| Md. Wasim Aktar* Pesticide Residue Laboratory, | | | | 2000, Indian dry chili exports also faced rejection in |
| Department of Agricultural Chemicals, Bidhan Chandra | | | | Germany, Italy, Spain and the U.K. due to the |
| Krishi Viswavidyalaya, Mohanpur-741252, Nadia, West | | | | presence of aflatoxin.8 More recently, exports of chili |
| Bengal, India | | | | and curry powder faced problems due to the use of |
| 1. Introduction | | | | the prohibited red dye Sudan 1 (Jaffee, 2005). In |
| Rising incomes and urbanization, an expanding | | | | February 2005, a massive recall of some 600 food |
| domestic consumer base concerned about food | | | | products took place in the UK because of the |
| quality and safety, and rapidly growing agricultural | | | | detection of Sudan 1 in Worcester sauce. This was |
| exports have been important drivers for the | | | | the largest ever food recall in the U.K. and it affected |
| increased attention to food safety in India. But the | | | | all major retailers as well as large numbers of food |
| development of effective food safety systems is | | | | manufacturers and food service companies, as the |
| hampered by a number of factors, including: | | | | Worcester Sauces had been used in the preparation |
| restrictive government marketing regulations, weak | | | | of a large number of different products. It is |
| policy and regulatory framework for food safety, | | | | estimated that this recall, and associated expenses, |
| inadequate enforcement of existing standards, a | | | | cost the U.K. and other European food manufacturers |
| multiplicity of government agencies involved, weak | | | | some 200 million Euros (Jaffee, 2005). The source of |
| market infrastructure and agricultural support | | | | the Sudan 1 dye in the Worcester sauce was traced |
| services. The small farm structure further limits | | | | to chili powder imported from India in 2002. Fish and |
| farmer capacity to meet increasing domestic and | | | | Fish Product Exports. Fish and fish products are one |
| export food safety and SPS requirements. | | | | of India's largest agricultural export earners, totaling |
| Addressing food safety concerns in India will require | | | | US$1.3 billion in 2004/05. Over the years, India has |
| adoption of appropriate legislation, strengthening | | | | encountered several food safety problems with its |
| capacity to enforce rules, promoting adoption of | | | | fish and fish product exports. Most prominent, in |
| good agricultural, manufacturing and hygiene | | | | 1997, the European Commission found the industry to |
| practices, greater collective action, and some | | | | be non-compliant in maintaining hygiene standards in |
| targeted investments. Implementing these actions will | | | | fish processing plants. In May 1997 the European |
| require joint efforts by the government and the | | | | Commission banned Indian exports of fresh |
| private sector. | | | | crustaceans and cephalopods and imposed border |
| Developing countries are paying increased attention | | | | testing for Salmonella and Vibrio spp. for frozen |
| to food safety, because of growing recognition of its | | | | products (Henson, Saqib and Rajasena, 2005). |
| potential impact on public health, food security, and | | | | Because of continued detection of salmonella, all |
| trade competitiveness. Increasing scientific | | | | exports of fish and fishery products to the EU from |
| understanding of the public health consequences of | | | | India were banned in 1997. While India has for the |
| unsafe food, amplified by the rapid global transmission | | | | most part been able to address the hygiene-related |
| of information regarding the public health threats | | | | problems plaguing its export of fishery products in |
| associated with food-borne and zoonotic diseases | | | | the late nineties, Indian exports are now under |
| (e.g. E. coli and salmonella, bovine-spongiform | | | | scrutiny because of problems related to antibiotic |
| encephalopathy (BSE), severe acute respiratory | | | | residues and bacterial inhibitors (antibiotics, |
| syndrome (SARs) and H5N1 avian flu) through various | | | | preservatives and chlorine) (Henson, Saqib and |
| forms of media and the internet has heightened | | | | Rajasena, 2005). It is widely acknowledged that in |
| consumer awareness about food safety risks to new | | | | the future, heavy metals and other contaminants |
| levels globally (Lindsay 1997, Unnevehr 2003, Buzby | | | | could be an emerging issue particularly because of |
| and Unnevehr 2003, Kafersteing 2003, Ewen et al. | | | | the increased attention to heavy metals in the EU. |
| 2006, Bramhmbatt 2005). Increased understanding of | | | | Surveillance of fisheries products for heavy metals |
| the impact of mycotoxins, which can contaminate | | | | has already begun in the U.K. Although India has been |
| dietary staples such wheat, maize, barley and | | | | able to broadly comply with food safety |
| peanuts, has further raised food security and public | | | | requirements for each of the export commodities |
| health concerns in many developing countries | | | | mentioned above, it continues to face problems |
| (Dohlman 2003, Bhat and Vasanthi 2003, Unnevehr | | | | across a range of agro-food exports. Evidence of |
| 2003). As developing countries seek to expand | | | | continuing trouble is clearly apparent from Import |
| agricultural exports especially to OECD countries, | | | | Refusal Reports issued each month by the USFDA |
| many are receiving a wake-up call on the challenges | | | | for food and drug imports into the United States. |
| of meeting both government and private sanitary | | | | Most recently, in both April and May 2006, India had |
| and phyto-sanitary (SPS) standards in export | | | | one of the highest rejections among all countries |
| markets (Otsuki et al. 2001, Henson 2003, Unnevehr | | | | exporting to the USA; India faced 176 rejections in |
| 2003, World Bank 2005a). Private standards or | | | | May, 2006 and 211 rejections in April, 2006.9 While a |
| supplier protocols have grown in prominence over the | | | | significant number of the 176 rejections were issued |
| past decade as a means to further ensure | | | | for drugs and cosmetics, the grounds for rejection |
| compliance with official regulations, to fill perceived | | | | among the various food items included salmonella and |
| gaps in such regulations, and/or to facilitate the | | | | or filth in raw peeled shrimp, prepared Indian breads |
| differentiation of company or industry products from | | | | (paratha, roti), basmati rice, sesame seeds, pepper, |
| those of competitors. Trends in private standards | | | | coriander and chili powder; pesticide residues in lentils; |
| increasingly tend to blend food safety and quality | | | | failure to declare the color additive FD & C Yellow |
| management concerns (i.e. the recent creation of ISO | | | | No. 5 in banana chips; and unsafe coloring in cream |
| 22000), or to have protocols which combine food | | | | biscuits. The number of rejections and the range of |
| safety, environmental, and social (child labor, labor | | | | problems reveal extensive safety problems in Indian |
| conditions, animal welfare) parameters (Willems et al. | | | | food products. It is also reasonable to assume that |
| 2005, World Bank 2005). At the same time, increasing | | | | the extent of the problems faced by domestic |
| globalization of trade introduces greater risks of | | | | consumers is far more serious as there many more |
| cross-border transfer of food-borne illnesses. Recent | | | | micro, small and medium enterprises that cater to |
| cases of disease episodes in the United States | | | | domestic consumers and generally pay less attention |
| resulting from imported food produce, such as | | | | to food safety issues. By contrast, exporters are |
| cyclospora from raspberries, hepatitis A from | | | | likely to be more well-established and larger firms |
| strawberries and salmonella from cantaloupe (Calvin | | | | with better technology and relatively more cognizant |
| 2003), illustrate to developing countries the potential | | | | about food safety concerns. |
| food safety challenges that can arise in a more | | | | 7. Challenges to Improve Food Safety in India |
| globalized market. Weaknesses in food safety | | | | Improving food safety in India, whether for the |
| systems can have a high cost to society and the | | | | domestic market or for export trade, is hampered by |
| global economy. The World Health Organization | | | | a number of structural, policy, institutional, technical |
| (WHO) estimates that 2.2 million people worldwide die | | | | and cultural barriers. |
