an over-arching risk management review. The first – and the usual – starting point is directly responding to a problem. An event occurs, and then you must take action. The first ‘operational’ step is to find the unacceptable product, for example, and get it out of the supply chain. Then, the often-final ‘tactical’ step is to put some type of countermeasure or control system in place to either fix or prevent the problem from occurring again. Usually, there is no additional ‘strategic’ step that considers if there are other factors to address, such as if the root cause of the problem could be present in other products or supply chains. This ‘strategic’ step is really the most important from an overall, enterprise-wide perspective. If you take the time to review a few other root causes, you will probably avoid the same problem occurring over and over again. The second approach is when there is a general review of risks. This is a top-down approach that is often in response to an enterprise-wide risk management program.
Operational/ Tactical/ Strategic
Based on basic business theories, there are several levels of planning or action:
- Operational: immediate and day-to-day focused activities often responding to changing conditions. The focus is on the execution of a plan or a strategy.
- Tactical: intermediate and longer-term focused activities that improve the efficiency of the ‘operational’ activities but are in alignment with the ‘strategic’ plan. The focus is more on procedures that help improve or streamline the operational activities.
- Strategic: long-term and future-focused activities that support the continued success of the enterprise in meeting its goals regardless of the changing marketplace or financial environment. The focus is more on a policy that helps the entire enterprise become more efficient, including staying in business and considering ‘what business should we be in.’
The Trigger for Prevention
We do not set out to prevent everything. Our focus is to prevent problems that have been identified and prioritized as significant. There are two ways that a problem is identified and responded to. First is the reactive response to a problem or an event. For food fraud prevention a food fraud prevention strategy could be developed in response to a single or series of incidents (e.g., species swapping in ground meat). The second is when there is a general review of risks or vulnerabilities. For food fraud prevention, this could be the overall awareness of the vulnerability or an initiative such as meeting new external or internal compliance requirements (e.g., the GFSI food safety management system requirements implemented through FSSC 22000, SQF, BRC/BRCGS, IFS, and others). Whatever the starting point, it is most efficient to not only address the urgent issue (e.g., species swapping in meat or a compliance requirement) but also to take the additional step beyond the operational approach and also to consider tactical and strategic issues.
Mitigation to Prevention and Risk to Vulnerability
We felt that the mitigation to prevention and risk to vulnerability question was so important that we wrote an entire scholarly journal on the topic (Spink J, Ortega D, Chen C, Wu F (2017). Food Fraud Prevention Shifts the Food Risk Focus to Vulnerability. Trends in Food Science & Technology 62:215-20).
- Mitigation: This focuses on reducing the impact of an event and assumes the event will occur. While this is – of course – important, the goal is not to be just quick at responding but to prevent the event from occurring in the first place.
- Prevention: This focuses on identifying and minimizing or eliminating the root cause of an adverse event or a problem. While in most situations, this is admittedly aspirational, it is still the goal.
Then, another important concept is risk versus vulnerability:
- Risk: is an uncertainty of an outcome that is assessed in terms of likelihood and consequence (see the Glossary of Food Fraud Related Terms for more details.
- Vulnerability: is a weakness or flaw that creates opportunities for undesirable events related to the system
When dealing with new or rapidly emerging issues such as food fraud, it is important to understand the risks (e.g., events that occur, such as melamine in infant formula or pet food), but there is always a difficult question of what the next incident is. A focus on vulnerability (e.g., reliance on a certificate of analysis versus conducting your own identity tests) provides a broader focus that target hardens an entire supply chain against a wide range of problems regardless of the individual risk.
Food Fraud: Operational, Tactical, and Strategic Responses
Taking all the previously discussed concepts into consideration, there is a range of activities that support the overall programs.
- Early Warning System (Mitigation, risk): As covered in our previous blog post and in more detail in the Food Fraud Prevention textbook, a traditional food safety Early Warning System focuses on the rapid detection of contaminants. This is an important ‘operational’ activity. This helps with mitigation and to address a risk.
- Team Procedures: This team is crucial to taking the information from the early warning system and conducting the operational activity of the recall and immediate corrective actions. This team also provides a second ‘tactical’ activity of examining the root cause and seeking procedural or process changes that reduce the vulnerability of this product.
- Prevention Strategy (horizon scanning and foresight methods[1], vulnerabilities): this highest level step is a policy-type activity that focuses on what was learned from the new incident as well as the root cause analysis, but also considers system-wide applications or recommendations. The goal is to continue to reduce the root causes and vulnerabilities so that future incidents are fewer and less impactful.
Takeaway Points
- The first food fraud efforts were to identify and detect the problem (“what is making babies and pets sick” and then “how to get the melamine-tainted products out of the supply chain quickly.”). While rapid detection of an active risk is crucial, there should be a focus on reducing the vulnerabilities that allow the problem to occur.
- When thinking of a food fraud prevention strategy – or the goal of any management system – there should be a balanced approach to operation, tactical, and strategic activities. Too often, we fight one fire and move on to the next before even considering fire prevention.
- As a key process step, make sure your Food Fraud Prevention team includes the later strategic review step, or even possibly mandate a management policy requirement that the FFP team confirms they have conducted this review and have submitted the findings to the responsible executive.
References:
[1] US National Library of Medicine, National Institute of Health, Book – Safeguarding the Bioeconomy, Chapter 6 Horizon Scanning and Foresight Methods, URL: https://www.ncbi.nlm.nih.gov/books/NBK556423/
And, US Department of Homeland Security, Horizon Scanning, URL: https://www.dhs.gov/science-and-technology/horizon-scanning
Blog Post: EXCERPT: Food Fraud Prevention Textbook – Early Warning Systems, August 17, 2021