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