Joseph LewisSixty eight percent of all milk is adulterated by FSSAI’s own analysis, food poisoning episodes typically erupt at marriage celebrations, restaurants served notices for unhygienic conditions and children fall ill consuming sweets. All this is appetizing information for print and media gossip, but should’nt consumers be informed about the nature of the hazards that caused these adverse events?
Image via iStock.com
What do authorities mean when they say a food is adulterated. Is milk intentionally diluted with water – economic fraud? Are sweets spoiled due to bacterial contamination (high plate counts)? Did school children fall sick because of an identified pathogenic bacteria e.g. salmonella, shigella or other? Are these hazards repeatedly found to occur in the same food type, like milk products? Are enforcement measures adequate or sensibly applied to reduce occurences so that consumers know public health is improving. More needs to be revealed … as authorities and media keep raising the scourge of adulteration in the country.
Image via iStock.com
Adulteration gained importance during the war period when extreme food shortages encouraged rampant adulteration. To address the problem, foods using certain names were mandatorily required to meet prescribed compositional standards, referred to ‘standards of identity’ (e.g. jam (minimum fruit content), margarine (minimum fat content), chocolate (cocoa fat), etc. Nothing could be added or abstracted or substituted from the food on sale. Any deviation from the standard, is adulteration.
Image via iStock.com
Standardization served a useful purpose at the time but later perversely used as a control measure. Unreasoned standard setting dominates Authority work, with scant attention to consequent costs, inspectorate burden, and whether the standard is fullfilling its intended purpose. Not every perceived market imperfection deserves a standard. In a country where unregulated food industry – often larger than its regulated cousin – operates outside the ambit or radar of the regulator, the latter bears the brunt of enforcement focus. Witness the large number of food pre-packages of savouries (banana chips, chakli, lying on food shelves without a label; contrary to the law.
Image via iStock.com
More than 400 product standards (vertical) exist and more keep coming; however product standards rarely deal with safety. Safety of all foods is provided by the General Standards, often referred to as horizontal standards. Enforcing vertical product standards engages disproportionate attention, time and resources of the the Food Authority and its inspectorates. While its activity is often known through raids, seizures, drives or surveys, public safety outcomes are unknown , impact of standards unquantified and its cost effectiveness uncalculated.
A public laboratory testing report (FSSAI: 2014-15), 68,197 food samples were collected nationally, of which 60,548 were analysed and 12077 found adulterated; approximately 17.7 % of samples tested. The impact of this enforcement activity resulted in 1355 convictions (2% of tested) and penalties amounting to approx Rs. 10.6 crore collected. Considering analytical costs only – excluding all other costs due to inspectorate time, administration, court and prosecution expenses etc – of Rs 3000 per sample, the total cost of analysis would be in excess of Rs. 18 crore. Add a further- almost equivalent cost borne by Industry – to the analytical cost of Rs. 18 crore borne by the regulator which represents the total cost burden on consumers. This raises the question. Is the inspection prioritized on risk, food sector or food failure or merely casual and random ?
While repeated offenders merit prosecution and strict oversight, the Authority ought to also reveal that the general majority of food business operators are compliant. More revealingly and often unpublished is the fact that approx 82% of samples conformed to standards. FDA Delhi which maintains an excellent database confirms this compliance figure; of 7407 samples taken over a 50 month period (2011-2016), on an average 89% (6614 samples) were genuine – that is they conform to standards – and about 269 samples (4%) were found to be unsafe. Once again what is termed ‘unsafe’ may not be scientifically communciated e.g sweets containing higher food colours than the prescibed limit; is it unsafe or substandard?
Image via iStock.com
Adulteration is a broad term used to describe any deviation in standards from moisture content or free fatty acid exceeding by a fraction of a percent. Neither of these deviations are related to safety of the product, however the term adulteration – distasteful as it is – conjures a sinister meaning in the mind of the consumer. It is for this reason that Regulators should specifically qualify the term adulteration with the accompanying offence or deviation. For example it should be stated that children fell ill due to consumption of adulterated sweets which was found to contain salmonella or other pathogen as identified. The term adulteration blurs the precision of consumer information; its time to communicate the true risks of failures.
Dr. Joseph Lewis
Very well summarised Sir
Now it’s time to really look into risk based understanding of any Regulatory measure from a regulator’s petspective. Risk communications and awareness on the same line should also be percolated through businesses specially unregulated sectors.