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Current FSSR guidelines need to be evaluated in line with global trends
Monday, 17 August, 2020, 08 : 00 AM [IST]
Karan Chechi
By strengthening the Food Safety and Standards Act in 2006, India has taken a significant step towards creating a healthy food culture in the country. Ensuring the availability of safe and nutritious food for human consumption is the primary purpose of this Act, as set out in its preamble. Thus, the Act streamlines all food-related regulations and prompts a change from multi-level, multi-departmental restrictions on food safety and nutrition to an integrated policy line with an overarching policy structure on food safety and nutrition.

In 2008, the Food Safety and Standards Authority of India (FSSAI) was set up under the aegis of the Ministry of Health and Family Welfare to implement the provisions of the new legislation. Under the Act, the Food Authority serves as a Central reference point for all issues relating to food safety and quality in the country. The Food Authority guides and governs all persons engaged in the manufacture, import, transport, storage, distribution and retailing of food on food safety and nutrition issues, with primary responsibility for regulation primarily on the part of state food commissioners.

While a series of initiatives were launched from 2008 onwards, actual work within the Food Authority started successfully in 2011 following notification of the rules and six main regulations as follows:
?    2011:   
•    FSSAI rules and six key regulations notified.
•    Food import clearance system put in place.
•    Licensing and registration of food business started.
?    2012:
•    Milk survey done at national level.
•    Product approval guidelines.
•    Process of FSSAI notifying NABL accredited food testing laboratories initiated.
?    2013:
•    Notification and labelling of FSSAI licence number and logo on every food product label.
?    2014:
    •    Online food product approval system initiated.
?    2015:
•    Standards for NOTS and crop contaminants notified.
•    India (FSSAI) became the regional coordinator for Asia in Codex.
•    Operationalisation of FSSAI function at one port.
Since the process of licensing and registration of food business began in 2011, the number of food businesses that have been part of the FSSAI has gradually grown over the years. Requirement of the FSSAI logo and the number on all food items has enhanced the visibility of the Food Authority. However, as seen from the journey so far, progress was slow and steady until 2015. This dramatically increased in all fields of practice in 2016.

There are seven key actionable areas:
•    Food Standards  
•    Safe Food Practices
•    Food Safety Compliance
•    Food Testing  
•    Food Safety Training
•    Social and Behavioural Changes
•    Consumer Focus

Food Standards
Under the Food Safety and Standards Act, 2006, the FSSAI is responsible for agricultural requirements for food products and food health. Food health requirements are evaluated considering the latest advances in food science, food consumption habits, emerging products and additives, improvements in manufacturing technology and food analytical methods, and detection of new risks. The implementation of standards is being conducted by 17 research committees and a professional committee composed of more than 220 subject independent experts/scientists of eminence.

The formulation of standards for any food article includes a variety of steps. Following the recommendation of the scientific panel, a standard shall be accepted by the Food Authority following the due process developed, including the approval by the scientific committee where the draft notice is released for inviting public input and eventually notified requirements.
•    9 major regulations notified & placed
•    11,000 standards of provisions of food additives adopted


Scientific Panels

Additives, Process aids Scientific Panels Product Standards
(Food  Additives,
Flavourings,  Processing
Aids and Materials in
Contact with Food)
Fortified Foods Others  (Water  (Including flavoured water)  & Beverages (alcoholic & non-alcoholic)
(Fortified  Foods,  and
Enriched Foods)
GMO Labelling  and Claims Contaminants, etc. Sampling
(Genetically  Modified          Contaminants in Food Chain (Methods of Sampling and Analysis)
Organism and Foods) (Advertisements, and Labelling & Claims)        Biological hazards  
           Pesticides and Antibiotic  
    Residues  


Standard Review Groups (SGRs)
Various regulations under the Food Safety and Standards Act, 2006, were notified in 2011 and most of the food product requirements mentioned in the FSSR, 2011, are taken from the very old PFA Regulations, 1955. Owing to technical advancements, changing dietary habits and so on, current FSSR guidelines need to be evaluated in line with global trends, addressing both the needs of customers and the promotion of innovation by industry. There is a gap between national and international standards, as well as the needs of the industry and the knowledge available to the FSSAI / scientific panels on this issue. Keeping in view of facts, FSSAI has set up eight standards review groups as follows:
•    SRG I: Oil 7 Fats
•    SRG II: Milk & Milk Products
•    SRG III: Cereal Products including Bakery
•    SRG IV: Fruits, Veg and Spices
•    SRG V: Sweets & Confectionary
•    SRG VI: Meat & Fish Products
•    SRG VII: Beverages- Alcoholic Included
•    SRG VIII: Functional Foods, Nutraceuticals Dietetic  

These groups define the needs and all aspects of existing standards, taking into account the Indian and international contexts, aim at new specific standards that reduce regulatory burden, make it easier to understand and represent developments in scientific expertise in the areas of food processing and technology, nutrition, toxicology and allergenicity, and prepare a study report on the standards.

