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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
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.