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