Promoting Research
The Food Authority also cooperates with numerous local national bodies and promotes new initiatives for research and development on food safety standards by offering financial assistance. Such research and development projects help to generate information that continually updates and improves food safety standards and the generation of data for standards setting MRL / ML benchmarking.

FSSAI has sanctioned 8 such projects to various ICMR, CSIR and ICAR institutes. Some of the major projects include:
•    Assessments of implication of khesari dal on human health and experimental Neurolathyrism in goats- ICMR (Indian Council of Medical Research)

•    Data generation on pesticides residue and mental contaminants in edible vegetable oils- CSIR (Council of Scientific and Industrial Research)

•    Pesticides and antibiotic residue in fish and fisheries projects- Evolving framework for fixation of MRLs-ICAR (Indian Council of Agricultural Research)

Food Safety Knowledge Assimilation Network - FSKAN
The FSKAN promotes the assimilation of scientific knowledge in the field of food safety and nutrition, detection of gaps and the funding of research projects in these gap areas.

The network approach helps to promote the ongoing growth and learning environment within the food industry, while developing ways and means of collecting creative inputs from the food industry at the same time.

Key objectives of FSKAN
1.    Creating a scientific community for collation of knowledge and expertise in a singular repository.
2.    Setting up a collaborative platform facility for scientific data collection and data sharing.
3.    Avoid duplication and divergent opinions, while ensuring rapid access to information.
4.    Extensive exposure of research findings on food safety issues.
5.    Joint projects with research partners.

Food Registration and Licence System (FLRS)
1.    To simplify the licensing and registration process, the manual procedure was replaced with an online Food Registration and License System (FLRS) by FSSAI in 2012 to serve as a single window for providing registration, Central licence, and state licence.

2.    The FLRS has been continuously developed to make it more user-friendly and facilitate ease of doing business. FLRS has managed to reach out to the FBOs and in the past few years owing to which, the number of FBOs applying for registration and licensing has grown.

3.    In addition to FLRS, FSSAI is also leveraging specific service centres (CSC-SPV) to promote the registration process for small-scale FBOs. The service is available via all CSCs across India.

Identifying for simplifying licensing and registration and Ease of Doing Business
?    IT initiatives:
•To bring transparency and productivity to handling, FSSAI has established an online IT Food Licensing Registration System (FLRS) in all states except Nagaland and also initiated the process of developing FLRS version 2.0.
?    Video Conferencing:
•To strengthen the communication with the state / UTs, FSSAI has facilitated a Video Conferencing (VC) session with the State / UTs food safety departments. Throughout the meetings, numerous state-specific issues are addressed and workable approaches to these problems are taken during the session. During 2016, this video conferencing was performed with 12 States / UTs.
New initiatives for compliance
?    Risk-Based Inspection System (RBIS):
•    Risk-based inspection (RBI) is a mechanism that defines, measures and maps industrial hazards that may threaten food health. RBI tackles the danger that can be regulated by careful inspection and review. Instead of safety inspection and safety or concept enforcement, it focusses on evaluating the safeguards set in place under operations to tackle the risk factors that might place food products at risk.

•    To establish an integrated approach to enforcement, FSSAI is implementing a RiskBased Approach (RBA) for inspection and surveillance in line with global standards. RBIS aims to improve and defend safe food supply and fair-trade practices and discourage fraudulent practices.
Objectives
•    Prevent unhealthy food from being put on the domestic market to protect the consumers in India.

•    To transition the food inspection system from a product-based process towards a risk-based method that can be used by food inspectors throughout the food industry, regardless of the food items being produced or manufactured.

