Wednesday 28 December 2011

Food Recall – Effective tool for ensuring food safety and FSS Act, 2006

December 28, 2011

While Food Recall is a relatively new concept in India, with the FSS Act, 2006, focussing on this vital aspect, awareness is growing and companies are looking at it as a vital link in the supply chain.

Indian companies are slowly realising that at times the product they have released in the market, needs to be recalled. And this can be minimised if the company’s recall system is well planned, implemented and understood by those who are involved in core activities of sourcing, manufacturing and distribution functions.

With the kind of emphasis, which is being given to food safety nowadays, consumers are also very much aware and at the same time concerned about the safety of the product they consume.

Section 28 of Food Safety and Standards Act, 2006, of Government of India emphasises the need for product recall. This states
If a food business operator considers or has reasons to believe that a food which he has processed, manufactured or distributed is not in compliance with this Act, or the rules or regulations, made thereunder, he shall immediately initiate the procedures to withdraw, the food in question from the market and consumers indicating reasons for its withdrawal and inform the competent authorities thereof.
Every food business operator shall follow such conditions and guidelines relating to food recall procedures as the Food Authority may specify by regulations.

In the past, in order to strengthen food safety, the FSSAI had released the draft regulation known as Food Authority’s Food Recall Procedures Regulations, 2009, which shall come into force from date of its notification in the official gazette.

Salient features of yet-to-be adopted regulations:

● To guide food business operators on how to carry out a food recall through an efficient, rapid identification as well as removal of unsafe food and food that violate the Act and Rules & Regulations made thereunder from the distribution chain and informing consumers (where necessary) of the presence of potentially hazardous food in the market and ensure that unsafe food are contained and destroyed or rendered safe;
● To guide food business operators on how to establish a written recall plan for carrying out food recall in case the food does not meet the requirements of the hygiene, safety and quality of food and to protect the health of consumers; and
● To establish a follow-up action / post-recall report in order to ensure the
effectiveness of the recall and prevent a recurrence.

● These regulations apply to the recall of food that presents a threat to the public      health or whose quality does not conform to the Act and Rules & Regulations made thereunder.
● All food businesses engaged in the wholesale supply, manufacture or importation of food regulated by Food Authority must have an up-to-date recall plan except food retailers, unless they are also engaged in the wholesale supply, manufacture or importation of food.
● Food businesses within the food service sector such as restaurants, caterers and takeaways are exempted to have recall plan unless they are running multi-outlet food business chains having integrated manufacturing and distribution network.
● The food retailers and businesses within the food service sector which do not need a recall plan, shall remove recalled stock from shelves and return it to the manufacturer, importer or wholesaler and must ensure that food that is subject to a recall is separated and identified from other food until it is disposed of in accordance with the instructions provided as part of the recall plan.
● A recall plan must be available in written form and shall be made available to the state food authority / food authority on request.
● The food business operator is required to comply with the plan it has developed when it recalls food.
● In the case of alcoholic beverages the mandatory mentioning of warning “consumption of alcohol is injurious to health” may not be treated as unsafe unless the beverage is otherwise not containing any harmful and dangerous substance that may cause serious health problems or is unsafe to the consumer.
Recall Classification 

FSSA Guidelines: Steps in Developing Recall Procedures

A Typical Composition of Recall Team
(Example from other established systems adopted internationally)

(Ensure that all functions are covered if various departments do not exist in your organisation)

Contents of food recall notifications 
● Name of the food business operator recalling the food.
● Name of the food, brand name, pack size, batch & code number, date of manufacture, used by date or best before date.
● The contamination / violation in the food / reason for recall.
● The “do not consume message if the food is unsafe.”
● Health warning and action.
● The places / outlets where the food is found.
● The action to be taken by the consumer.
● A contact number for queries.

The recalling food business operator shall respond to each query from the state food authority / food authority within 24 hours of the receipt of the query.

Contents of recall status report 
● Number of downstream food business operators or individuals notified, and date and method of notification;
● Number of food business operator responding to the notification and quantity of the particular food in their possession;
● Number of food business operator or individuals not responding to the notification and quantity of food dispatched to them. (if needed, the identity of non-responding food business operator may be requested by the state food authority / food authority);
● Quantity of recalled food and result of investigation;
● Proposed method of disposal or otherwise of recalled stock with records of destruction;
● Anticipated time limit for completion of the recall.

