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Food Safety

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Food products are sourced from different parts of
the world, assembled and processed.

Food sales through food service sector, packaged


food, pre cooked food, ready to eat increasing

Reduction of consumer control over food handling


and preparation

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What goes into the making of the food at the
farms, at the factories, during storage etc a
genuine concern

Need for greater assurance about safety and


quality of the food to the consumers

Food safety is not negotiable Unsafe food


cause serious health hazards

Food quality influences a product value, both


positive and negative attributes 4
Food safety is defined as the assurance that
the food will not cause harm to the consumer
when it is prepared and/or eaten according to
its intended use (FAO)

Consumer buying decisionssafety, quality


and shelf life.

No repurchase if it fails in any one of the above

Food safety is reduction of risk or hazard that


occur in the food
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Cost of food poisoning may be very high for a
companyloss of reputation costly to recover

Fall in demand
Product recall costs
Fines
Investigation costs
Clean up costs
Liability suits
Plant downtime

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Major source of hazard in food
Microbiological pathogens, chemical additives
and natural materials

May exist in original plant and animal (toxins)

Added during production (pesticide, chemical


additives, heat process),

Zinc, copper and other materials from the


equipment, nuts, bolts, grease, wire etc
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Develop during storage of the product
Fungal growth, microbiological
pathogens

In short Hazards can occur anywhere in


the supply chain

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Food safety left to the market?

Markets often fail to provide for adequate


safety.
Safety is not apparent to the consumer

He may not be willing to pay for it

Firm may not be interested in investing in


safety measures if it is not able to recover
the cost
A bad firm may drive out a good firm
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Classification of Food Products

Perfect Information Imperfect Information

Search Goods Experience Goods Credence Goods

Repeat Purchase One-time Purchase Imperfect Imperfect


Information Information
to Buyers to Buyers
Sellers have
Information Imperfect
Hide Side- Information
Reputation Reputation Not Effects and/or to Sellers
Established Established Adulterate

Quality Information Based Classification of Food Products 14


Search goods
Sensory attributes such as colour, aroma and
texture can be searched before consumption-
Market mechanisms can take care of these
attributes.
(feel, smell and physically verify to buy a
product)

Experienced Goods
Taste, flavour, are sensory attributes which
can be experienced only on consumption of
food
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Credence Foods
Consumer information is imperfect both before
and after the purchase

Consumer cannot establish the cause and effect


relationship between contamination and ill health

e.g adulteration and low level exposure to toxins


which has long term effects

Both the producer and consumers have imperfect


information about the product before as well after
the use
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So, the necessity for public intervention

Scientific approach to food safety --- in a


framework of risk analysis, a structured approach
whereby risks to human health are assessed and
the best means for their control identified.

Policy is the outcome of the complex trade


off among different groups

Consumers, food manufacturers, retailers,


farmers 17
Public regulations can be ex ante and ex post

Ex ante
Specification of Standardsto both the
produce and the process (pesticide residues,
heating process, packaging material etc)

Through inspection and product testing ensure


compliance penalize companies that are not
meeting the standards

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Ex post
Performance Standards
Certain levels of safety to be achieved when
the product is supplied leave suppliers free to
choose the mechanism through which to meet the
conditions

Product liabilities that is punish companies that


produce below quality products.

Do not specify standards but impose criminal


liability for harmful consequences 19
Private System
Self regulation
Certification

Self regulation includes internal control


system that assure product quality

Certification involves setting product quality


standards and the monitoring and certification
by third party that is outside the firm
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Private regulation due to requirement by
those with whom the firm does business

Strategic tool to increase market share or


protect the current market share

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Many of the microbiological hazards may occur
anywhere in the supply chain,

The cost of monitoring and testing the sample is


very high

Therefore increased focus on Hazard Analysis


of Critical Control Point (HACCP) as a system
for increasing food safety

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HACCP -- recognized as an effective approach
for establishing good production, sanitation and
manufacturing practices that produce safe foods.

