By: Dr. K.V. Satyanarayana*
Different food safety hazards can arise across the ‘farm to fork’ value chain and, thus, monitoring and control should take place at multiple points. Some hazards can only be controlled at farm level, for example, pesticide residues in plant sourced foods and antimicrobial residues in animal sourced foods. For biological hazards, controls may be needed at multiple stages – from raising crops or animals and post-harvest or post-slaughter practices to processing and consumption – in order to significantly reduce the risk of food borne diseases. The One Health approach considers the complete ‘farm to fork’ chain along with cross-sectoral collaboration in significantly improving food safety.
Adopting Required Research Priorities, Policy Frameworks and Practices in Food Safety
The Food Safety and Standard Act, 2006 (FSS, 2006) stipulates the limits for “contaminants, naturally occurring toxic substances, heavy metals, etc.” and “pesticides, veterinary drugs residues, antibiotic residues and microbiological counts, etc.” in food. The FSS (Contaminants, Toxins and Residues) Regulations, 2011 only has standards for antibiotics in fisheries and honey and currently, there is no regulation for use of antibiotics in livestock in India. In November 2017, FSSAI amended the draft notification specifying tolerance limit for antibiotics and other veterinary drugs used in livestock. Hopefully, this regulation will be finalized soon after consultations with various stakeholders.
There is a need for drafting convergent policy frameworks for implementing the One Health initiative in the country. Creating a framework for strengthening surveillance of and response to food-borne diseases in India by fostering multi-sectoral collaboration, especially in the animal and agriculture sectors, is the need of the hour. Epidemiology, surveillance, and food monitoring and testing infrastructure are required for implementing effective food safety systems in the country.
There are some global initiatives like whole genome sequencing across different sectors for enhanced One Health surveillance of food-borne diseases and India, too, should play an active role in this initiative by building the required capacities and infrastructure.
The Market Scenario in India
India exports fresh and processed food products to several countries, valued at around $0.40 billion in 2016-17. Many developed countries impose more stringent standards than globally acceptable standards, such as the Codex Alimentarius standards which act as non-tariff barriers to exports from India. Examples include MRLs for pesticide-commodity combinations, limits for mycotoxins, etc. Several Indian consignments to the US and the EU have faced rejections due to the presence of higher than approved levels of pesticide residue/other contaminants.
Some countries have additional pre-compliance requirements. National Residue Control Plan (NRCP) and Annual Residue Monitoring Plans (RMP) are statutory requirements for exporting to EU countries and are being implemented by the Export Inspection Council (EIC) of India. The Indian dairy industry is predominantly unorganised, with only 20% of milk production being routed through the organised channels of dairy co-operatives and private dairies. Approximately 75 million rural households are engaged in dairy production, with an average herd of 2 animals; most of these are low input/low output farms.
There is low awareness among these dairy farmers about animal health, and vaccination and healthcare of cattle depends on government extension programs. India exports fresh and processed food products to several countries, valued at around $0.40 billion in 2016-17.
Many developed countries impose more stringent standards than globally acceptable standards, such as the Codex Alimentarius standards which act as non-tariff barriers to exports from India. Examples include MRLs for pesticide-commodity combinations, limits for mycotoxins, etc. Some countries have additional pre-compliance requirements. National Residue Control Plan (NRCP) and Annual Residue Monitoring Plans (RMP) are statutory requirements for exporting to EU countries and are being implemented by the Export Inspection Council (EIC) of India.
Melamine & Histamine: Restriction or Tolerance Limit in Food
Section 2.5 of FSS (Contaminants, Toxins & Residues) Regulations, 2011 [of FSSA, 2006] prescribes a maximum permitted level of Melamine in powdered infant formula, liquid infant formula and other foods. This section also lists fish species that have the potential to cause histamine poisoning and prescribes the permitted limits of Histamine in various fish and fishery products.
Laying down science-based standards for articles of food
Food safety standards should be scientifically based, instead of being based on public perceptions and opinions. There is a risk assessment framework built into various national regulations. Codex Alimentarius guidelines/recommendations help in ensuring the harmonisation of food safety standards across different countries.
With the growing importance of export markets in mind, several exporters and Indian farmers have started implementing measures such as Good Agricultural Practices (GAP) and traceability, and adopted various voluntary standards for food safety and quality systems to meet export market requirements. Preventive approaches such as the Hazard Analysis Critical Control Point System (HACCP) have resulted in the industry taking greater responsibility for and control of food safety risks.
*Leads the Food Processing and Retail practice at Sathguru Management Consultants