Ensure Credible Risk Management & Risk Analysis to develop credible Food Regulation

Vijay Sardana & Priyanka Sardana

EVERY country develops a food regulatory mechanism to protect public health. The challenge is the credibility. Let me raise the issue of credibility at outset. Have we ever conducted a survey to find out how many people trust food safety authorities in India? How many people in India feel food safety authorities are doing what they are suppose to do? A survey of members of every state assembly should be conducted. We should find out from people’s representatives, what they think about food safety status in their own state? The responses will very exciting to note.

Food Safety Authority should Protect Consumers

While recognizing the dual purposes of the food safety authority i.e. protecting the health of consumers and ensuring fair practices in the food trade, the authority’s decisions and recommendations on risk management should have as its primary objective – the protection of the health of consumers.   

In many meetings it was observed that various interest groups had worked overtime to protect their commercial interests with a pretext these were minor things and could be ignored. Or very often argument was “how many consumers know what they are eating”? Any forward looking food safety management system must avoid unjustified differences in the level of consumer health protection to address similar risks in different situations. Very often there is a case of over-simplification without going into details of complex technical matters and that should be avoided. This is a common problem in the prevalent system. This is one of the important reasons, why the credibility of food regulatory authority is criticised.

Transparency will bring Trust

In order to ensure confidence of stakeholders, it is high time all the agenda papers, like codex, must be on the website of authority, with the response from all the stakeholders to the agenda.

In fact, Food Authority should place the list of all committee members with their bio-data and experience on the subject, for which they are called to join the committee. Authority should also indicate who is representing which interest group. This is vital to ensure whether there is a conflict of interests or not.

We are looking forward for that day when we as consumers will be able to get the details about the people who are deciding the issues
on health of our children and our own.

Risk Analysis procedure must be transparent and objective

According to Codex Alimentarius, Risk management should follow a structured approach including preliminary risk management activities, evaluation of risk management options, monitoring and review of the decisions taken. The decisions should be based on risk assessment. They should take into account, where appropriate, other legitimate factors relevant for the health protection of consumers and for the promotion of fair practices in food trade, in accordance with the established criteria for the consideration of the other factors.

The current system is in fact criticised a lot because of this aspect. The current system is based on committee approach and all the evidences are asked from the applicant, say in case of approval of certain additives. Now we know that many findings in drugs discovery and data showing their effectiveness need revalidation. What is the mechanism with food safety authority to cross check the data provided by the applicants? Where are the scientific back-ups with consumer groups in India? Who is monitoring the health implication of various inputs permitted in various foods for various sections of society?

Due to lack of data, decision-making is relied on the published information from other parts of the world. There is no harm in adopting these provided we have developed similar simulation models in relation to our consumption habits. This is an important aspect in risk analysis.

Who is conducting risk assessment in India?

The Codex Alimentarius Commission and its subsidiary bodies, acting as risk managers in the context of these Working Principles, ensures that the conclusion of the risk assessment is presented before making final proposals or decisions on the available risk management options, in particular in the setting of standards or maximum levels, bearing in mind the guidance given.

In case of India who is undertaking the risk assessment activity for various products and additives. There are large numbers of traditional foods in which manufacturers add various additives. There is no database available about these products and the role of additives.

We have rarely seen any discussion paper on the agenda items about the need, its significance and what is the loss or gain because of the modification proposed in food laws. What we see is the application from the interested party who is looking for the addition of a new additive? We have never seen a document or agenda from authority itself regarding the revision of the limits of additives.

In achieving agreed outcomes, risk management should take into account relevant production, storage and handling practices used throughout the food chain including traditional practices, methods of analysis, sampling and inspection, feasibility of enforcement and compliance, and the prevalence of specific adverse health effects.

Role of Food Laboratories needs auditing

The state of affairs in food laboratory in India also need independent audit from an agency, which cannot be influenced. It is high time that all private as well as government laboratories must declare the number of samples tested, how many of them found substandard or adulterated. With no records available to public, an ordinary citizen has no idea what is going on in the food safety situation in India. Under e-governance programme, government of India must undertake this initiative. The food safety authority should ensure this happen in time bound manner.

Risk Management Process must be documented and transparent

The risk management process should be transparent, consistent and fully documented. FSSAI decisions and recommendations on risk management should be documented, and where appropriate clearly identified in individual standards and related texts so as to facilitate a wider understanding of the risk management process by all interested parties.

The outcome of the preliminary risk management activities and the risk assessment should be combined with the evaluation of available risk management options in order to reach a decision on management of the risk.

Risk management options should be assessed in terms of the scope and purpose of risk analysis and the level of consumer health protection they achieve. The option of not taking any action should also be considered. The justification for the same should be provided.

Very often justification behind the government decisions is not given. This raises the doubt about the reason for change.

Food Authority and Imported Foods

In order to avoid unjustified trade barriers, risk management should ensure transparency and consistency in the decision-making process in all cases. Examination of the full range of risk management options should, as far as possible, be taken into account an assessment of their potential advantages and disadvantages. When making a choice among different risk management options, which are equally effective in protecting the health of the consumer, the food authorities and other related bodies should seek and take into consideration the potential impact of such measures on trade.

Why Indian Authorities not taking action against defaulters?

When it comes to imported products, we have seen substandard products, banned additives, wrong labelling, many other deficiencies are present in the imported products. We have not seen any action taken by any authority.

There should be a list of detained products. Their origin and importers’ details should also be recorded which is a practice in USA and EU. Why authorities are hiding such information about their activities at entry points of the country? In case if these issues are not important and there is no need to take action in that case why Indian manufacturers are asked to follow all the restrictions defined under Indian Laws. Somewhere it appears that Indian food authorities are keener to stop the development of domestic industry and more lenient on people importing food products which are violating Indian food laws. Why they are doing like this is best known to them? There can be only two reasons; either they are not aware of the rules of the land or they have some other vested interest, which is more important than national interests and public health. In both the cases, responsible authorities must take suitable action. What is the assurance that such system can protect India from terrorists’ attack or bioterrorism through food?

Risk Management and Economic Consequences

Risk management should take into account the economic consequences and the feasibility of risk management options. Risk management should also recognize the need for alternative options in the establishment of standards, guidelines and other recommendations, consistent with the protection of consumers’ health. Risk management should be a continuing process. It should take into account all newly generated data in the evaluation and review of risk management decisions. Food standards and related texts should be reviewed regularly and updated as necessary to reflect new scientific knowledge and other information relevant to risk analysis.

Considering the SSI nature of Indian food industry, FSSAI and state governments must have a fund allocation for capacity building otherwise, they will face lot of hardship in implementation and the desired objective of good food in a cost effective manner will be defeated.

It is a big task for food authority to ensure fair deal for every one and at the same time ensure the stated objectives. The best way to ensure both is by transparency in decisions and competency of committees.






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