Food regulation anywhere in the world is a difficult and challenging task. The best of regulations have to face challenges. Food regulation is expected to be a facilitator for the industry, but very often they both are at loggerheads.
Though industry respects regulation, it gets frustrated when they are not clear and reasonable. Developed countries have gone through several encountering controversies and have come out with highly transparent and technically valid methods combining industry and consumer friendly measures to an extent that such problems have become infrequent.
India, till 2006, had a food regulation act, which in principle was aimed at preventing adulteration. With formation of the Food Safety and Standards Authority of India (FSSAI), expectations among stakeholders shot up. However, the FSSAI had teething issues and has been trying to come to terms with them. Despite this, over the last five to six years the progress has not been too satisfactory. Neither the industry nor the consumers are satisfied.
For food regulation to be efficient, it needs:
Adequate infrastructure and quality international standards in testing and analysis
Defined protocols for every aspect of the regulatory process including, product approvals, setting standards, scientific reviews, innovations, claims, development of meaningful procedures for approvals, monitoring, testing, legal procedures, enforcement, emergency management etc.
Constant updating of the science of food regulation in sync with international practices.
Good interaction with the food industry while ensuring compliance as well as understanding the limitations that may exist.
Well-trained, knowledgeable, updated and motivated manpower
Dynamic and scientifically inclined positive thinking management. The very basis of food safety is a good understanding of the risk assessment process and its management. Every ingredient of a particular food has benefits if consumed within the acceptable limits. If consumed in excess, based on scientific studies and evidences in the population, they may carry a risk which should be understood vis-a-vis the benefits which we accrue by consuming.
The best evidence of human safety for a food ingredient is the history of safe human use anywhere between 30 years and several centuries, as in the case of traditional foods. History of safe use could be obtained from other populations across the world unless there are scientific evidences to believe that we Indians are a species that respond differently.
With the availability of an array of information on the net, consumers have empowered themselves with knowledge, only some of which are scientific while most are anecdotal, hearsay and unsubstantiated.
Even if there arises a situation when any serious hazard is identified, the regulation should instantly but systematically study every aspect of the hazard with adequate checks, counter-checks and validation before any action is taken. This, for example, is what should have been done in the matter of heavy metal contamination of a popular food.
Proper documentation, adequate controls, repetitive samples, external validation in other labs with same sample, review of the industry’s own QC data, additional market and industry samples should all be tested and every loophole plugged to make the findings robust, confidant and reproducible. Penal actions shall follow only after such a dossier is prepared and shared in the public domain.
Public confidence is paramount for a regulator. There need to be predefined protocols so that every member involved in regulation knows what he/she is expected to do under such circumstances. Regulation should also not be based on beliefs, apprehensions, hearsay, political pressures, international pressures, activism or so-called tradition and local practices etc. Every decision made should have a scientific basis and nothing else.
Since science-based limits and acceptable daily intakes are set for most food components as well as contaminants and harmful substances, regulation should be relatively easy. In case of new information about a safety concern, the scientific panel should make a review-based best decision and the regulation could adopt it after an open discussion.
A constant channel of communication should be made available to the regulator to interact with consumers and the industry. There should also be a voluntary recall procedure where the industry in itself decides to withdraw a product from the market based on their in-house testing data.
The future of the massive food industry and the safety of the Indian consumer depends on reliable regulation and the government should spare no effort to deliver the best.
(The writer is former Director, National Institute of Nutrition, ICMR)