| from diarrheal diseases caused by a host of bacterial, | | | | Policy and Regulatory Environment. A number of |
| viral and parasitic organisms, which are spread by | | | | policies and regulations governing agricultural |
| contaminated water (WHO 2006a). In India, it is | | | | marketing and food processing complicate the |
| estimated that 20% of deaths among children under | | | | implementation of food safety measures by the |
| five are caused by diarrheal disease (WHO 2006b). | | | | government and by the private sector. Two critical |
| The SARs outbreak in 2003 in East Asia is estimated | | | | marketing regulations are the State level Agricultural |
| to have caused an immediate economic loss of about | | | | Produce Marketing (Development and Regulation) |
| 2% of the Region's GDP in the second quarter of | | | | Acts and the Small Scale Industry Reservation Policy. |
| that year, even though only 800 people died from | | | | Almost all states in India have an Agricultural Produce |
| the disease (Brahmbatt 2005).1 The Lowy Institute | | | | Marketing (APM) Act, which gives state governments |
| for International Policy (2006) estimates that a mild | | | | the sole authority to establish and manage wholesale |
| global outbreak of the avian flu can cost the world | | | | markets.10 The Act, adopted by most states in the |
| 1.4 million lives and close to 0.8% of GDP (US$330 | | | | 1960s and 1970s, prescribes the setting up of a |
| billion) in lost economic output. At the same time, | | | | network of state controlled "regulated markets" or |
| country reactions to protect its citizens from food | | | | mandis and the establishment of Market Committees |
| safety risks can also have large consequences for | | | | to operate each. All "notified" agricultural commodities |
| exporting countries. Otsuki et al (2001) examined the | | | | grown in areas surrounding the market are required |
| projected impact of the EU's new harmonized | | | | by law to be sold only through these markets, with |
| aflatoxin standard on the value of trade flows to 15 | | | | the number of notified commodities varying by state |
| European countries from 9 African countries and | | | | and market. Implementation of the Act and its |
| found that it could decrease African exports by 64% | | | | enforcement vary considerably by state. In 2005, |
| (US$670 million). Food safety concerns are getting | | | | there were nearly 8,000 regulated markets in the |
| widespread attention in India. The country's rural | | | | whole country.11 The requirement that all agricultural |
| development strategy, for which a key element is | | | | commodities be channeled through the regulated |
| the promotion of increased agricultural exports as a | | | | markets not only increases transactions costs, but is |
| means to foster rural growth and poverty reduction, | | | | also a major obstacle to preserving produce quality |
| is coming up against tightening food safety and SPS | | | | and traceability. In 2003, the GOI formulated a model |
| standards in prospective markets (World Bank 2006a, | | | | Agricultural Produce Market Act for state |
| 2006b). From a domestic perspective, the large | | | | governments to adopt, which removes the |
| national market of 1.2 billion people is undergoing rapid | | | | restrictions on farmer direct sales and permits entities |
| change. Increasing incomes, a growing middle class, | | | | outside of government to establish and operate |
| increased urbanization and literacy, and a population | | | | wholesale markets. To date only 10 of the 28 states |
| highly tuned to international trends fueled by the | | | | and Union Territories have adopted the model Act.12 |
| information technology boom are creating a large | | | | The Small Scale Industry (SSI) Reservation restricts |
| consumer base giving increasing value to food quality | | | | the processing of certain commodities to the small |
| and safety. Improving food safety systems, to meet | | | | scale sector. Although the list of commodities subject |
| domestic and export requirements, however, face a | | | | to this restriction has been reduced significantly during |
| number of policy, regulatory, infrastructural and | | | | the last decade, several processed agricultural |
| institutional obstacles. | | | | products are still subject to SSI reservation, such as |
| 2. OBJECTIVES | | | | rapeseed, mustard and ground nut oil,13 bread, |
| (i) To review the main drivers for the increased | | | | pastry, pickles and chutneys, and hard boiled sugar |
| priority to addressing food safety risks in India in | | | | candy (Department of Small Scale Industries 2006). |
| both the export and domestic markets, (ii)To | | | | The SSI reservation imposes constraints on |
| examine the nature and effectiveness of | | | | enterprises' ability to undertake the necessary |
| government and private responses to the food | | | | investments (e.g. HACCP) and certifications required |
| safety challenges, with special focus on high value | | | | to meet the domestic and international food safety |
| agriculture; (iii)To identify the constraints to more | | | | and SPS requirements.14 There is a complex web of |
| effective responses; (iv) To examine the implications | | | | laws governing the processed food sector which |
| for policy; v) To review food safety with special | | | | complicate implementation of food safety measures. |
| relation to Pesticides; and vi) To discuss briefly about | | | | These laws are enforced by 8 different ministries. |
| the food safety from consumer point of view. | | | | Some of the most critical are: Prevention of Food |
| 3. Types of Food Safety Risks | | | | Adulteration Act 1954 implemented by the Ministry of |
| Food safety risks, as they relate to human health, | | | | Health and Family Welfare; Milk and Milk Products |
| arise from of a number of factors. These include: (i) | | | | Order 1992 and Agricultural Produce Grading and |
| microbial pathogens (bacteria, viruses, parasites, fungi | | | | Marking Act 1937 implemented by the Ministry of |
| and their toxins); (ii) pesticide residues, food additives, | | | | Agriculture; the Essential Commodities Act 1955, |
| livestock drugs and growth hormones; (iii) | | | | Standards of Weights and Measures Act 1976, |
| environmental toxins such as heavy metals (e.g. lead | | | | Consumer Protection Act 1986, and Bureau of Indian |
| and mercury); (iv) persistent organic pollutants (e.g. | | | | Standards Act 1986 implemented by the Ministry of |
| dioxins); and (v) zoonotic diseases (e.g.Avian flu, | | | | Food, Consumer Affairs and Public Distribution; the |
| Japanese encephalitis, tuberculosis) (Buzby and | | | | Fruit Products Order 1955 implemented by the |
| Unnevehr 2003, Ewen et al. 2004).2 The health risks | | | | Ministry of Food Processing Industries; import and |
| associated with these agents impact the whole food | | | | export regulations implemented by the Ministry of |
| supply chain, starting from input supply to the farm | | | | Commerce; Trade in Endangered Species Act |
| to the consumer table (Figure 1). | | | | implemented by the Ministry of Forest and |
| Figure 1 Food Supply Chain: Potential Sources of Food | | | | Environment; Atomic Energy Act 1962/Control of |
| Safety Hazards | | | | Irradiation of Food Rule 1991 implemented by the |
| Common use of pesticides in modern farming | | | | Ministry of Science and Technology; and Infant Milk |
| inevitably leaves some residues on food crops. | | | | Substitutes, Feed Bottles and Infant Foods |
| Potential food safety hazards at HOME can be | | | | (Regulation of Production, Supply and Distribution) Act |
| divided into three categories: 1. Biological | | | | 1992 implemented by the Ministry of Human |
| 2. Chemical | | | | Resource Development (Patnaik 2005). These laws |
| 3. Physical | | | | also authorize several agencies to lay down standards |
| While all the above type of hazards are important | | | | for food products: (i) Bureau of Indian Standards |
| from viewpoint of prevention, the focus here will be | | | | (BIS) of the Ministry of Food, Consumer Affairs and |
| on the microbiological hazards and in that on | | | | Public distribution under the BIS Act, (ii) Ministry of |
| foodborne bacteria, which can lead to illness if the | | | | Food Processing Industry under the Fruit Products |
| food is mishandled, particularly for those more at risk | | | | Order, (iii) Ministry of Agriculture under "Ag Mark" and |
| -- the very young, the elderly and the | | | | the FPO, (iv) Ministry of Health and Family Welfare |
| immuno-compromised. Certain processes or handling | | | | (MOHFW) under the PFA Act; (v) Export Inspection |
| practices by consumers in the home have been | | | | Council under the Export-Import Policy, and (vi) the |
