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Food Safety in India: Challenges and Opportunities

Md. Wasim Aktar* use of prohibited food colorants. In the
Pesticide Residue Laboratory, Department mid-nineties, Indian dry chili exports
of Agricultural Chemicals, faced several rejections including
Bidhan Chandra Krishi rejections in Spain due to pesticide
Viswavidyalaya, Mohanpur-741252, Nadia, residue in excess of permissible MRLs,
West Bengal, India and in the United States because residues
1. Introduction of quinalphos, a pesticide not registered
Rising incomes and urbanization, an in the United States (Jaffee, 2005).
expanding domestic consumer base Between 1998 and 2000, Indian dry chili
concerned about food quality and safety, exports also faced rejection in Germany,
and rapidly growing agricultural exports Italy, Spain and the U.K. due to the
have been important drivers for the presence of aflatoxin.8 More recently,
increased attention to food safety in exports of chili and curry powder faced
India. But the development of effective problems due to the use of the prohibited
food safety systems is hampered by a red dye Sudan 1 (Jaffee, 2005). In
number of factors, including: restrictive February 2005, a massive recall of some
government marketing regulations, weak 600 food products took place in the UK
policy and regulatory framework for food because of the detection of Sudan 1 in
safety, inadequate enforcement of Worcester sauce. This was the largest
existing standards, a multiplicity of ever food recall in the U.K. and it
government agencies involved, weak market affected all major retailers as well as
infrastructure and agricultural support large numbers of food manufacturers and
services. The small farm structure food service companies, as the Worcester
further limits farmer capacity to meet Sauces had been used in the preparation
increasing domestic and export food of a large number of different products.
safety and SPS requirements. Addressing It is estimated that this recall, and
food safety concerns in India will associated expenses, cost the U.K. and
require adoption of appropriate other European food manufacturers some
legislation, strengthening capacity to 200 million Euros (Jaffee, 2005). The
enforce rules, promoting adoption of good source of the Sudan 1 dye in the
agricultural, manufacturing and hygiene Worcester sauce was traced to chili
practices, greater collective action, and powder imported from India in 2002.
some targeted investments. Implementing Fish and Fish Product Exports. Fish and
these actions will require joint efforts fish products are one of India's
by the government and the private sector. largestagricultural export earners,
Developing countries are paying increased totaling US$1.3 billion in 2004/05. Over
attention to food safety, because of the years, India hasencountered several
growing recognition of its potential food safety problems with its fish and
impact on public health, food security, fish product exports. Most prominent, in
and trade competitiveness. Increasing 1997, the European Commission found the
scientific understanding of the public industry to be non-compliant in
health consequences of unsafe food, maintaining hygiene standards in fish
amplified by the rapid global processing plants. In May 1997 the
transmission of information regarding the European Commission banned Indian exports
public health threats associated with of fresh crustaceans and cephalopods and
food-borne and zoonotic diseases (e.g. E. imposed border testing for Salmonella and
coli and salmonella, bovine-spongiform Vibrio spp. for frozen products (Henson,
encephalopathy (BSE), severe acute Saqib and Rajasena, 2005). Because of
respiratory syndrome (SARs) and H5N1 continued detection of salmonella, all
avian flu) through various forms of media exports of fish and fishery products to
and the internet has heightened consumer the EU from India were banned in 1997.
awareness about food safety risks to new While India has for the most part been
levels globally (Lindsay 1997, Unnevehr able to address the hygiene-related
2003, Buzby and Unnevehr 2003, problems plaguing its export of fishery
Kafersteing 2003, Ewen et al. 2006, products in the late nineties, Indian
Bramhmbatt 2005). Increased understanding exports are now under scrutiny because of
of the impact of mycotoxins, which can problems related to antibiotic residues
contaminate dietary staples such wheat, and bacterial inhibitors (antibiotics,
maize, barley and peanuts, has further preservatives and chlorine) (Henson,
raised food security and public health Saqib and Rajasena, 2005). It is widely
concerns in many developing countries acknowledged that in the future, heavy
(Dohlman 2003, Bhat and Vasanthi 2003, metals and other contaminants could be an
Unnevehr 2003). emerging issue particularly because of
As developing countries seek to expand the increased attention to heavy metals
agricultural exports especially to in the EU. Surveillance of fisheries
OECDcountries, many are receiving a products for heavy metals has already
wake-up call on the challenges of meeting begun in the U.K.