•    Associating “Risk Grade “with licensing & registration system.
Convergence
The Food Authority was founded in recognition of this interconnectedness with an intent to resolve the uncertainty in the minds of consumers, traders and producers because of the multiplicity of food regulations enforced by various agencies. Thus, convergence happens to be the DNA of the Food Authority. FSSAI has maintained an integrated chain of control and a common reference point for all issues relating to food safety and nutrition, standards, regulations, and enforcement. It also deals with a variety of Central ministries / departments listed below:

Functional Domain Related Ministries and Departments

Research for Standard

Setting

Regulating Food

Safety

Training and Capacity

Building

Maintaining Food

Safety

Indian Council for Agricultural Research (ICAR)

Indian Council for Medical Research (ICMR),

CSIR

DST

Ministry of Urban Development

 

Ministry of Panchayati Raj

Ministry of Skill Development & Entrepreneurship

Department of Higher Education

Department of School Education

Ministry of Railways

 

Ministry of Civil Aviation




FSSAI
Supply Chain Related Ministries and Departments

Primary Production

Storage,

Transportation,

Distribution, and

Retail

Manufacturing and

Processing

Nutrition/Wholesale

Food

Ministry                         of

Agriculture,

Cooperation             and

Farmers             Welfare

Department of Food and Public Distribution

(Storage                          &

Transportation)

Ministry       of        Food

Processing

 

Department of School Education (Midday

Meal Scheme)

 

(Pesticides,     Residue,

Organic                 Foods,

Agmark)

 

Ministry of Animal Husbandry and

Fisheries     (Veterinary

Drug Residue)

Ministry                         of

Environment and Climate Change (GM Food Regulations)

 

Department of Consumers (Legal Metrology, Consumer

Connect)

 

Department of Commerce (Food Trade)

Department                 of

Industrial production and Promotion

 

Ministry of Micro and

Small Enterprises

Ministry of Women and        Child

Development (ICDS)

 

Department of Sports

(Sports and Nutrition)



Food Smart Cities
Moving ahead on the smart city plan, the Food Authority is creating a framework for smart food cities that will provide end - to - end solutions for urban food systems.

Rapid urbanisation has contributed to a range of core issues such as food security, food safety and environmental concerns. One way to tackle this is to incorporate sustainable food protection and nutrition systems into smart city design and create smart food cities. Also globally, the idea of a smart food city is still at a nascent stage and India has the opportunity to play a leading role in shifting perspective and approach around this critical problem, which is why FSSAI has collaborated with thought leaders in this area, such as the UK Food Foundation and the Swedish and Norwegian EAT Foundations.

This idea was co-developed with the Ministry of Urban Development and some smart cities, including Ludhiana, Ajmer, Bhubaneswar, Jaipur, New Delhi and Gurgaon.

There is a four-pillar approach to food smart city. It involves maintaining health and sanitation through the supply chain, improving nutrition, stimulating social and behavioural changes in customers, and reducing surplus food and promoting food loss recovery.

Roadmap for Future
Ever since the printing of FSSAI logo and licence number on food labels was made mandatory in 2013, FSSAI has become more and more visible. FSSAI has been successful in promoting trust among consumers. As of now, the main challenge for FSSAI is to further strengthen this trust and support it with robust backend systems and processes.
5 key elements of such a system would be:
1.    Unambiguous food safety standards based on robust methodology of risk assessment.
2.    Safe storage and transportation, manufacturing and processing, distribution, and retail practices that food businesses should follow.
3.    Reliable food testing laboratories to estimate food safety levels.
4.    Transparent, effective, and light-touch compliance verification system through risk-based inspections.
5.    Regular food safety surveys to assess impact and provide insights for continuous improvement in the system.

Developing a reliable food safety programme is a massive challenge and also a liability as millions of food companies are involved and many of them have limited resources and infrastructure. This process naturally involves the concerted efforts from a significant number of stakeholders. FSSAI has planned to establish successful partnerships across ministries in Central and state governments, public and private bodies, civil society, and research institutions. By using its convening power, the FSSAI will create successful partnerships with other organisations and develop a network of relationships that will help to get things done as per plans.
There are also new prospects for rapid developments in field of science and technology. FSSAI needs to develop a network of scientific cooperation across science ministries and agencies for research collaboration, data sharing and curating new technologies for food testing. In order to resolve the issue of pollutants from primary production, codes of practice need to be established in collaboration with relevant ministries and agencies, which then need to be widely circulated for adoption. Many areas such as battle against antimicrobial resistance, issues related to pesticide contamination, heavy metals and maintaining the integrity of organic food, require close coordination of action plans through ministries and agencies.

Food companies need to be encouraged to ensure self-compliance by training and through capacity building, more open licensing, enforcement structures and routine third--party audits. Collaboration with various field departments, including state and district authorities, is also required, which may be achieved by energising regulatory bodies at the state and district levels.

(The author is research director, TechSci. He can be reached at sales@techsciresearch.com)
 
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