| identified as being essential or critical in preventing | | | | Defense Ministry for their own purchases. These laws |
| foodborne illness. These practices, which prevent or | | | | and associated regulations in some cases prescribe |
| control the "meals" microbial contamination associated | | | | contradictory or differing standards. For example, |
| with foodborne illness, are under the direct control of | | | | while the Fruit Products Order (FPO) allows the use |
| the consumer, from food acquisition through disposal. | | | | of artificial sweeteners in fruit products, the |
| They are purchasing, storing, pre-preparation, | | | | Prevention of Food Adulteration (PFA) Act bans it. |
| cooking, serving, and handling leftovers. Failure to | | | | Mandatory declaration labels required by the PFA |
| take appropriate action at these critical points could | | | | differ from those of the Packaged Commodity |
| result in foodborne illness. | | | | Regulation Rules (1977) under the Standard Weights |
| 4. Pesticides and Food Safety | | | | and Measures Act. The emulsifier and stabilizers |
| Fruits, vegetables and cereal crops treated with | | | | permitted for use in jams and chutneys under the |
| pesticides are perceived by some as a health risk, | | | | PFA differ from those allowed under the FPO. In |
| and this belief along with affordability, and time | | | | 1998, the GOI began the process of rationalizing the |
| pressures may all play a role in limiting consumption of | | | | legal and regulatory framework for food and food |
| plant foods, such as cereal grains, fruit and vegetable | | | | processing. The Prime Minister's Council on Trade and |
| consumption of consumers in Asia. The World Health | | | | Industry established a Task Force on Food and |
| Organisation (WHO), the World Cancer Research | | | | Agro-Industries Management Policy to recommend |
| Fund (WCRF) and many other national and | | | | options for rationalizing the various policies and |
| inter-governmental agencies recommend that adults | | | | regulations. The outcome was a new Food Safety |
| consume at least 400g of fruit and vegetables per | | | | and Standards Bill, which was submitted to Parliament |
| day and 25-30 grammes of dietary fibre per day, but | | | | in August 2005 and is awaiting approval. The Bill aims |
| analysis of current dietary patterns around the world | | | | to consolidate the laws relating to food. The key |
| indicate that many consumer are not achieving these | | | | provisions of Bill include: (i) the repeal of a number of |
| dietary goals, particularly those who are less affluent. | | | | Acts and Orders;15 (ii) the establishment of a Food |
| AFIC's Short Briefing on Pesticides, Food Safety and | | | | Safety and Standards Authority of India; (iii) definition |
| Health is intended to provide a science-based factual | | | | of the standards for food additives, contaminants, |
| overview of the issue, to enable consumers to make | | | | genetically modified and organic foods, packaging and |
| better informed choice about their diet, in particular | | | | labeling, and food imports; (iii) accreditation of |
| fruit, vegetables and grains consumption, and allay | | | | laboratories, research institutions and food safety |
| unwarranted anxieties and concerns. Definition of | | | | auditors; (iv) licensing and registration of food |
| Pesticide: The Food and Agriculture Organisation | | | | business and setting penalties for offenses; and (v) |
| (FAO) defines a pesticide as 'any substance or | | | | establishment of a Food Safety Adjudication Tribunal |
| mixture of substances intended for preventing, | | | | (Ministry of Food Processing Industries 2005). |
| destroying, attracting, repelling, or controlling any pest | | | | Approval of the Bill will be an important milestone in |
| including unwanted species of plants or animals during | | | | strengthening food safety systems in India. There |
| the production, storage, transport, distribution, and | | | | are a large number of government agencies involved |
| processing of food, agricultural commodities, or animal | | | | in agricultural marketing activities, more broadly or |
| feeds or which may be administered to animals for | | | | with respect to specific commodities, which |
| the control of ectoparasites' Natural Toxins: | | | | complicates effective implementation of a coherent |
| Substances that are capable of causing cancer are | | | | food safety strategy for the country. As in the case |
| virtually everywhere, even in natural compounds. The | | | | of the soft drink contamination, the multiple laws and |
| FDA estimates that the intake of carcinogens from | | | | agencies added to the confusion. The BIS was |
| man-made pesticide residues is extremely small | | | | charged with setting the standards for pesticides in |
| compared to carcinogenic residues that plants | | | | soft drinks, while the MOHFW is charged with setting |
| produce naturally. According to Bruce Ames, a | | | | the pesticide standards for bottled water. Smallholder |
| professor of molecular biology and biochemistry at | | | | Agriculture. The current structure of the farm sector |
| the University of California, more than 99.99 percent | | | | in India constrains farmer capacity to meet domestic |
| of the pesticides Americans ingest are "nature's | | | | and international food safety standards. Farming in |
| pesticides" or "natural toxins" (Hotchkiss, 1992; Moore, | | | | India is dominated by small farmers - the average |
| 1989). Natural toxins are present in all plants and such | | | | farm size in 1990/00 was 1.8 ha (NABARD 2002). |
| food products as beans, lettuce, apple juice, wine, | | | | Most farmers face credit constraints (World Bank |
| black pepper, spinach, peanut butter and many | | | | 2004), and literacy rates are low.16 These constraints |
| others. Of the known natural toxins, which | | | | impose limits on the number of farmers capable to |
| concentrate in parts per thousand versus parts per | | | | adopt more sophisticated farm practices and |
| billion in synthetic pesticides, none has been shown to | | | | undertake the necessary investments (e.g. land |
| cause cancer (Hotchkiss, 1992; Moore, 1989). | | | | improvements, obtaining necessary certifications, cold |
| Reasons of pesticide residues in food | | | | storage) to meet more stringent food quality and |
| Pesticide residues may be present in food because of | | | | safety requirements. They increase the cost of |
| the following reasons: 1) Direct use of pesticides on | | | | transacting business and monitoring compliance with |
| food crops; 2) Animal feeding on pesticide treated | | | | food safety standards. Stringent land policies, e.g. land |
| feed; 3) Environmental contamination | | | | ceilings and restrictions on land rental, limit possibilities |
| Pesticide Use on the Farm: Many of today's food | | | | for greater land amalgamation (World Bank 2006c). |
| producers are taking an Integrated Pest Management | | | | International experience indicates, however, that |
| (IPM) approach to preventing, reducing or eliminating | | | | farm size constraints may be overcome through |
| pest problems. Growers and processors must make | | | | innovative interventions such as organizing farmers |
| complicated decisions prior to planting, during the | | | | into producer groups, establishing collection centers |
| growing season, and during postharvest handling. | | | | (by supermarkets and exporters), using contract |
| Scientific IPM strategies give the grower economic | | | | farming arrangements, and by creating public-private |
| incentives for sustaining long-term crop protection | | | | partnerships to assist farmers in a variety of ways, |
| with minimal disruption to the environment. The | | | | including help in obtaining the capital required to make |
| agricultural community typically will use pesticides | | | | on-farm improvements and other investments (e.g. |
| judiciously as part of the IPM strategy whenever | | | | grading or cooling facilities), developing and improving |
| proven alternatives are not available for pest control. | | | | farming skills through joint extension provision, and |
| Growers are hiring professional crop consultants with | | | | assistance in acquiring the required national and |
| increasing frequency for advice on maintaining or | | | | international certifications (Berdegué et al. 2003, |
| increasing production through the utilization of IPM | | | | Boselie et al. 2003, Dries et al 2004, Reardon and |
| programs structured toward their specific agronomic | | | | Swinnen 2004, Reardon and Timmer 2005a, 2005b). |
| situations. Integrated pest management: It is an | | | | In order to address various food safety concerns in |
