Friday, May 25, 2018


Reduction in number of convictions for economically-motivated adulteration
Tuesday, 02 May, 2017, 08 : 00 AM [IST]
Ashwin Bhadri
In the year 2014-2015, as per the FSSAI Annual Public Laboratory Testing Report, it came to be known that one in five food products could not clear the quality and safety tests in India. Out of 49,290 products analysed by FSSAI, 8,469 products were found incapable to clear the basic tests.

Yet the number of convictions for economically motivated adulteration of food has come down from 3,845 in 2013-14 to just 1,256 now.

These are some disturbing numbers which bring one question to everyone’s mind - are the food products on our plates right now, safe?

The importance of food quality can only be known in its absence. The turmoil caused in 2015 when the noodles fiasco came into picture was one such matter that showed us the tapestry of food safety. However, that was just one such scandal that was known. Every other day, there are news stating product recalls, scandals pertaining to food adulteration and stale products displayed and sold. Every day, we hear people who succumb to diseases caused due to unhygienic food products.

With a motive to curb the growing menace caused due to unethical practices in the food industry and to safeguard the health of the consumers, eight food rules were consolidated to form the FSSA - Food Safety and Standards Act, 2006. Following this, to ensure people and companies comply with FSSA, Food Safety and Standards Authority of India (FSSAI) came into existence.

•    Functions to Maintain Quality Assurance of Food
Three aspects work in close relation with each other - GHP/GMP, Documentation and Inspection/Audit.
1.    GHP/GMP - While creating an FSMS (Food Safety Management System) plan, Section (3) (s) of FSSA speaks about Adoption of Good Hygiene Practices / Good Manufacturing Practices, as well as Hazard Analysis and Critical Control Point (HACCP) and other such practices as required by the Business. GHP/GMP are norms that help in assuring safe food products and safeguard the food served to the people in restaurants and cafes.
2.    Documentation - A complete documentation protocol in terms of FSMS plan ensures the smooth functioning of unit process. It encompasses the schedule of testing, instrument calibration, process methodology, application of licence and more. Let’s review an example for this case -

The Manual of Food Safety Management System by FSSAI has clearly mentioned the necessities of adequate documentation and how to achieve them. Self-inspection checklist forms which ask questions related to the type of business, the people into the business, hygiene aspects followed in the premises and so on.

The baseline and foundation of these questions and checklists remain the same. However, each type of food product and its ancillary items are devoted a separate checklist, the methods to prepare, till the product is dispatched.

In case of milk, a simple but powerful documentation would involve the standardised steps for processing milk, the hygiene practices followed in the premises, the training allotted, prospective hazards identified and adequate measures to counteract the same. These steps are followed across procuring, processing, storing, packaging and dispatching liquid milk.

•    Compliance with Specifications

The crux of the food industry is to serve the people. While doing so, the brand / company has to make sure the product out in the market is safe and healthy. Different brands may have a different perspective towards safety. So will different countries across the globe. How can we then state the food served to us can be consumed?

In February 1961, director-general of FAO B R Sen actively entered into a discussion with WHO, UNECE, OECD and the Council of Codex Alimentarius Commission which led to the genesis of Codex Alimentarius Commission (CAC). According to Article 1 of the Codex Statuses, the main objective of the CAC is to protect the health of the consumers and ensure fair practices in the food trade among the countries.

Slowly, the harmonisation of various governments with the Codex was observed. Formed in 2006, FSSAI undertook the harmonisation of India’s food standards with that of Codex standards. This helped in identifying the areas which may require improvisations, as well as making the necessary changes in the food law with respect to the Codex laws. With Codex in place, the apex body has made several changes in the regulations for contaminants and additives, along with few others.

FSSA specifies regulations which bring under its umbrella all possible food businesses and types of food products. Every category has been allotted specifications which are evolving as per the changes seen in the food industry. FSSAI speaks about regulations on Licences and Registrations, Contaminants and Toxins, Packaging and Labelling, Food Product Standards and Food Additives, and more.

The major problem still lies with the consumers and FBOs (Food Business Operators) not understanding the ways to achieve compliance and safety. Adequate training still lacks in the country and not enough awareness has been created on how to be compliant and identify key areas.

•    Report keeping with Producers

One major aspect that people and even food businesses fail to observe is the safety of the raw materials procured. FBOs usually follow Good Hygiene / Manufacturing Practices at their premises, have adequate documentation in place and even have a valid licence; what they do not observe is the quality of the food products they obtain at the beginning of the food processing chain.

Some properties of food quality are visible - fungal contamination, pungent odour, and powered particles. There are other properties which are not evident at the first sight, but slowly shows up when people consume these food products. Not using good quality wheat grains and milk, using shrunken vegetables, inadequately sized, adulterated fruits, are some of the examples.

