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Food Safety Standards and Regulations

Government of India is in the process of establishing Food Safety and Standards Authority of India (FSSA). Subsequently rule making process will start to develop suitable rules as per the new Food Safety and Standards Act passed by the Parliament of India. India is a signatory to WTO agreements and also a member of many treaties which are important to facilitate trade and development while protecting stakeholders' respective interest. New scientific evidences are also emerging around the world. Indian food safety and standards act must consider all these in order to have an effective food regulatory regime that supports and promotes innovation, trade and investment in Indian food and related sector without compromising food safety for its population and at the same time should not face trade barriers while exporting products to other countries.

The new food safety and standards laws must also facilitate speedier implementation of equivalence treaties, free trade agreements and agenda agreed by India at WTO Forums. Every individual/entity living in India will have impact of any changes in food safety and regulations. The biggest challenge is to get the views and feedback of various stakeholders specifically of those who are not part of organised industry associations and consumer groups but have major stake in food sector either for income generation, nutritional needs, or any need for special dietary requirements. Otherwise, majority of stakeholders will not get a chance to participate in deliberations and discussions in such crucial matters where their livelihood is at stake, where the individual interest is involved. It is thus important to have a forum which has high accessibility at all times, easy to reach, low in cost, reliable and also operates on real time basis so that whosoever wants to express their views can do so with least barriers and hassles. I could only think of Solution Exchange Food and Nutrition Security Community of Practice to get such wider choices of views, expertise and inputs.

Therefore, an action group was proposed in the recently held Resource Group meeting of the community to deal with the issues which are relevant to the new Food Safety and Standards Authority of India and emerging food regulatory environment in the country.

The discussion is intended to be structured in four parts viz; (1) Food Safety, (2) Effective Enforcement (3) Trade Norms, and (4) Stakeholder Participation. We could take up the discussion one after the other. The categories and queries mentioned are indicative and members are welcome to raise any further items for inclusion in this regard. However, a focussed approach is very much appreciated for the sake of through analysis and identification of issues and structured outcome. As the Government of India has appointed the Chairman for the Food Safety and Standards Authority of India recently, the discussion outcomes would timely feed into the process of this new Authority.

Food safety regulations or norms are of paramount importance not only to take care of the health and well-being of the domestic consumers but also to facilitate unhindered trading in the conventional foods and related products in the global markets. In this regard, food safety norms have to be specified for all processed and packaged conventional foods; beverages including sports drink, energy drink and wellness drink; organic foods; edible oils etc.

In the case of processed foods and particularly those being claimed as health foods the norms shall cover not only for the traditional nutrients such as carbohydrates, fats, proteins, minerals and vitamins, but also for such ingredients that may provide health benefit such as phytochemicals or neutraceuticals. It is also essential to indicate whether the foods contain GM ingredient.

The market for sports drink, energy drink, wellness drink etc. is steadily on the increase. The contents of caffeine, vitamins and minerals are to be specified besides the freedom from GM organisms and whether organic or not.

In the case of edible oils apart from the principal physical characteristics the percentage fatty acid composition has to be specified. Necessarily the norms shall be for the percentage composition of short and medium chain fatty acids (12 carbons or less), monounsaturated and polyunsaturated fatty acids instead of the routine classification of saturates and unsaturates.

The norms for organic foods shall stipulate absence of pesticides/herbicides, absence of harmful bacteria, absence of synthetic fertilizers and plant protection chemicals and freedom from GM organisms. It is also desirable to prescribe standards for green foods, which are not organic but produced in a nature-friendly manner.

Guiding Principles of Food safety:

A discussion on general principles is to understand the approaches which are available for the country to exercise a choice within is own legal and social framework. Apart from the international guiding principles on food safety, in the Indian context an important issue is the antiquity of food safety issues. In India, food safety principles were followed since time immemorial. The concept of "Madi" or religious purity (not allowing anybody to touch the cook or enter the area, during the process of cooking), the concept of "Juta" (e.g. drinking water from the glass without touching the lips so as to avoid contamination with oral bacteria), drinking only boiled milk, not tasting food by licking fingers etc are relevant even today. Hence, the time tested scientific tradition should find a place as a guiding principle. Historical treatises such as Chankyas Arthshastra provide us with valuable information on food safety issues. For examples, it mentions supervising the food preparation in a well guarded locality by the head cook to the king, testing of the food by feeding it to birds before giving it to the king so as to avoid poison in foods, fines to be imposed for selling rotten flesh etc.

Sampling and Analysis

Sampling of foods by food inspectors should be at random, as consumers pick their goods. Only for research studies, the sampling should be on statistical methodology. Samples of high risk commodities for adulteration should be lifted more. An earlier study by us has found that the most adulterated commodity are oils followed by spices, milk, sweets, cereals and cereal products, ghee, tea and milk products. While analysing priority should be given to different classes of adulterants such as coal tar dyes, cheaper oils, cheaper agricultural products, chemicals, extraneous matter and meal contaminants. (Sudershan R V and Bhat R V J Food Sci Technol 32: 368-372, 1995). From time to time, depending on the pattern of adulteration the lists could modified. The meager resources available for analysis should not be wasted in indiscriminately analysing samples.

Provision of Public finance:

The workshop on National Strategy for Food Quality Control held at the National Institute of Nutrition, Hyderabad during October 12-16, 1981 (National Strategy for Food Quality Control, Ed Ramesh V Bhat and B S Narasinga Rao, 1985, NIN, Hyderabad, pages 207) had recommended that a statutory National Food Quality Control Board be established. It had called for the establishment of a Food Quality Improvement Fund with authorization for the Board to levy the cess on the food industry at such scale as decided by the Government in consultation with the State Governments. The fund be utilized for the improvement of quality of food especially by the small scale sector. The suggestion made quarter century ago is valid even today, as exemplified by the recent acceptance of the suggestion on independent Food Safety Authority by the Government. The Commerce Ministry levy of export cess also could be another model to raise finances. Whenever an application is filed before the Central Committee for Food Standards (CCFS) for permission for the addition of a food additive, specified fee could be charged.

Food adulteration is a crime against humanity. It requires concerted efforts on several fronts.

  • Basic understanding of food safety issues by the consumers and practical knowledge on choosing safe products
  • Rapid methods of precise and accurate monitoring of adulterants
  • Products standardization and Good Processing Practices by the food processing industry
  • Safe supply chain practices
  • Strict policy framework promoting manufacturing and trade of safe and high quality food
  • Strict implementation of policies
  • Periodic review of policies and implementation plans in the light of new scientific knowledge that might have become available.