| ecological approach to pest management in which all | | | | both the spices and fresh and processed fruit and |
| available control techniques are consolidated into a | | | | vegetable sectors, some exporters initiated contract |
| unified program so that pest populations can be | | | | farming operations or "vendor screening" programs. |
| managed in such a manner that economic damage is | | | | One industry that has been especially successful in |
| avoided and adverse side effects are minimized. | | | | establishing contract farming arrangements and |
| Practices used as a part of this management | | | | meeting stringent food safety and quality standards |
| philosophy include the following: 1) destruction of crop | | | | is the pickled gherkin industry. The industry, consisting |
| debris, 2) having pests feed and concentrate on trap | | | | of some 42 companies and nearly 50,000 smallholder |
| crops, 3) crop rotation, 4) selectivity of planting and | | | | outgrowers, is concentrated in Karnataka, Andhra |
| harvest dates, 5) soil test analysis for crop nutrient | | | | Pradesh, and Tamil Nadu. The leading gherkin |
| needs, 6) planting crop species adapted for local | | | | exporting companies each have several thousand |
| conditions, 7) using genetically improved crop varieties | | | | farmers under contract. The companies provide |
| with resistance to specific pests, 8) using biological | | | | intensive oversight and maintain extensive records of |
| control, 9) predicting pest outbreaks with computers, | | | | farmer practices, especially related to pesticide use. |
| 10) pheromones for trapping pests, 11) scouting and | | | | At least one company began the process of getting |
| monitoring for pests, 12) economic thresholds as | | | | outgrowers certified under EurepGAP (World Bank |
| guides to pest control, 13) better timing and | | | | 2006b). Contract farming has worked relatively well in |
| application of pesticides, 14) use of biological | | | | the case of gherkins as almost the entire production |
| insecticides, 15) improved pesticide application | | | | from India is exported and there is no local market. |
| efficiency, 16) adapting promising technology, including | | | | Hence contract enforcement has not been a major |
| the use of infrared scanners, satellite photos, | | | | challenge as in the case of other commodities where |
| gene-splicing biotechnology, and new pesticide | | | | the export intensity is much lower and the majority |
| delivery systems that incorporate farm-specific | | | | of production is consumed domestically. |
| information on tractor mounted computers. Pesticide | | | | Until recently, contract farming was illegal in India as |
| Limits and Regulation: Approval for use of any | | | | per the provisions of the APM Act. The only way |
| pesticide in a country is subject to its safety | | | | entrepreneurs can legally enter into contract farming |
| evaluation. Safety levels for any pesticide are | | | | with farmers is to obtain a special waiver from the |
| calculated over a number of formal assessments. The | | | | APM Act from the State Government. The new |
| Codex Alimentarius Commission is an international | | | | model APM Act provides the legal framework and |
| body which sets international guidelines on many | | | | guidelines for contract farming. The provisions in the |
| elements of food safety, including pesticides residues | | | | model Act allow contract buyers to directly purchase |
| on food. These guidelines are not mandatory, but | | | | commodities from farmers under individual contracts |
| many countries in Asia use these guidelines, | | | | or from farmers' markets. It also allows the direct |
| sometimes with additional scientific data determined | | | | sale of farm produce at the farmers' fields without |
| by their national regulatory agencies to establish limits | | | | having them routed through regulated markets. |
| on use and also acceptable residue levels at point of | | | | Adoption of the model Act by state governments |
| sale. Acceptable Daily Intake: One of the most | | | | will therefore facilitate not only more efficient |
| important tools in the safety evaluation of pesticide | | | | marketing, but also improved food safety and the |
| use on food crops is the calculation of what is an | | | | adoption of improved agricultural practices. Weak |
| Acceptable Daily Intake (ADI). The ADI for any given | | | | Extension Systems. The public agricultural extension |
| pesticide is a measure of the quantity of a particular | | | | systems at the state level are very weak and have |
| chemical in food that can be consumed daily over a | | | | not effectively caught up to the changing needs of |
| lifetime without any known risk to health. It is | | | | farmers and the market (World Bank 2005b). In view |
| expressed in relation to bodyweight. ADI is derived | | | | of the GOI's earlier concentration on food |
| by first conducting diet trials on laboratory animals | | | | self-sufficiency, the state-level Department of |
| and observing the maximum level of pesticide that | | | | Agriculture (DoA) extension systems generally |
| can be consumed by the animal with no observable | | | | focused on cereals, particularly rice and wheat, with |
| adverse effect on health. This level expressed as | | | | an emphasis on the transfer of improved varieties |
| percentage of body weight is known as the No | | | | and management practices. The weak coordination |
| Observable Adverse Effect Level (NOAEL or NOEL), | | | | between the state DoAs and the other line |
| The investigations include checks for birth defects, | | | | departments (e.g. Departments of Irrigation, |
| cancer, reproductive changes, damage to the | | | | Horticulture, Livestock, Marketing, etc) and the limited |
| nervous system, harm to organs such as the kidney | | | | staff capacity beyond the Department of Agriculture |
| or liver, and many other measurable health indicators. | | | | also often translated to limited extension activities |
| A safe level for human consumption is estimated by | | | | beyond cereals, limiting its impact on agricultural and |
| dividing the NOAEL on humans by an uncertainty | | | | market diversification trends. The weak coordination |
| factor (usually 100) to allow for the possibility that | | | | with research at the central level further increased |
| humans may more sensitive than the animals used | | | | the difficulty of ensuring effective |
| for testing and also to account for possible variation | | | | research-extension-farmer linkages at the state level. |
| in sensitivity to the pesticide between human | | | | In many states, tight fiscal constraints contributed to |
| individuals, for example adults and children. These | | | | the breakdown of the state extension machinery |
| results in an ADI for humans which is 100 times lower | | | | (Hanumantha Rao 2003). Private extension provision |
| than the NOAEL consumption rate established from | | | | (fee for service) is emerging. There are an increasing |
| trials on laboratory animals. Acute Reference Dose: | | | | number of input suppliers, traders, contract buyers, |
| Safety evaluation of all pesticides also requires an | | | | supermarkets, and exporters which provide extension |
| estimate of the acute refrence dose (ARfD). The | | | | services to farmers as an integral part of their |
| ARfD is an estimate of the amount of a substance in | | | | trading arrangements (World Bank 2005b). However |
| food or drinking water expressed as percentage of | | | | in the national context, private extension remains |
| body weight, that can be consumed over a short | | | | limited. The findings of a World Bank agricultural |
| period of time, usually one meal or one day, without | | | | marketing survey, covering 1,579 farmers producing |
| any known effect on health. This figure is also | | | | high value crops (tomatoes, potatoes, mangoes, |
| expressed as a percentage of body weight. | | | | maize and tumeric) in four states in India (Orissa, |
| Maximum Residue Levels: A maximum reside levels | | | | Tamil Nadu, Uttar Pradesh, and Maharashtra) |
| (MRL) is the maximum permissible quantity of | | | | conducted during February to May 2005, confirm the |
| pesticide that may still be present on the crop at | | | | limited effectiveness of the national extension |
| point of sale. It is derived from an assessment of the | | | | system. Farmers primarily depended on personal |
| residues found when the crop is treated according to | | | | observation or on other farmers for information |
| good agricultural practices. The MRL is the maximum | | | | about crop prices, post harvest practices, irrigation, |