Dealing with the recovered food  
● The recalling food business operator shall store the recovered food in an area which is separated from any other food and is identified by a label plate with prominently written Recalled Product.
● The recalling food business operator shall maintain accurate records of the recovered food and their lot no. / batch code, pack size, brand name, date of manufacture, best before date etc. Proper recording system shall be available to ensure that all the foods are retrieved and their details recorded.
● The recalling food business operator may correct or reprocess the recovered food if appropriate in consultation with state food authority and ensure that it is fit and safe for human consumption before release to the market.
● In all other cases, the recalling food business operator will ensure appropriate destruction of such food in consultation with / presence of the state food authority representative.
● A complete record of the disposal of such product shall be maintained.

Post-recall report  
● The recalling food business operator shall submit post-recall report after the completion of the recall to assess the effectiveness of the recall.
● The effectiveness of a recall shall be assessed on the basis of the quantity / amount of food returned as a proportion of the quantity / amount of food that left the recalling food business operator while taking into account the retail turnover of the food.
● In addition to assessing the effectiveness of a recall, it is necessary to follow up by investigating the reason for the recall and taking action to prevent a recurrence of the problem.

Termination of a recall 
● The recalling food business operator may request termination of its recall by submitting a written request to the state food authority / food authority along with latest recall status report / post-recall report stating that the recall was effective.
● A recall may be terminated when the state food authority / food authority determines that all reasonable efforts have been made and it is reasonable to assume that the food subject to the recall has been removed and proper disposition or correction has been made.
● Written notification to the effect that a recall is terminated will be issued by the state food authority / food authority to the recalling food business operator within two weeks of the request submitted by the recalling food business operator.
● In case of unsatisfactory reports, the state food authority / food authority may consider further action like stepped-up inspection, seizure or any other legal action, against the recalling food business operator.
(The writer is food safety and system expert and consultant: 

Nutrition Information and Labelling

December 28, 2011

Several empirical studies indicate that the label is an instrument that reduces the asymmetric information problem between producers and consumers, as well as reduces the search costs for consumers to meet their desired choices.

Food labelling is a tool to promote and protect public health by providing accurate nutritional information so that consumers can make informed dietary choices, while others consider it as an instrument of marketing and product promotion.

The recently-published WHO-FAO (World Health Organisation-Food & Agriculture Organisation) report on diet, nutrition and the prevention of chronic diseases suggested that nutrition labels are an important means of facilitating choice of and access to nutrient-dense foods. The WHO global strategy on diet, physical activity and health endorsed in May 2004 by the World Health Assembly, states that providing accurate, standardised and comprehensible information on the content of food items is conducive to consumers making healthy choices.

According to 2005 Online Consumer Opinion Survey by A C Nielsen, most Indians (41 per cent) check nutritional labels when purchasing a product for the first time. Interestingly, however, consumers are most concerned with the nutritional information on food labels when buying food products for their children (Murali, 2006; Baisya, 2007).

The disclosure of information on food labels in India is primarily governed by the Prevention of Food Adulteration Act, 1954, which has primarily focussed on the basic information of the product on the food labels and put less emphasis on health and nutritional information to be given on the food labels. However, recent amendments on packaging and labelling of food under part VII of the Prevention of Food Adulteration Rules, 1955, has mandated to disclose the health and nutritional claims on the food labels along with basic information. The new integrated Food Safety and Standards Act (FSSA), 2006, also aims at establishing a single reference point for all matters relating to food safety and standards across the country, by moving from multi-level, multi-departmental control to a single line of command. Chapter IV, paragraph 23 of the FSSA clearly states that no person shall manufacture, distribute, sell or expose for sale, or dispatch or deliver to any agent or broker for the purpose of sale any packaged food product which is not marked and labelled in the manner as may be specified by regulation. The Food Safety and Standards Authority of India has already been established to speed up the implementation of various rules and regulations in the Act. A study was conducted to determine and analyse the nutritional information on the packaging of major packaged food products of leading Indian & multinational brands being marketed in India. (Kumar et al, 2011) The analysis clearly indicated that the food processors disclose nutritional information on their food labels to facilitate the consumers in making informed choices as per their corporate strategy.

Labels and consumers
Because almost all food products have embedded credence attributes, it is difficult for consumers to evaluate the quality of food products themselves by looking at the food labels. In general, consumers do not understand the complex and technical information regarding health and nutrition that is given on such labels. However, this information definitely increases consumer confidence about food quality and safety.

Standardisation and uniformity of information on food labels might help consumers understand the information. But it will not be possible for consumers to assess quality and safety if a food product has been wrongly labelled. Because claims on food labels create expectations among consumers regarding the healthfulness of products, these claims need to be scientifically confirmed and enforced through proper regulatory mechanisms.