This might come across as a shocker, but maximum food-related disorders are caused due to usage of these raw materials. FBOs and retailers keep pondering over their own hygiene practices, while the crime scene is located at an altogether different location.

What can be done?

Make sure the seller has a food licence in place; Ensure the intact quality as you receive the lot; Check for any breakage, leakage or tear around the package; Ask for the documents which show the seller’s practices; Ensure the seller gets its products tested from an accredited laboratory; Observe its hygiene practices; Maintain reports of all the products you have purchased and the related documents.

These things will help you identify the loopholes in your product quality. Remember, it’s your product and brand name that will be on the line. A compromise of no manner should be tolerated where quality of food, brand equity and most important, health of the consumers is in question.

•    Technologies for Quality Assurance System

In Quality Assurance, technologies come into picture at two most critical junctures - Testing of the product and Auditing/Inspection. Let’s review these in detail.

1. Techno-Testing - Product testing in earlier days depended solely on its looks, odour, texture - in simple terms, Sensory Evaluation, which is now revived back, to estimate how a product fairs in terms of mass acceptance. Chemical and Biological testing of food products came in the 19th century, with the advent of microscope and other instruments, though the knowledge existed for centuries.

Slowly, with the development of laws and the growing necessity of stringent food limits, came in many more novel instruments for product analysis. Today, we have a standardised protocol for testing and that depends on the calibrated testing instruments. The testing of heavy metals present in nanograms, which was earlier difficult to even estimate, can now be calculated with a couple of hours, few days tops.

Technology has brought us a long way. The heavy lab instruments have now evolved into portable devices, many of which are used by food safety officials to avoid wasting time in sample carrying and long testing periods. This has helped fasten the quality assurance in each and every corner of the country and the world, which was earlier difficult to reach.

2. Techno-Auditing - The days where auditors and inspectors carried pen and paper to identify loopholes, mention remarks and make sure the photocopy of the document reaches people, has started coming to an end. Mobile/Tablet Auditing is now in place, which makes it stupendously easy to carry the device, share details and loopholes with the owner/manager of the food unit and maintain records. Many companies use specially designed apps as well for reaching out to people in case of internal matters.

Technological advancements have also come into place for pre- and post-production of food. Packaging, labelling, dispatching are areas other than processing, where instruments are used on a large scale to handle bigger consignments.

•    Special Problems: Consumer Complaints, Production Problems, Training

- Consumer Complaints - No matter how compliant a food business or a restaurant owner is, there is left a loophole which manages to pop up, if critical view is not maintained. At such times, customer is bound to complain about the product/service and it is your duty to ensure this is efficiently handled and looked into.

FSSAI has a series of portals, both social networks and otherwise, where a consumer can register a complaint or state his/her grievances. This has bridged the gap between the people and the government body, ensuring smooth communication, as well as identifying the FBO that needs to comply with the regulations.

These are some of the pointers that might help one with consumer complaints. These will differ as per the changing business type, but on  whole, these are some of the good practices that an FBO should have in place -

1.    Make sure you have a feedback policy in place. 73% of the brand equity is lost when people resort to public platforms to state their grievances.
2.    Ensure the people with confidence that their matter will be dealt with at the earliest.
3.    Maintain the deadline stated to the consumers. Never give people the chance to state their query twice.
4.    Work on the query as soon as possible. There is no better thing than a happy consumer.
5.    Communicate the query to the concerned team. Make sure they know what they should do to rectify the mistake and ensure this is not repeated.

- Production Problems - This problem is usually seen in small and large food processing / production units. From breaking down of the machines, to lack of adequate work force, production problems can lead to wastage of food products, time, finances, resources and energy. Halting of food production/processing can be a tedious task. It takes a long time to begin the process by cleaning the remnants of the previous batch, reinstating the hygienic conditions and preparing the batch flow. A unit should have a HACCP plan in place with counteracting measures to deal with each disruption. This will help in faster counteracting measures, prevent waste of time, and have a negligible effect on the finances.

- Training - It goes without saying that the people working in the premises should be trained on handling the food, cleaning practices, auditing and inspections. Good Hygiene Practices, Good Manufacturing Practices, ergonomic factors - the importance of all should be stated and taught to the personnel working in the unit.

•    Role of GHP Guidelines

Good Hygiene Practices (GHP) are the fundamentals for ensuring quality assured safe food. These are basic methodologies which should be practiced by every Food Business Operator to deliver contamination-free products - Covering your head with head gear; Using clean apron and duster; Keeping nails short and hair covered; Avoiding nail paints and jewellery in the working area; Using separate slippers in the working area; Refraining from picking nose and scratching ears while handling food; Using appropriate eye wear while preparing food.

There are more such practices stated in the FSMS plan to maintain Good Hygiene Practices. These help in working towards a compliant business and product/service.

(The author is chief executive officer, Equinox Labs)
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