both government and private sanitary and Although India has been able to broadly
phyto-sanitary (SPS) standards in export comply with food safety requirements for
markets (Otsuki et al. 2001, Henson 2003, each of the export commodities mentioned
Unnevehr 2003, World Bank 2005a). Private above, it continues to face problems
standards or supplier protocols have across a range of agro-food exports.
grown in prominence over the past decade Evidence of continuing trouble is clearly
as a means to further ensure compliance apparent from Import Refusal Reports
with official regulations, to fill issued each month by the USFDA for food
perceived gaps in such regulations, and and drug imports into the United States.
or to facilitate the differentiation of Most recently, in both April and May
company or industry products from those 2006, India had one of the highest
of competitors. Trends in private rejections among all countries exporting
standards increasingly tend to blend food to the USA; India faced 176 rejections in
safety and quality management concerns May, 2006 and 211 rejections in April,
(i.e. the recent creation of ISO 22000), 2006.9 While a significant number of the
or to have protocols which combine food 176 rejections were issued for drugs and
safety, environmental, and social (child cosmetics, the grounds for rejection
labor, labor conditions, animal welfare) among the various food items included
parameters (Willems et al. 2005, World salmonella and/or filth in raw peeled
Bank 2005). At the same time, increasing shrimp, prepared Indian breads (paratha,
globalization of trade introduces greater roti), basmati rice, sesame seeds,
risks of cross-border transfer pepper, coriander and chili powder;
offood-borne illnesses. Recent cases of pesticide residues in lentils; failure to
disease episodes in the United States declare the color additive FD & C Yellow
resulting fromimported food produce, such No. 5 in banana chips; and unsafe
as cyclospora from raspberries, hepatitis coloring in cream biscuits. The number of
A from strawberries and salmonella from rejections and the range of problems
cantaloupe (Calvin 2003), illustrate to reveal extensive safety problems in
developing countries the potential food Indian food products. It is also
safety challenges that can arise in a reasonable to assume that the extent of
more globalized market. the problems faced by domestic consumers
Weaknesses in food safety systems can is far more serious as there many more
have a high cost to society and the micro, small and medium enterprises that
global economy. The World Health cater to domestic consumers and generally
Organization (WHO) estimates that 2.2 pay less attention to food safety issues.
million people worldwide die from By contrast, exporters are likely to be
diarrheal diseases caused by a host of more well-established and larger firms
bacterial, viral and parasitic organisms, with better technology and relatively
which are spread by contaminated water more cognizant about food safety
(WHO 2006a). In India, it is estimated concerns.
that 20% of deaths among children under 7. Challenges to Improve Food Safety in
five are caused by diarrheal disease (WHO India
2006b). The SARs outbreak in 2003 in East Improving food safety in India, whether
Asia is estimated to have caused an for the domestic market or for export
immediate economic loss of about 2% of trade, is hampered by a number of
the Region's GDP in the second quarter of structural, policy, institutional,
that year, even though only 800 people technical and cultural barriers.
died from the disease (Brahmbatt 2005).1 Policy and Regulatory Environment. A
The Lowy Institute for International number of policies and regulations
Policy (2006) estimates that a mild governing agricultural marketing and food
global outbreak of the avian flu can cost processing complicate the implementation
the world 1.4 million lives and close to of food safety measures by the government
0.8% of GDP (US$330 billion) in lost and by the private sector. Two critical
economic output. At the same time, marketing regulations are the State level
country reactions to protect its citizens Agricultural Produce Marketing
from food safety risks can also have (Development and Regulation) Acts and the
large consequences for exporting Small Scale Industry Reservation Policy.
countries. Otsuki et al (2001) examined Almost all states in India have an
the projected impact of the EU's new Agricultural Produce Marketing (APM) Act,
harmonized aflatoxin standard on the which gives state governments the sole
value of trade flows to 15 European authority to establish and manage
countries from 9 African countries and wholesale markets.10 The Act, adopted by
found that it could decrease African most states in the 1960s and 1970s,
exports by 64% (US$670 million). prescribes the setting up of a network of
Food safety concerns are getting state controlled "regulated markets" or
widespread attention in India. The mandis and the establishment of Market
country's rural development strategy, for Committees to operate each. All
which a key element is the promotion of "notified" agricultural commodities grown
increased agricultural exports as a means in areas surrounding the market are
to foster rural growth and poverty required by law to be sold only through
reduction, is coming up against these markets, with the number of
tightening food safety and SPS standards notified commodities varying by state and
in prospective markets (World Bank 2006a, market. Implementation of the Act and its
2006b). From a domestic perspective, the enforcement vary considerably by state.