| concentration of a pesticide residue that is legally | | | | fertilizer and pesticide use (Table 2). Although food |
| permitted in, or on, a food commodity, and is set by | | | | safety concerns have not been a major focus in the |
| national governments if the approval is given for the | | | | extension program, it is partly addressed through the |
| use of the pesticide on specified crops. MRLs are set | | | | increased Ministry of Agriculture (MoA) priority to |
| to determine legal trading limit, and are not an | | | | integrated pest management (IPM). MoA established |
| indicator of risk to health. MRLs are set at levels | | | | the National Center for Integrated Pest Management |
| which would result in consumption of any residue at a | | | | in1988 to develop and promote IPM technologies. |
| level substantially lower than the ADI or the ARfD | | | | Notably there has been a decline in total pesticide |
| for the pesticide, and any pesticide whose MRL could | | | | consumption in India from 75,000 mt in 1990/91 to |
| result in dietary intake which might exceed the ADI | | | | 48,400 mt in 2003/03 (Directorate of Plant Protection |
| or ARfD would not receive approval. Pesticide | | | | and Quarantine 2006). Poor Infrastructure and |
| Residue Monitoring: Under FFDCA, the Food and Drug | | | | Services in the Marketing System. Reducing food |
| Administration (FDA) and USDA share responsibility | | | | safety risks from the farm to domestic and export |
| for monitoring levels of pesticide residues on foods. | | | | markets is constrained by inadequate infrastructure |
| FDA enforces pesticide tolerances for all domestically | | | | and facilities, particularly at the wholesale markets. |
| produced food shipped in interstate commerce and in | | | | The World Bank Agricultural Marketing Survey also |
| imported foods, except for meat, poultry and some | | | | collected information on the operations of 78 |
| egg products, which are monitored by USDA. Many | | | | wholesale markets in the four states. The survey |
| agriculturally-intensive states such as California and | | | | found that the infrastructure and facilities in these |
| Florida also conduct extensive pesticide residue | | | | markets are limited and rudimentary. Overall, |
| monitoring programs. FDA uses three approaches for | | | | Maharashtra and UP had slightly better infrastructure |
| pesticide residue monitoring: 1) incidence/level | | | | than the other two states. About 83% of markets |
| monitoring, 2) regulatory monitoring, and 3) Total Diet | | | | had covered shops, but only 18% had paved roads |
| Study (FDA, 1994). Total Diet Studies: To assess | | | | within the market and 51% had public toilets. Access |
| potential health problems from contaminants, both | | | | to warehouses is limited, except in Maharashtra |
| natural and man-made in the food supply, the WHO | | | | (85%). Less than 40% of markets had a drying area |
| recommends total diet studies (TDS) as the one of | | | | and no markets in Orissa or Uttar Pradesh had cold |
| the most cost-effective means for assuring that | | | | storage facilities (compared to 5% in Tamil Nadu and |
| people are not exposed to unsafe levels of toxic | | | | 20% in Maharashtra). |
| chemicals through food. TDS provides an additional | | | | Table 2: Farmer Sources of Information. |
| tool to assess whether or not any pesticides may be | | | | Waste management and pest control in the markets |
| present in the diet at levels which might pose a risk | | | | are very weak. Officials working in the wholesale |
| to health. A TDS is conducted by purchasing through | | | | markets were asked how the spoiled produce and |
| standard retail outlets a typical selection of foods | | | | waste products were disposed off. Fifty-four percent |
| commonly consumed in the country or region. The | | | | responded that market employees or contracted |
| 'basket' of foods is processed and prepared as if for | | | | firms handled garbage disposal and waste |
| normal consumption and then analysed in the | | | | management; 29% reported that they were just left |
| laboratory to measure total levels of the substances | | | | to rot in the market, while 13% reported that they |
| of interest, for example pesticides. Drinking water | | | | were left for the animals to eat. Market officials |
| and water used in cooking are also included in the | | | | were also asked about the pest control measures |
| assessments. The TDS provides a measure of the | | | | they undertake. Fifty-nine percent indicated that no |
| average amount of the pesticide consumed by | | | | particular control measure for rats and insects are |
| different age/sex groups living in a country. See box | | | | implemented in their market, 32% indicated it was up |
| for an example of an actual TDS and results for | | | | to the individual shop owners to take care of their |
| estimate of pesticide consumption. Risk Calculation: | | | | rat problems. Only 8% reported the market |
| Risk = exposure x toxicity. Risk of harm from a | | | | management or association or a subcontracted firm |
| chemical depends on both the level of exposure to | | | | took care of rat problems. Reducing food safety |
| the chemical and on the toxicity of the chemical | | | | risks will require significant public and private |
| (Chaisson et al., 1991). Therefore, to quantify | | | | investments to upgrade the market infrastructure |
| potential risks from consuming minute quantities of a | | | | and services. For regulated markets, this will also |
| particular chemical residue in food, scientists consider | | | | require improving the operational and fiduciary |
| the toxicity of the chemical, the residue content of | | | | management to ensure that more resources are |
| foods and the amounts of these foods eaten by | | | | re-invested back into the markets. |
| population subgroups. Population subgroups such as | | | | Cultural Issues. Religious beliefs further constrain the |
| infants, children, women, women of child-bearing age | | | | kinds of food safety measures that could be |
| and ethnic subgroups may be considered in risk | | | | adopted in India. The sacred value attached to cattle |
| assessments in addition to the total population. The | | | | imposes limits on disease control measures to |
| groups considered depend on the toxicologic | | | | address food safety and public health (BSE, foot and |
| characteristics of a particular chemical. Risk | | | | mouth disease), such as culling to limit disease spread |
| assessments that consider regional and seasonal | | | | or to create disease free zones. Inadequate grades |
| variations also are performed. Exposure = residue | | | | and standards for the domestic market and poor |
| concentration in food x amount of food consumed. | | | | enforcement. The Directorate of Marketing & |
| Potential exposure to a chemical in a specific food is | | | | Inspection under the Department of Agriculture and |
| assessed by multiplying the residue concentrations in | | | | Cooperation is responsible for enforcing and |
| food times the amount of food consumed by each | | | | implementing the Agricultural Produce (Grading and |
| person in the population. This exposure is expressed | | | | Marking) Act. Its mandate includes promoting |
| as milligrams of residue per kilogram of body weight | | | | standardization and grading of agricultural products. |
| per day (mg/kg BW/day). Potential dietary exposure | | | | Grades and standards have been prescribed for 164 |
| to a chemical is assessed by adding together residue | | | | commodities under the APM Act for domestic trade, |
| intakes from all foods. Different assumptions | | | | for export trade and for grading at the producer's |
| regarding residue concentrations in food may be used | | | | level. The AGMARK grades are primarily voluntary |
| to assess exposure. A worst-case exposure scenario | | | | grades covering aspects such as size, variety, weight, |
| may be calculated using tolerance levels for pesticides | | | | color, and moisture levels. For certain items they also |
| in food. This exposure assessment is the theoretical | | | | cover parameters such acceptable levels of organic |
| maximum residue contribution. Exposure may also be | | | | and inorganic foreign matter (in pulses, for example) |
| calculated using anticipated residue levels (Chaisson et | | | | and other chemical properties such as specific gravity |
| al., 1991; California Agriculture,1994). | | | | for essential oils. Different grades and standards are |
| 5. Food Safety and the Indian Domestic Market | | | | laid out under AGMARK for domestic consumption |
| Increasing incomes, urbanization, and literacy, | | | | versus exports. The Directorate provides third party |
