Guest Blog by Food Journalist Paul Gander
Food fraud is problematic. Unless yours is a vertically-integrated food & drink business which runs the entirety of its own ingredients sourcing operation from field to fork-lift, there will always be doubts and concerns about the supply chain.
Periodically, scares and scandals about upstream criminal adulteration – from melamine in milk powder to horse meat – do a particularly good job of eroding consumer and retailer confidence. Out of the 2013 horse meat debacle came the Elliott report and its key recommendation that a National Food Crime Unit (NFCU) be set up in the UK. But, given the Government’s response to that report, is this the best way to shore up downstream confidence, both among manufacturers and their customers?
Apparently in ‘listening mode’, the Government did indeed establish the NFCU under the auspices of the Food Standards Agency (FSA), and last year appointed the experienced Andy Morling as its head.
Several months into his new job, Morling admitted to me that there were serious gaps in the unit’s understanding of the threat from food crime in Britain. That is to be expected, at this stage. Less easy to accept has been the suggestion by the FSA that the NFCU may never have full investigatory powers.
If there is an episode of the Keystone Cops where the cops themselves – rather than the criminals – are handcuffed, this sounds like it. Coincidentally, one insider who worked on the Elliott report did confide that he saw the whole thing as a ‘classic Whitehall farce’ designed to kick the question of food fraud into touch. Let’s hope the drama does not shift from comedy to tragedy.
On a practical note, Morling wondered whether the principles of situational crime prevention (SCP) could be applied to the food arena. For anyone not familiar with it, SCP is defined by Cambridge University’s Institute of Criminology as any strategy aiming to reduce criminal opportunities rooted in everyday routines.
The institute cites CCTV as a prime example of SCP in action. But what would the equivalent be in a food fraud setting?
If we cannot literally ‘watch’ our suppliers every minute of every day, we can collect, collate and access data about them; and data, it could be argued, is the ‘CCTV’ of supply-chain security.
Manufacturers will have to judge how much testing of ingredient consignments (and what sort of testing) should be carried out. At the same time, they are likely to be extremely reliant on third-party auditing and certification at source. Diligent data collection may throw up worrying trends and anomalies among suppliers or their ingredient specifications. This in turn may allow businesses to step in early to avert more serious consequences.
Of course, neither frequent testing nor auditing is likely to produce direct evidence of wrongdoing. That is beside the point. The primary role of a speed camera, for example, and its role from an SCP perspective, is to deter speeding.
It has been said that the food industry supply chain operates on the basis of quality assurance rather than quality control. But ‘assurance’ can (and in many cases should) be improved. Going beyond the legal minimum with overt test procedures and the active use of third-party certification must help to deter fraud, while also reassuring customers.
On this last point, as with the creation of the NFCU (a cynic might say), it would be difficult to separate out the tangible and practical benefits from the ‘soft’ – and, in the case of the NFCU, political – benefit of simply being seen to be doing something.
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