large national market of 1.2 billion In 2005, there were nearly 8,000
people is undergoing rapid change. regulated markets in the whole country.11
Increasing incomes, a growing middle The requirement that all agricultural
class, increased urbanization and commodities be channeled through the
literacy, and a population highly tuned regulated markets not only increases
to international trends fueled by the transactions costs, but is also a major
information technology boom are creating obstacle to preserving produce quality
a large consumer base giving increasing and traceability. In 2003, the GOI
value to food quality and safety. formulated a model Agricultural Produce
Improving food safety systems, to meet Market Act for state governments to
domestic and export requirements, adopt, which removes the restrictions on
however, face a number of policy, farmer direct sales and permits entities
regulatory, infrastructural and outside of government to establish and
institutional obstacles. operate wholesale markets. To date only
2. OBJECTIVES 10 of the 28 states and Union Territories
(i) To review the main drivers for the have adopted the model Act.12
increased priority to addressing food The Small Scale Industry (SSI)
safety risks in India in both the export Reservation restricts the processing of
and domestic markets, (ii)To examine the certain commodities to the small scale
nature and effectiveness of government sector. Although the list of commodities
and private responses to the food safety subject to this restriction has been
challenges, with special focus on high reduced significantly during the last
value agriculture; (iii)To identify the decade, several processed agricultural
constraints to more effective responses; products are still subject to SSI
(iv) To examine the implications for reservation, such as rapeseed, mustard
policy; v) To review food safety with and ground nut oil,13 bread, pastry,
special relation to Pesticides; and vi) pickles and chutneys, and hard boiled
To discuss briefly about the food safety sugar candy (Department of Small Scale
from consumer point of view. Industries 2006). The SSI reservation
3. Types of Food Safety Risks imposes constraints on enterprises'
Food safety risks, as they relate to ability to undertake the necessary
human health, arise from of a number of investments (e.g. HACCP) and
factors. These include: (i) microbial certifications required to meet the
pathogens (bacteria, viruses, parasites, domestic and international food safety
fungi and their toxins); (ii) pesticide and SPS requirements.14
residues, food additives, livestock drugs There is a complex web of laws governing
and growth hormones; (iii) environmental the processed food sector which
toxins such as heavy metals (e.g. lead complicate implementation of food safety
and mercury); (iv) persistent organic measures. These laws are enforced by 8
pollutants (e.g. dioxins); and (v) different ministries. Some of the most
zoonotic diseases (e.g.Avian flu, critical are: Prevention of Food
Japanese encephalitis, tuberculosis) Adulteration Act 1954 implemented by the
(Buzby and Unnevehr 2003, Ewen et al. Ministry of Health and Family Welfare;
2004).2 The health risks associated with Milk and Milk Products Order 1992 and
these agents impact the whole food supply Agricultural Produce Grading and Marking
chain, starting from input supply to the Act 1937 implemented by the Ministry of
farm to the consumer table (Figure 1). Agriculture; the Essential Commodities
Figure 1 Food Supply Chain: Potential Act 1955, Standards of Weights and
Sources of Food Safety Hazards Measures Act 1976, Consumer Protection
Common use of pesticides in modern Act 1986, and Bureau of Indian Standards
farming inevitably leaves some residues Act 1986 implemented by the Ministry of
on food crops. Food, Consumer Affairs and Public
Potential food safety hazards at HOME can Distribution; the Fruit Products Order
be divided into three categories: 1955 implemented by the Ministry of Food
1. Biological Processing Industries; import and export
2. Chemical regulations implemented by the Ministry
3. Physical of Commerce; Trade in Endangered Species
While all the above type of hazards are Act implemented by the Ministry of Forest
important from viewpoint of prevention, and Environment; Atomic Energy Act 1962
the focus here will be on the Control of Irradiation of Food Rule 1991
microbiological hazards and in that on implemented by the Ministry of Science
foodborne bacteria, which can lead to and Technology; and Infant Milk
illness if the food is mishandled, Substitutes, Feed Bottles and Infant
particularly for those more at risk -- Foods (Regulation of Production, Supply
the very young, the elderly and the and Distribution) Act 1992 implemented by
immuno-compromised. the Ministry of Human Resource
Certain processes or handling practices Development (Patnaik 2005).