| improved infrastructure and closer ties to global | | | | certification under the AGMARK quality certification |
| trends, especially during the last decade, are driving | | | | scheme. The 'AGMARK' seal is supposed to ensure |
| changes in consumer demand and preferences in | | | | quality and safety. Any consumer, trader or |
| India. Sustained economic growth (6.0% per year in | | | | manufacturer can have products tested at one of |
| real terms from 1990/91 to 2003/04) resulted in GDP | | | | the 23 regional AGMARK laboratories for designated |
| per capita increasing by about 70%, from about | | | | commodities. Typically, testing is only carried out for |
| US$315 in 1990 to US$538 in 2004 (constant 2000 | | | | adulteration prone commodities such as oils, ghee, |
| dollars). National poverty rates (headcount) declined | | | | whole and ground spices, honey, and whole and milled |
| from 38.9% (Central Statistical Organization 2002) in | | | | food grains. Blended edible vegetable oils and fat |
| 1987/88 to 28.5% in 1999/00 (Deaton and Dreze | | | | spreads are compulsorily required to be certified |
| 2002).3 The middle class, which now accounts for | | | | under AGMARK. The Prevention of Food Adulteration |
| about 15% of the 1.2 billion people in India, is the | | | | Act also sets standards for food products including |
| fastest growing income group and is a major force | | | | aspects such as permissible food colorings, |
| shaping the diet revolution that is occurring (Landes | | | | preservatives, pesticide residues, packaging and |
| and Gulati 2003). | | | | labeling. As illustrated by the bottled water and soft |
| Figure 2: Diversification on Food Consumption | | | | drink pesticide residue incidents, inadequate standards |
| Expenditures | | | | and weak enforcement remain a problem. The |
| These structural changes are reshaping consumer | | | | grades specified under AGMARK and standards as |
| demand. The Indian food consumption basket is | | | | laid out in the PFA are designed to facilitate trade as |
| diversifying away from cereals towards higher value | | | | well as ensure food safety. The food safety |
| and more perishable products, such as fruits and | | | | standards under the PFA in general need to be |
| vegetables, dairy, meat and fish (Figure 2). Increasing | | | | aligned with international standards. However there |
| female participation in the work force and higher | | | | are many commodities that are not grown or |
| disposable incomes to spend on non-home cooked | | | | consumed outside of India. For these commodities it |
| foods are driving growth in demand for prepared and | | | | may not be possible to align domestic standards with |
| semi-prepared foods, and thus the growth of the | | | | international standards because there are no |
| processed food industries (Pingali and Khwaja 2004). | | | | established international standards. In these instances |
| These trends bring increased attention to safety | | | | it is important for research to be conducted in India |
| concerns in the handling, processing and marketing of | | | | to set appropriate standards for the domestic |
| foods. In addition, growing consumer preference for | | | | market. Lack of pro-activity in addressing |
| shopping convenience, increased exposure to the | | | | food-safety issues. Domestic food safety scares and |
| media (TV, cable and the internet) and ownership of | | | | the more notable food-safety problems faced by |
| durables such as refrigerators and cars are fostering | | | | Indian agro-exports, reveal the overall absence of |
| the growth of modern retailing (i.e. supermarkets and | | | | any pro-activity in addressing food safety concerns in |
| hypermarkets), which in turn demand greater | | | | India. Several factors contribute to this. In the case |
| efficiency and food quality and safety standards in | | | | of exports, many if not most of the emerging SPS |
| the supply chain Mukherjee and Patel 2005, | | | | and international standards are widely viewed as not |
| Chenggapa, et al 2005). Increased vigilance by NGOs, | | | | scientifically based and as representing unfair "barriers |
| consumer groups, and local research institutes is also | | | | to trade" (World Bank, 2006b). These measures are |
| raising awareness and spurring action among | | | | viewed as efforts to protect foreign farmers or |
| consumers and policy makers to address food safety | | | | processors from competition, or are being fueled by |
| risks. Findings of high levels of pesticides in bottled | | | | unreasonable consumer fears in high income countries |
| water and soft drinks in 2003 by the Centre for | | | | and improved technologies for detecting hazards. |
| Science and Environment (CSE), an NGO, shook the | | | | Consequently, the approach of the government and |
| country and forced the Government of India (GOI) | | | | private sector has been to try to negotiate away |
| to take swift action (Mathur et al 2003, CSE 2004). | | | | the problems with trading partners and, failing that, |
| The CSE tested 30 bottled water brands from the | | | | addressing the various measures in international |
| major cities of Delhi and Mumbai in Maharashtra and | | | | standard-setting or dispute flora. As a consequence, |
| found that all except one contained pesticide | | | | insufficient attention is devoted to monitoring the |
| residues. | | | | requirements of official and private standards, |
| Figure 3: Pesticide Residues in Soft Drinks in India, | | | | interpreting their implications for Indian agriculture and |
| 2003 | | | | using current and anticipated requirements as |
| The Delhi brands on average contained pesticide | | | | catalysts to upgrade existing operations and |
| residues 36.4 times the maximum pesticide residues | | | | strengthen supply chain management (World Bank |
| stipulated by the European Union standards for | | | | 2006b). This absence of pro-activity has meant that |
| bottled water (CSE 2004). Shortly thereafter, Mathur | | | | India has either had to adopt a "defensive" strategy |
| et al. (2003) tested 12 brands of soft drinks sold in | | | | avoiding markets with more stringent food safety |
| Delhi for 16 organochlorine and 12 organophosphorus | | | | and agricultural health standards or launch into a |
| pesticides and 4 synthetic pyrethroids commonly | | | | fire-fighting mode when it faces potential disruption |
| used in agricultural fields and homes in India. Their | | | | or loss of trade due to noncompliance with |
| analysis found that all brands exceeded the EU | | | | standards.17 The absence of pro-activity is well |
| maximum pesticide residue limit of 0.0005 ppm (Figure | | | | illustrated through examples of problems faced with |
| 3). To deal with the back-to-back crises, the GOI | | | | exports of fishery products in the late nineties and |
| established a special Joint Parliamentary Committee | | | | the more recent troubles with grape exports to |
| on "Pesticide Residues in and Safety Standards for | | | | Europe. In both cases, although there were signs of |
| Soft Drinks, Fruit Juice and Other Beverages" in | | | | potential problems for a considerable period of time, |
| August 2003 to investigate the allegations. Two GOI | | | | the food safety problems were not given serious |
| Laboratories were instructed to conduct tests on the | | | | attention until India was faced with a crisis. In the |
| 12 brands (but using different samples) and their | | | | case of exports of fish and fishery products, |
| findings showed that 9 of the 12 samples exceeded | | | | necessary monitoring and enforcement measures for |
| the EU limits (Hindu Business Line 2003). Weak | | | | ensuring that exports complied with food safety |
| regulations and inadequate standards were major | | | | concerns were not put in place until the loss of EU |
| causes of these high profile food safety crises. In the | | | | markets in 1997 (Henson, Saqib and Rajasena, 2005). |
| case of bottled water, while the existing norm set | | | | This was despite the fact that India had continually |
| out by the Bureau of Indian Standard (BIS) required | | | | faced rejections because of failure to meet hygiene |
| that "no pesticides should be detectable," the | | | | standards and other food safety requirements since |
| prescribed methodology could only detect pesticides | | | | the 80s, and in spite of regulatory reforms to |
| at extremely high levels. Consequently, GOI issued a | | | | provide safety assurance for fish and fishery |
| notification revising the standards for pesticide | | | | products undertaken in 1995 (Henson, Saqib and |
| residues on bottled water, adopting the EU single | | | | Rajasena, 2005). Similarly, in the case of grape |
