Food fraud, or the act of defrauding buyers of food or ingredients for economic gain, has plagued the food industry throughout history. Although it is not known conclusively how widespread food fraud is in the United States or worldwide, it is now estimated to be a $50 billion industry for the total food market --about the same size as the entire 2017 U.S. organic market. Although the act of adulterating food for economic gain dates back to at least the Middle Ages, its presence in the global organic supply chain is more recent, and poses a significant threat to the integrity of the organic brand.
For the past two years, the Organic Trade Association has prioritized significant time and resources into organic fraud prevention solutions that will help mitigate and prevent the occurrence inside and outside of the United States. Our work to address organic fraud is taking place on several fronts ranging from our farm bill priorities, to our member task force action to shape a major piece of National Organic Program (NOP) enforcement rulemaking slated for spring 2019, to our major private-sector initiative that has evolved into an industry-wide fraud prevention program set to launch this spring.
Before diving into our organic fraud prevention program, let’s take a look at the steps we took to get here.
GOSCI Task Force and Best Practices Guide
In May 2017, the Organic Trade Association convened a Global Organic Supply Chain Integrity (GOSCI) Task force of 48-member companies to develop a best-practices guide to preventing fraud specifically for the organic industry. In an effort to both acknowledge and utilize the extensive fraud prevention strategies already developed by Michigan State Food Fraud Think Tank and the Global Food Safety Initiative (GFSI), the task force adopted a model that highlights the motivation behind fraud (i.e. the root cause) to better understand the detection and prevention activities that need to be developed based on a company’s susceptibility or exposure to food fraud risk. The GFSI model is a smart and practical approach because it was built to be a starting point consistent with other quality management practices such as HACCP (Hazard Analysis and Critical Control Points), lending itself to a fraud prevention program that can be adopted into existing internal quality management systems. While the traditional HACCP-type food safety approach is applied at manufacturing steps, food fraud vulnerabilities are company-wide, and must be applied cross-functionally and within the overall organization.
The Guide developed by the task force is aimed at buyer responsibility and the assessment of factors that create vulnerabilities in an organic supply chain. Accordingly, the Guide provides businesses engaged in the organic trade with a systematic risk-based approach for identifying appropriate fraud mitigation measures, and developing and operationalizing a written Organic Fraud Prevention Plan. It also includes information on what to do when you suspect or detect fraud along with resources and helpful tools for identifying and deterring fraud.
GOSCI ‘Pilot Project’
Following the creation of the Guide, the trade association launched a pilot program. The pilot was an intensive-focused exercise running from June – September 2018 in which 13 OTA member companies “test drove” in their specific businesses the fraud prevention strategies described in the Guide. Participants concentrated on one product or ingredient and developed fraud mitigation measures based on the results of a vulnerability assessment that identifies weak points in a supply chain that increase exposure to fraud. Pilot participants informed the final version of the Guide and helped set the stage for implementing a corresponding program. Collaborating partners in the project included USDA-NOP, the Accredited Certifiers Association (ACA) and NSF International.
Organic Fraud Prevention Solutions
With a tested and completed fraud prevention guide in hand, the Organic Trade Association has developed an organic fraud prevention program in which organic businesses may voluntarily enroll. The mission of the program is to assure the authenticity of organic products by mitigating the occurrence of organic fraud. The goal of the program is to establish a framework and formal process for businesses to create continuously improving internal programs for achieving organic integrity throughout their associated supply chains. The program requires training, registration and the development of an organic fraud prevention plan, followed by confirmation and public acknowledgment of enrollment. The program is not a certification or verification program nor is it a product label. Instead, the program serves as a business-to-business marketing advantage designed to improve internal quality assurance programs. It is also designed to complement and reinforce USDA’s organic standards and the work of the accredited certifying agencies.
It is critical that distributors, traders and holders of organic brands have systems and measures in place that adequately support the promise of providing organic food that people can trust. The Organic Trade Association’s program, as adopted by businesses engaged in organic trade, will become the industry standard reference for excellence and achieving integrity across complex organic global supply chains. The more companies that join, the stronger the organic supply chain will become.
If you are interested in learning more or signing up for the Organic Fraud Prevention Solutions program, please contact Gwendolyn Wyard. //
Gwendolyn Wyard is Vice President of Regulatory and Technical Affairs for the Organic Trade Association (firstname.lastname@example.org).