Despite the common belief that food fraud in the United States is a rarity, the globalized nature of our food supply chain means many of our favorite foods and ingredients travel far and wide before they reach our plates, making adulteration and other types of food fraud a considerate problem here as well. And it’s not just one food being called another (e.g. escolar as tuna) that we need to worry about. Many of the foods we consume every day are filled with ingredients that aren’t supposed to be there. Food fraud occurs with varying frequency in foods across the board—oils, dairy, meats, alcohol, sweeteners, spices and more. As much as food fraud is a cost-driven economic issue, it’s important to remember that it is also a public health issue. Much adulteration involves unconventional contaminants that we know little about, making the health risks difficult to quantify yet still substantially problematic, and also hard to address. “Food fraud is complex,” says John Spink, director of the Food Fraud Initiative at Michigan State University, in an interview. “It happens because bad guys are good at finding small gaps.” In a recent revision to Food Safety Modernization Act (FSMA) rules, currently open for public comment, the U.S. Food and Drug Administration proposes to address economically motivated adulteration (EMA) within the preventive controls rule rather than within the intentional adulteration rule. FDA suggests a focus on adulterants that are most likely to cause illness, as well as on circumstances where there has been a pattern of adulteration in the past. The problem with this thinking, explains Karen Everstine, research associate at the National Center for Food Protection and Defense at the University of Minnesota, is that historically, many of the most impactful adulterants have been the ones that no one expected. After all, most cases of adulteration are organized by experienced criminals who work hard to avoid detection. Take, for example, the Chinese milk scandal in 2008 when six people died and hundreds of thousands were sickened by milk products adulterated with melamine. Yet, prior to the incident, authorities and stakeholders were unaware of any potential problems surrounding the adulterant at hand. This is why proactive, rather than reactive, thinking is important in food fraud prevention efforts. Instead of simply testing products for adulterants, this could mean working to think more like a criminal, Everstine says. U.S. companies looking to prevent food fraud in the products they source from overseas are increasingly turning to food fraud vulnerability assessments, which identify and investigate parts of a food supply chain most likely to be subject to food fraud incidents. These assessments look at factors including supply chain characteristics, relationships with suppliers’ quality assurance measures, fraud history, economic indicators and geopolitics, always looking to identify opportunities for fraud before it can happen. “We try to determine why a criminal would perceive a crime opportunity,” Spink says. “When we understand that motivation we can try to put systems in place to prevent it.” Vulnerability assessments sometimes involve looking at large amounts of data, such as hundreds of seemingly random incidents that when analyzed together may cluster into groups and help stakeholders focus on areas of concern. Everstine believes big data has potential to play an important role in addressing food fraud in the future. For example, a protected data platform that facilitates data sharing between industry and government could be helpful for gathering intelligence. “Its about finding a way to tackle the problem together and share the intelligence that will give people a way to proactively address things,” Everstine says. A food fraud detection and prevention company called Inscatech conducts on-the-ground food fraud intelligence investigations as a way of getting closer to the root of the problem. The company employs a network of undercover operatives around the world who discretely investigate food fraud on behalf of many large U.S.-based companies that are concerned about the authenticity and safety of the foods they import. Some companies are proactive when it comes to making these investigations happen, but other companies remain more passive, worrying an investigation has the potential to open a costly and complex can of worms. One way of reducing food fraud is to encourage companies to be more diligent about conducting background screenings of their suppliers, says Mitchell Weinberg, president and CEO at Inscatech. For example, if a commodity is cheaper than average, the buyer might want to figure out whether food fraud played a role in driving down that price. “If companies were to source as much as possible in the U.S., our foods would be much safer,” Weinberg says. “But our industry is driven by costs, so they are going to markets outside the U.S.”