by consumers in the home have been These laws also authorize several
identified as being essential or critical agencies to lay down standards for food
in preventing foodborne illness. These products: (i) Bureau of Indian Standards
practices, which prevent or control the (BIS) of the Ministry of Food, Consumer
"meals" microbial contamination Affairs and Public distribution under the
associated with foodborne illness, are BIS Act, (ii) Ministry of Food Processing
under the direct control of the consumer, Industry under the Fruit Products Order,
from food acquisition through disposal. (iii) Ministry of Agriculture under "Ag
They are purchasing, storing, Mark" and the FPO, (iv) Ministry of
pre-preparation, cooking, serving, and Health and Family Welfare (MOHFW) under
handling leftovers. Failure to take the PFA Act; (v) Export Inspection
appropriate action at these critical Council under the Export-Import Policy,
points could result in foodborne illness. and (vi) the Defense Ministry for their
4. Pesticides and Food Safety own purchases.
Fruits, vegetables and cereal crops These laws and associated regulations in
treated with pesticides are perceived by some cases prescribe contradictory or
some as a health risk, and this belief differing standards. For example, while
along with affordability, and time the Fruit Products Order (FPO) allows the
pressures may all play a role in limiting use of artificial sweeteners in fruit
consumption of plant foods, such as products, the Prevention of Food
cereal grains, fruit and vegetable Adulteration (PFA) Act bans it. Mandatory
consumption of consumers in Asia. The declaration labels required by the PFA
World Health Organisation (WHO), the differ from those of the Packaged
World Cancer Research Fund (WCRF) and Commodity Regulation Rules (1977) under
many other national and the Standard Weights and Measures Act.
inter-governmental agencies recommend The emulsifier and stabilizers permitted
that adults consume at least 400g of for use in jams and chutneys under the
fruit and vegetables per day and 25-30 PFA differ from those allowed under the
grammes of dietary fibre per day, but FPO.
analysis of current dietary patterns In 1998, the GOI began the process of
around the world indicate that many rationalizing the legal and regulatory
consumer are not achieving these dietary framework for food and food processing.
goals, particularly those who are less The Prime Minister's Council on Trade and
affluent. AFIC's Short Briefing on Industry established a Task Force on Food
Pesticides, Food Safety and Health is and Agro-Industries Management Policy to
intended to provide a science-based recommend options for rationalizing the
factual overview of the issue, to enable various policies and regulations. The
consumers to make better informed choice outcome was a new Food Safety and
about their diet, in particular fruit, Standards Bill, which was submitted to
vegetables and grains consumption, and Parliament in August 2005 and is awaiting
allay unwarranted anxieties and concerns. approval. The Bill aims to consolidate
Definition of Pesticide: The Food and the laws relating to food. The key
Agriculture Organisation (FAO) defines a provisions of Bill include: (i) the
pesticide as 'any substance or mixture of repeal of a number of Acts and Orders;15
substances intended for preventing, (ii) the establishment of a Food Safety
destroying, attracting, repelling, or and Standards Authority of India; (iii)
controlling any pest including unwanted definition of the standards for food
species of plants or animals during the additives, contaminants, genetically
production, storage, transport, modified and organic foods, packaging and
distribution, and processing of food, labeling, and food imports; (iii)
agricultural commodities, or animal feeds accreditation of laboratories, research
or which may be administered to animals institutions and food safety auditors;
for the control of ectoparasites' (iv) licensing and registration of food
Natural Toxins: Substances that are business and setting penalties for
capable of causing cancer are virtually offenses; and (v) establishment of a Food
everywhere, even in natural compounds. Safety Adjudication Tribunal (Ministry of
The FDA estimates that the intake of Food Processing Industries 2005).
carcinogens from man-made pesticide Approval of the Bill will be an important
residues is extremely small compared to milestone in strengthening food safety
carcinogenic residues that plants produce systems in India.