| residue limit of 0.0001 ppm and multiple residue limit | | | | exports to the EU, pesticide residue problems had |
| of 0.0005 ppm (CSE 2004). In the case of soft | | | | surfaced since the late nineties. During this period, |
| drinks, the BIS only had voluntary standards, not | | | | some limited testing was done for pesticide residues |
| mandatory standards for pesticide residues. To | | | | in export-oriented grapes. Testing was made |
| address the problem, BIS constituted a 39 member | | | | mandatory in 2000, but most of the available testing |
| committee, consisting of representatives from the | | | | equipment was not up to date, could not test to the |
| soft drinks industry, government scientists, NGOs and | | | | same level of detection as was common in Europe |
| consumer groups to formulate the new BIS | | | | and was unable to detect certain heat-sensitive |
| standards. The outcome was the Indian Ready to | | | | chemicals such as acephate and methomyl (World |
| Serve Non-Alcoholic Beverages Specifications, which | | | | Bank, 2006b).18 Only after EU Rapid Alerts were |
| established the limits for 16 pesticides in the finished | | | | issued in 2003 did the Government and industry step |
| product (0.0001 mg/l for individual pesticides and total | | | | into action to address the problem. In general India |
| pesticide residue limit of 0.0005 mg/l) (CSE 2004). | | | | has not viewed complying with food safety and |
| Even the government-sponsored Mid-day Meals | | | | agricultural health standards as a means to both |
| program encountered serious food safety incidents. | | | | improve its competitive position and to enhance the |
| The National Program for Nutritional Support to | | | | effectiveness of its negotiations on particular |
| Primary Education (NPNSPE), more popularly known | | | | technical and commercial matters, which is in stark |
| as the Mid-Day Meals Scheme, aims to improve child | | | | contrast to the approach of leading agro-food |
| enrollment in primary school and encourage regular | | | | exporting countries (World Bank, 2006b). A |
| attendance by providing supplementary feeding, while | | | | consequence of the lack of pro-activity and the crisis |
| improving their nutritional status. It covers children | | | | management mode of operation has been the |
| enrolled in classes I to IV in government and | | | | adoption of very rigorous and strict controls for |
| government-aided schools in the whole country (Jha | | | | commodities threatened with the loss or disruption of |
| and Umali-Deininger 2003). In June 2006, 85 students | | | | trade. This has led to extremely high costs of |
| from a Chennai primary school were admitted to the | | | | compliance in some cases (e.g. grapes) (World Bank, |
| hospital because of food poisoning after consuming | | | | 2006b) or rather onerous requirements (e.g. |
| food prepared under mid-day meal scheme.4 In | | | | requirements for processing facilities exporting fishery |
| February 2004, 281 children attending municipal | | | | products) (Henson, Saqib and Rajasena, 2005). In the |
| schools in Delhi fell ill and were admitted to the | | | | case of grapes, the Government of India (GOI) |
| hospital after consuming their mid-day meal.5 There | | | | Agricultural and Processed Food Products Export |
| have been many other cases, despite quality norms | | | | Development Authority (APEDA), formulated an |
| being established for the mid-day meal program. | | | | integrated system of intensive grape supply chain |
| While issues related to pesticides in bottle water and | | | | oversight that included • A requirement that |
| carbonated drinks, and out-breaks of food-borne | | | | all farms growing grapes for export to Europe have |
| illnesses received wide media attention, there are | | | | to register with the Department of Agriculture. About |
| other serious domestic food safety concerns that | | | | 6200 growers registered for the 03/04 season; |
| have been identified including heavy metal | | | | • Three field inspections (for registered |
| contamination in foods. Marshall, et al. (2003), tested | | | | exporters) during the crop cycle by a newly |
| fresh cauliflower, okra, and spinach - common | | | | constituted cadre of horticultural field inspectors. |
| vegetables in the Indian diet - in 5 production sites | | | | Some 244 such officers were initially appointed and |
| around the Delhi region and in Delhi's Azadpur | | | | trained. There are now 291 such officers; • |
| wholesale market from May 2001 to June 2003. They | | | | The inspection and registration of all grape export |
| found that 72% of the 222 spinach samples | | | | packinghouses by APEDA. • Mandatory |
| exceeded the Indian MRLs for lead of 2.5 mg/kg, and | | | | pesticide residue testing from each registered field of |
| 100% exceeded the Codex MRL of 0.3 mg/kg. They | | | | export grapes. Testing would be done prior to |
| attributed the high lead content to a number of | | | | harvest and only if the tests were passed would |
| possible causes, including contamination of the | | | | authorization be given for harvesting for export. |
| irrigation water by sewage and industrial effluent and | | | | Grapes from fields with failed results would need to |
| industrial pollution.6 Contamination was exacerbated | | | | be sold in other markets or re-tested. • |
| by their locations-the production sites and market | | | | Every consignment would be checked by AGMARK |
| were in peri-urban and urban areas. When tested for | | | | to ensure conformity with EU quality specifications |
| zinc, 21% of samples exceeded both the Indian and | | | | for grapes. AGMARK would issue certificates. |
| international standards. Currently, however, no regular | | | | • Obtaining a phytosanitary certificate issued |
| testing for heavy metals in vegetables is undertaken | | | | by Plant Protection, Quarantine and Storage for |
| by government agencies in India. Tests undertaken | | | | every consignment; and • Later, in 2005, |
| by the Indian Council for Agricultural Research found | | | | another procedure was added whereby National |
| pesticide residues above the MRL in 5.3% of 666 | | | | Research Center for Grapes would take a 5% |
| samples of vegetables in 2003 and 15% of 468 | | | | sample of ex-packhouse grape consignments to |
| samples of milk tested in 2001 (Directorate of Plant | | | | re-test for pesticide residues. The extensive system |
| Protection and Quarantine 2006). The long term use | | | | of checks and controls primarily focused on |
| of pesticides in agriculture and for disease control | | | | end-of-the-pipeline solutions. In addition to the |
| (e.g. DDT for malaria control) is manifesting itself in | | | | protocols that potential exporters to the EU have to |
| the blood, human milk and fatty tissue in the | | | | follow, the government also invested heavily in |
| population in many states. Table 1 presents the | | | | upgrading laboratory testing equipment, training field |
| results of micro-research studies in selected states in | | | | inspectors, subsidizing packhouse upgrades, and |
| India from 1980 to 2005. | | | | strengthening the National Research Centre for |
| Table 1: Level of DDT and HCH Content in Human | | | | Grapes. Overall, it is estimated that the cost of this |
| Blood Samples in Selected States in India. Location | | | | control system for pesticide residues (to government |
| Year Number of Samples Total DDT (ppm) Total | | | | and the private sector) is about US$1.2 million, |
| HCH (ppm) Lucknow, Uttar Pradesh 1980 25 0.020 | | | | equivalent to 7.9% of the FOB value of India's grape |
| 00.022 Delhi 1982 340 0.710 0.049 Lucknow, Uttar | | | | trade to Europe in 2005 (Table 3). If all other costs |
| Pradesh 1983 48 0.028 0.075 Delhi 1985 50 0.301 - | | | | associated with the oversight of the grape supply |
| Ahmedabad, Gujarat (rural) 1992 31 0.048 0.148 | | | | chain are added to the costs of pesticide residue |
| Ahmedabad, Gujarat (urban) 1997 14 0.032 0.039 | | | | testing, SPS compliance costs are estimated to |
| Punjab (rural) 2005 20 0.0652 0.057 Note: HCH - | | | | account for 13% of this FOB value. |
| Hexachlorocyclohexane Source: ICMR 2001, Mathur et | | | | Table 3: Estimated Annual Cost of Meeting EU SPS |
| al. 2005. | | | | Standards-2005 US $ |
| 6. Food Safety Concerns in Indian Exports | | | | While it is arguable that there are many spillovers and |
| Increased globalization and liberalization of markets, | | | | important lessons that have been learned from the |
| facilitated by the World Trade Organization (WTO), | | | | handling of the pesticide residue problem with grape |
| are opening new export markets for Indian | | | | exports, and that these measures have been |