Nutritional labelling
The way nutrition labels are formatted influences how effectively they can be used, interpreted and compared by consumers. Regulations are important because they dictate which nutrients are listed and the way that they are expressed quantitatively, along with other aspects of label design. The Codex has encouraged consistency between trading partners, but different countries have developed a diverse array of approaches to these requirements.

Current Codex guidelines recommend energy, fat, protein and carbohydrate be listed on nutrition labels. Dietary fibre should be added where a claim for dietary fibre is made, and sugars where a claim is made for carbohydrates. The guidelines allow, however, for national adaptation, stating, “Any other nutrient deemed by national legislation to be relevant for maintaining good nutritional status may be listed.” (Figure 1)

Regulatory environment
Overall, countries and areas can be characterised as having one of four types of regulatory environment:
● Category 1: Mandatory nutrition labelling on all prepackaged food products (to date, seven in the study, 10 as of 2006, and proposals for one further area as of 2010);
● Category 2: Voluntary nutrition labelling, which becomes mandatory on foods where a nutrition claim is made (most countries also mandate labelling on foods with special dietary uses) (27 in the study);
● Category 3: Voluntary nutrition labelling, which becomes mandatory on foods with special dietary uses (18 in the study);
● Category 4: No regulations on nutrition labelling (19 in the study).
Countries that require nutrition labelling only where a claim is made, or on foods with special dietary uses, may also require mandatory labels on specific foods. India falls under Category 3.

Thus nutrition labelling is effective in providing:
● The consumer with information about a food so that a wise choice of food can be made;
● A means for conveying information of the nutritional content of a food on the label;
● The use of sound nutrition principles in the formulation of foods which would benefit public health;
● The opportunity to include supplementary nutrition information on the label.

No misleading info
Nutrition labelling does not describe a product or present information about it which is in anyway false, misleading, deceptive or insignificant in any manner.

With regard to nutrition labelling, there appears to be a trend embracing the concept of, and need for, the declaration of nutritional information. It is widely believed that labelling can assist consumers in making food choices and that regulations are needed to ensure standardisation between labels.

In conclusion, nutrition labelling can be an effective means of helping consumers to make healthful food choices, although existing evidence concerning the effect of health claims on diet and public health is insufficient. Regulations can play a crucial role in enhancing the potential for nutrition labelling and health claims to promote health. The effectiveness of nutrition labelling and health claims in improving national dietary patterns relies largely on a motivated and educated public to make healthful choices. This approach has limitations. If there is to be significant change, action on nutrition labels and health claims need to be part of an integrated approach that tackles the increasing rates of diet-related non-communicable diseases at a population level, as well as targeting individuals.

1. Diet, nutrition and the prevention of chronic diseases. Report of a Joint WHO/FAO Expert Consultation. Geneva, World Health Organisation, 2003 (WHO Technical Report Series, No. 916) (, accessed 5 January 2004).
2. Integrated prevention of non-communicable diseases. Draft global strategy on diet, physical activity and health. Geneva, World Health Organisation, 2003 (; accessed 12 January 2004)
3. Codex Guidelines on Nutrition Labelling (CAC/GL 2_1985) (Rev.1_1993). Rome, Food and Agriculture Organisation of the United Nations / World Health Organisation, 1993.
(The author is senior manager, nutrition science, Enhance Proteins Limited) 

Monday 19 December 2011

All India Food Safety Summit focusses on new licensing procedures under FSSA

Highlighting the achievements and hurdles in the functioning of the food processing industry in India, the All India Food Processors’ Association (AIFPA) organised the ‘All India Food Safety Summit — 2011,’ at Hotel Le Meridien, on Friday.

The Summit had sessions covering the issues and challenges relating to licensing, registration and enforcement. Various aspects about the smooth transition of the industry from the earlier Act/Rules/Orders to the new norms were discussed. Uniformity in implementation of the Rules and Regulations in various states was deliberated upon.

An important part of the Summit was the session on the standards for food additives, packaging and labelling. The Summit highlighted the strategies to make the Regulations more effective by harmonising the essential elements of earlier Food Acts, certain provision of Legal Metrology and some standards of the BIS (Bureau of Indian Standards).

The CEO of the Food Safety and Standards Authority of India, V N Gaur, delivered the key note address. Also, Dr V Prakash, distinguished scientist of CSIR (Council for Scientific and Industrial Research) and president, Nutrition Society of India, delivered a special address.

Piruz Khambatta, president, AIFPA and chairman, Rasna, said, “After serving the cause of the industry for more than 60 years, the AIFPA has been taking fresh initiatives to accelerate the industry’s growth.”

Khambatta further said, “Development of food processing industry is of prime importance for food security, controlling food inflation, and for prosperity in rural areas.”