naturally. There are a large number of government
According to Bruce Ames, a professor of agencies involved in agricultural
molecular biology and biochemistry at the marketing activities, more broadly or
University of California, more than 99.99 with respect to specific commodities,
percent of the pesticides Americans which complicates effective
ingest are "nature's pesticides" or implementation of a coherent food safety
"natural toxins" (Hotchkiss, 1992; Moore, strategy for the country. As in the case
1989). of the soft drink contamination, the
Natural toxins are present in all plants multiple laws and agencies added to the
and such food products as beans, lettuce, confusion. The BIS was charged with
apple juice, wine, black pepper, spinach, setting the standards for pesticides in
peanut butter and many others. Of the soft drinks, while the MOHFW is charged
known natural toxins, which concentrate with setting the pesticide standards for
in parts per thousand versus parts per bottled water.
billion in synthetic pesticides, none has Smallholder Agriculture. The current
been shown to cause cancer (Hotchkiss, structure of the farm sector in India
1992; Moore, 1989). constrains farmer capacity to meet
Reasons of pesticide residues in food domestic and international food safety
Pesticide residues may be present in food standards. Farming in India is dominated
because of the following reasons: by small farmers - the average farm size
1) Direct use of pesticides on food in 1990/00 was 1.8 ha (NABARD 2002). Most
crops; farmers face credit constraints (World
2) Animal feeding on pesticide treated Bank 2004), and literacy rates are low.16
feed; These constraints impose limits on the
3) Environmental contamination number of farmers capable to adopt more
Pesticide Use on the Farm: Many of sophisticated farm practices and
today's food producers are taking an undertake the necessary investments (e.g.
Integrated Pest Management (IPM) approach land improvements, obtaining necessary
to preventing, reducing or eliminating certifications, cold storage) to meet
pest problems. Growers and processors more stringent food quality and safety
must make complicated decisions prior to requirements. They increase the cost of
planting, during the growing season, and transacting business and monitoring
during postharvest handling. Scientific compliance with food safety standards.
IPM strategies give the grower economic Stringent land policies, e.g. land
incentives for sustaining long-term crop ceilings and restrictions on land rental,
protection with minimal disruption to the limit possibilities for greater land
environment. The agricultural community amalgamation (World Bank 2006c).
typically will use pesticides judiciously International experience indicates,
as part of the IPM strategy whenever however, that farm size constraints may
proven alternatives are not available for be overcome through innovative
pest control. Growers are hiring interventions such as organizing farmers
professional crop consultants with into producer groups, establishing
increasing frequency for advice on collection centers (by supermarkets and
maintaining or increasing production exporters), using contract farming
through the utilization of IPM programs arrangements, and by creating
structured toward their specific public-private partnerships to assist
agronomic situations. farmers in a variety of ways, including
Integrated pest management: It is an help in obtaining the capital required to
ecological approach to pest management in make on-farm improvements and other
which all available control techniques investments (e.g. grading or cooling
are consolidated into a unified program facilities), developing and improving
so that pest populations can be managed farming skills through joint extension
in such a manner that economic damage is provision, and assistance in acquiring
avoided and adverse side effects are the required national and international
minimized. Practices used as a part of certifications (Berdegué et al. 2003,
this management philosophy include the Boselie et al. 2003, Dries et al 2004,
following: 1) destruction of crop debris, Reardon and Swinnen 2004, Reardon and
2) having pests feed and concentrate on Timmer 2005a, 2005b).
trap crops, 3) crop rotation, 4) In order to address various food safety
selectivity of planting and harvest concerns in both the spices and fresh and
dates, 5) soil test analysis for crop processed fruit and vegetable sectors,
nutrient needs, 6) planting crop species some exporters initiated contract farming
adapted for local conditions, 7) using operations or "vendor screening"
genetically improved crop varieties with programs. One industry that has been
resistance to specific pests, 8) using especially successful in establishing
biological control, 9) predicting pest contract farming arrangements and meeting
outbreaks with computers, 10) pheromones stringent food safety and quality
for trapping pests, 11) scouting and standards is the pickled gherkin
monitoring for pests, 12) economic industry. The industry, consisting of
thresholds as guides to pest control, 13) some 42 companies and nearly 50,000
better timing