| agricultural products, both fresh and processed. Indian | | | | "successful" in that they have not resulted in further |
| agricultural exports grew at an average annual rate | | | | alerts or rejections, the heavy handed approach with |
| of 7.2% from 1990/91 to 2003/04. In response to | | | | which the problems were addressed, and the costs |
| these new opportunities, India's agriculture exports | | | | involved, clearly suggest that it is not a strategy that |
| diversified from traditional exports of tea, spices, and | | | | should be replicated. Although India has not faced |
| coffee to include horticultural, fish and livestock | | | | further rejections of exports to the EU, routine |
| products. Between the triennium ending (TE) 1991/92 | | | | laboratory testing still reveals violative residues, |
| and TE 2003/04, the value of fresh and processed | | | | indicative of the continuing need to focus on |
| fruit and vegetable exports rose from US$84 million | | | | improving overall agricultural practices to assure food |
| to US$394 million in real terms (1993/94 dollars) while | | | | safety. Lack of good agricultural, manufacturing and |
| marine product exports rose from US$516 million to | | | | hygiene practices. In addition to constraints that arise |
| US$1.5 billion during the same period (Figure 4). | | | | due to small farm sizes, the lack of good agricultural, |
| As Indian agricultural exports diversified, and the | | | | manufacturing and hygiene practices remain a major |
| value of exports to high income countries increased, | | | | challenge for improving food safety both for the |
| India has had to confront new food safety | | | | domestic and export market. It is only recently that |
| challenges. Concerns over numerous rejections of | | | | efforts are being made to promote good practices. |
| Indian agro-food exports on food safety grounds | | | | For example, Marine Products Export Development |
| have spilled over domestically, generating greater | | | | Authority (MPEDA) promoted codes of good |
| domestic attention to pervasive food safety | | | | practice, particularly with regards to addressing |
| problems in the supply chain including high levels of | | | | antibiotic use. To this extent the organization was |
| pesticide residues, presence of heavy metals in food, | | | | involved in monitoring antibiotic usage levels, providing |
| and micro-biological contamination. The following | | | | training and disseminating information (Henson, Saqib |
| section describes recent food safety challenges in | | | | and Rajasena, 2005). In the spices sector, the Spices |
| Indian horticultural, spice and fisheries exports. | | | | Board (SB) undertook measures to address problems |
| Figure 4: Trend in Agricultural Exports, Triennium | | | | with regards to pesticide residues and aflatoxin. The |
| Ending (TE) 1990/91 to TE 2003/04 | | | | SB, in conjunction with State Departments of |
| Horticultural Exports. In 2004, India exported US$575 | | | | Agriculture and various NGOs, supported measures to |
| million of fresh and processed fruits, vegetables and | | | | promote integrated pest management (IPM) and the |
| flowers. Traditionally India's fresh fruit and vegetables | | | | production of organic spices (Jaffee, 2005). They |
| exports were targeted to markets in neighboring | | | | helped address the aflatoxin concern by promoting |
| South Asian countries, to the Middle East and to East | | | | better drying practices. The Ministry of Food |
| Asia. Since the early 1990s India achieved some | | | | Processing Industries and APEDA have both been |
| success in exporting fresh horticultural produce to | | | | promoting adoption of HACCP and ISO certification |
| Western Europe. India has been quite proud of its | | | | among processed food manufacturers through a |
| penetration into the U.K, Netherlands and German | | | | range of training initiatives and private sector |
| fresh grape markets. Grapes are a highly seasonal | | | | investment grant for upgrading processing plants to |
| crop and Indian exporters have been targeting a | | | | obtain HACCP/ISO certification. However, the |
| crucial March to April window in the European market, | | | | adoption of good practices remains limited. Much |
| which falls at the end of the main southern | | | | remains to be done in improving practices with |
| hemisphere production season (in South Africa and | | | | regards to the manufacture and use of pesticides |
| Chile) and before Egypt and Turkey enter the | | | | and improving post harvest techniques. Although |
| market. Virtually all of India's grape exports are of | | | | there have been some limited spillovers from the |
| the Thompson Seedless variety. The Indian grape | | | | export sector into the domestic market, in terms of |
| export crisis in May 2003 was a pivotal wake-up call | | | | improving production practices, for most |
| to Indian exporters concerning the costs of failing to | | | | commodities, including spices and fresh fruit and |
| meet food safety standards. In the midst of a | | | | vegetables, farmers do not necessarily see any |
| commercial dispute with an Indian grape exporter, a | | | | advantages or necessity for altering their production |
| Dutch importer had samples of the Indian grapes | | | | practices since the vast majority of production is |
| tested by a private laboratory. On finding that the | | | | consumed in the domestic market. Until domestic |
| grapes contained residues of the insecticide | | | | consumer awareness and willingness to pay for |
| methomyl in excess of the EU maximum residue limit | | | | improved food safety becomes more widespread, it |
| (0.05 microgram/kg.), the importer placed an | | | | is unlikely that addressing food safety concerns will |
| advertisement in the local paper warning that grapes | | | | become standard practice nationally. Similarly, |
| from this Indian supplier contained "poison" (World | | | | significant measures are needed to improve the |
| Bank, 2006b). Dutch authorities, who were alerted | | | | safety of processed foods. In the food processing |
| about the finding, tested samples from the 28 | | | | sector there are a growing number of firms with |
| containers of Indian grapes then in Rotterdam port | | | | modern factories and good quality assurance |
| and found that about 75% of the samples exceed | | | | systems, but this segment co-exists with large |
| the MRLs for methomyl and/or acephate.7 The | | | | numbers of small and older firms that would need to |
| problem was reported on the EU Rapid Alert system, | | | | make significant upgrades to implement HACCP and |
| causing not only significant short term economic | | | | other quality assurance systems.19 In the short term, |
| losses, but also considerable longer term reputation | | | | developments in the food retail sector in India are |
| damage. The price of Indian grapes dropped sharply, | | | | likely to bring about improvements in food safety. |
| and the Indian grape shippers incurred losses, either in | | | | International experience shows that modernization of |
| Dutch sales or by diverting the shipments to other | | | | the food retail sector is an important driver for |
| markets. | | | | change not only in the structure of production and |
| Spice Exports. India is the world's largest consumer | | | | wholesale marketing of produce, but also in fostering |
| and producer of spices and is also a significant | | | | adoption of improved grades and food safety |
| exporter of spices (Jaffee, 2005). In 2004/05, India's | | | | standards (Berdegué et al 2003, Reardon and |
| spice exports totaled US$399 million. India, however, | | | | Timmer 2005a, 2005b). Despite the ban on foreign |
| has encountered a number of food safety problems | | | | direct investments in food retailing, the supermarket |
| in its spice exports including high pesticide residues, | | | | industry is growing rapidly, driven by investments |
| aflatoxin contamination and the use of prohibited | | | | from the Indian corporate sector.20 Many of the |
| food colorants. In the mid-nineties, Indian dry chili | | | | modern retail outlets are beginning to undertake |
| exports faced several rejections including rejections in | | | | direct procurement from individual farmers or |
| Spain due to pesticide residue in excess of | | | | farmers' associations. In some cases farmers or |
| permissible MRLs, and in the United States because | | | | associations supplying these outlets are required to |
| residues of quinalphos, a pesticide not registered in | | | | follow a code of practice to meet quality and safety |
| the United States (Jaffee, 2005). Between 1998 and | | | | requirements of their buyers. |