He stressed that the central and the state government agencies should work closely with the industry to ensure this development as food processing could do for rural India what IT has done for urban India.

Khambatta also emphasised that India could rightly become the food factory of the world. What the sector needs is accelerated reforms.

The Summit was followed by an award function, where awards and scholarships were bestowed upon food processors, entrepreneurs and others for their contribution to the development of the food processing industry.

Saturday 10 December 2011

FIR lodged in ghee adulteration case

VADODARA: The city seems to be emerging as a hotbed of adulterated ghee supply.
Wadi police have registered an FIR against a man who prepared such ghee and supplied it in the market. On the other hand, the Anand police are also looking for an accused from the city involved in a similar racket from the city.

A huge stock of adulterated ghee branded as 'Amul' or 'Sagar' was seized from the city on October 18, but no offence was registered regarding the seizure as the police claimed that they were waiting for reports of the analysis of the samples of the seized material from Vadodara Municipal Corporation (VMC) that had received the tip-off and conducted the raid along with the Wadi police. It had come to light that one Piyush Patni was behind the racket.

In all, 1,018 kg of ghee was seized from Baranpura area of the city. Labels and material to pack the ghee was also recovered from a godown during the raid.
In the meantime, Anand police seized 15 tins of similar ghee branded as 'Amul' from a shop in Anand earlier this week.

The Anand police registered an offence regarding the incident and it came to light that the stock as supplied by one Pravin Patni from the city. They had conducted raids in the city to nab Pravin, but could not locate him.

The action by Anand police led to the Wadi police here drawing flak. Wadi police had not registered an offence regarding the incident till Friday night.

An offence was registered only on Friday night and attempts are being made to locate Piyush.
Wadi police inspector R G Bhavsar said the FIR was delayed as VMC had not submitted its test report. "We registered the offence because we got it only on Friday," he said. VMC food safety officer Jitendra Gohil filed an offence regarding the seizure.

Bhavsar said both Pravin and Piyush had not been nabbed yet. He added that they were distant relatives, but it was still not clear if they operated the racket together.

Source: The Times of India

Tuesday 6 December 2011

Food safety workshop for canteens focusses on hygiene, self-regulation

December 06, 2011

A food safety workshop for corporate canteens was organised by Equinox Laboratories at Hotel Renaissance, Mumbai, on Friday.

The dominant topics at the event were hygiene – both at the personal level and at the workspace – and self-regulation.

What prompted a panel discussion on these key issues was the recent spate of food poisoning cases that was witnessed at a premier educational institution in the city, which was the subject of considerable media attention.

In his welcome address, Debjeet Banerjee, branch manager, Equinox Laboratories, touched upon how India was perceived by foreigners, highlighting both sides of the coin instead of speaking only on the positive aspects.

The inaugural speech was supposed to be delivered by Mahesh Zagade, commissioner, Food and Drug Administration for the state of Maharashtra, but he could not make it to the event.

Dr V G Chapke, the seniormost speaker and a key member of Team Equinox, spoke about the Food Safety & Standards Act, which came into being on August 5, 2011, and reminded those who were in the food business that they would have to complete their licensing or registration by the same date the next year.

His session, which was beginning to turn into an interactive session because of the legal nature of the content, basically focussed on four sub-topics – enforcement, penalties, licensing and registration and corporate responsibility in relation to food safety.

The post-tea session saw the hotelier take the dais. Vineet Manocha, a known name in planning menus and other aspects of the actual process of food production in the hospitality industry, was the speaker.

Manocha spoke at length on a topic that everyone was aware of but few actually follow –basic kitchen hygiene. An interesting point he kept raising, “The kitchen should not be visually appealing but also clean from the point of view of sanitation.”

Ashwin Bhadri, director, Equinox Labs, whose age belies his professional title, was the next speaker. Like Banerjee, he also conducted two sessions.

His first session revolved around the food safety management system (FSMS), hygiene management for corporate canteens (which was quite an eye-opener) and basic cost-effective steps in hygiene, which are mandatory for food-handlers to adhere to.

His second session focussed on the training of facility managers for ensuring food safety. This involved the selection of the right vendor, ensuring good hygiene practices at the vendor’s kitchen and ensuring good hygiene practices at corporate hygiene, which, as he pointed out, was pretty tough.

Banerjee spoke on either side of the lunch break. The highlights of his pre-lunch session were the challenges faced by all those who were trying to ensure food safety. The award presented to those who comply with every food safety norm is called the Hygiene Shield.

Post-lunch, he touched upon the best global practices to ensure food safety in corporate canteens before proceeding to present several case studies to highlight the points he was making.

After a short break for tea, the floor was thrown open to those who wished to ask the industry professionals questions on the topics covered. This round-table interactive session revolved around ensuring hygiene and food safety.

To sum it up, whether a food vendor provides a dustbin outside his joint or avoids using a sheet of newspaper to wrap his food, there is just one universal truth in the business of food: hygiene is the new buzzword.

Source: FnB News

Thursday 1 December 2011

Feature: All good things come in great packaging

December 01, 2011

Today products that have attractive labelling and packaging tend to lure their target customers more than the contents inside.

No wonder print packaging technology is at an all-time high. The market is led by who's serving its target customers the best product deal; with paramount ingredients and superlative look and feel.

Packaging not only protects the food from oxidation, but also promises its quality, authenticity, safety and trust. Furthermore, traceability of the product's origin is now possible with the print packaging technology in the market.

The packaging industry claims to comprise three types of packaging: Self-adhesive labels which mark the origin and mention relative information about the product on it; Flexible or variable packaging for the wrappers of chocolates and chips, shrink wraps etc.; and, lastly, the big Carton packaging.

● Secured packaging: Product imitations and duplicates are an inescapable part of the consumer industry today. Drug anti-counterfeit programmes are being run to protect the drugs in pharmacy business. A traceable barcode is printed on the medicine, which helps in tracing the originality of the pill. Customers can scan from their smartphones or simply SMS the 10 digit barcode number to the pharmaceutical company from anywhere and verify the legitimacy of the tablet. The HP Smart Labels and Secured Packaging solution helps pharmaceutical companies adhere to guidelines and pedigree mandates from government and state regulators, ensuring that the drug supply is safe and secure. These solutions are designed to help stem the potentially steep revenue losses that can result from counterfeiting and product diversion, while improving profitability and reducing cost.

Four years back one of the leading wine-makers in France - Ch√Ęteau Carignan, wanted to have a secured packaging for the reason of avoiding risk of getting a premium wine morphed by fake marketers. The one-point solution was the Digital Print Packaging Technology offered by HP Indigo presses, which provided the initially packaged label a printed mark of originality, stating a logistic ID for each bottle, the micro-text and a CRM code with an invisible ink. This could be seen not through the naked eyes but under the infrared light. This marked the beginning of the era of secured packaging and customer being able to connect directly with the brand, helped in building up the brownie points on customer relationship.

●Digital packaging: Embraces the job of making your chips packet most tempting and make you grab one and munch. Later you consider it to be or not to be included in your kitty of choicest flavours. The alluring chocolate wrappers add to your pleasure of the bites melting in your mouth. HP Indigo's exclusive printing technology grants you the boon of customisation of the packaged prints as per the brand requirements.

Meanwhile, frozen foods are becoming a rage in the consumer market these days and to ensure their quality is utmost priority. A lot of brands are offering products at competitive prices, here comes into play the exclusive printing and packaging technology which distinguishes your product with the other. The best packaging wins the customer attention and content being the same, grasps the space in the buyer's shopping bag. The Digital packaging by HP allows the test-marketing a well-timed and economical affair. The brands get an opportunity to create and test versions of the products in the market which build up brand awareness and let one know the preferences of the target customers.

●Flexible packaging: The limited editions' wrappers of the promotional offers allow the brands to reach out the target market in a cost-effective way, as HP digital presses allow them to play with the designing options and get limited quantities printed as required and desired. Taking a step back in the past reminds me of the pan-Israel "Design your Own Sprite" contest, resulting in the printing of 6 winning entries on the Sprite cans for 6 months. This gave the world of food & beverage a caption of customisation and personalisation.

HP today allows you to test market, customise, personalise, reduce your time-to-market and safety packaging in the product building process, ensuring the use of inks approved under the "Food Grade Certification." The four major areas where HP provides the brands a profitable printing and packaging deal are Shorter quantities required to be printed in an experimental state of affairs; Lesser turnaround time in printing; Cost- effective promotional packaging for the soft launch of the upcoming products in the market; and Security packaging.

HP Indigo WS4500 Digital Press and HP Indigo WS6000 Digital Press are the one-point solution machines that accomplish the task of Secured packaging, Variable packaging and Digital printing in an exceptional fashion, creating a prototype for the branding process in the market. Keeping a watch over the current market scenario we can say that this sanctifies the labelling and packaging industry and makes it far more accessible to print different labels, in different ways through different colours, and market them through different marketplaces. This provides the arena of test market a new paradigm, which allows the brands to experiment with the product's adaptability and likeability among the target customers.

(The author is country manager, Indigo & Inkjet Press Solutions, GSB, HP-IPG India)