HACCP establishes process control through


identifying points in the production process that
are most critical to monitor and control.

Can be applied to control any stage in the food


system and is designed to provide enough
feedback for corrective activities.

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HACCP TERMINOLOGY

Critical Control Point


CCP is an operation (practice, process,
procedure or location) at which a preventive or
control measure can be exercised that will
prevent or minimize a hazard or several
hazards.

Critical Limit
The value of a monitored action which
separates the acceptable from unacceptable.
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Corrective Action
It is a specified prompt action to be taken when
the criteria are not met or when the results of
monitoring the CCP indicates a trend towards
loss of control.

Verification
Review of monitoring records to determine
whether the HACCP system is in place and
functioning as planned and to ensure that
monitoring is carried out effectively and
efficiently.
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Seven Principles of HACCP
1. Conduct hazard analysis and identify preventive
measures

2. Identify critical control points (CCPs) in the process

3. Establish critical limits

4. Monitor each CCP

5. Establish corrective actions

6. Establish verification procedures

7. Establish record-keeping and documentation


procedures

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The Indian Food regulations various
laws- under different ministries.

Enacted at different points of time

Eight ministries dealt with food- many


bodies with different standards

e.g Bureau of Indian Standards, Central


Committee for Food Standards, Weights
and measures etc,.
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Independent of each otherlittle
coordinationlax enforcement

Inconsistent and overlapping

Laws not responsive towards evolving


new food products

Over regulated under administered

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The integrated food law should ensure
safe and wholesome food to the
consumers.

It should be able to create an enabling


environment for value addition to
primary agricultural produce,

to foster innovation and creativity, and


rapid development of food processing
industries in an integrated manner.

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It should also specify quality norms for
meeting globally recognised standards.

This law should be able to cover all articles


of food or drink for human consumption
kept for sale.

Single reference point

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The Food Safety and Standards Act 2006

Passed on 27th August 2006.


An integrated food law and the related
regulations to consolidate the laws relating to
food and to establish the Food Safety and
Standards Authority of India for laying down
science based standards for articles of food and
to regulate their manufacture, storage,
distribution, sale and import to ensure
availability of safe and wholesome food for
human consumption and for matters connected
therewith or incidental thereto.
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The act consists of 12 chapters viz
Preliminary
Food safety and Standards Authority of India,
General Principles of Food Safety
General Provisions as to Articles of Food
Provisions relating to imports
Special responsibility as to food safety
Enforcement of the Act
Analysis of Food
Offences and Penalties
Adjudication and Food safety appellate tribunal, Finance
Accounts, audit and reports and Miscellaneous.
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Food means any substance, whether processed,
partially processed or unprocessed which is intended for
human consumption and includes primary food,
genetically modified or engineered food or food containing
such ingredients, infant food, packaged drinking water,
alcoholic drinks, chewing gum and any substance
including water used into the food during its manufacture,
preparation or treatment but does not include any animal
feed, live animals unless they are prepared or processed
for placing on the market for human consumption, plants
prior to harvesting, drugs and medicinal products,
cosmetics, narcotic or psychotropic substances.
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Main features

Food Safety and Standards Authority to be


established

22 member body drawn from

Ministries of agriculture, commerce, food


processing, consumer affairs, health, legislative
affairs, small scale industries,

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Representatives from food industry, consumer
organizations, eminent scientist, farmers
organizations.

Duty to regulate and monitor the manufacture,


processing, distribution, sale and import so as to
ensure safe and wholesome food.

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Specifythe standards and guidelines in
relation to articles of food and an appropriate
system for enforcing various standards

Set the limits for the use of food additives, crop


contaminants, pesticide residues, residues of
veterinary drugs, heavy metals, processing
aids, myco toxins, antibiotics and
pharmacological active substances and
irradiation of food.
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The mechanism and guidelines for accreditation
of certification bodies engaged in certification of
food safety

The procedure and the enforcement of quality


control in relation to any article of food imported
into India

Method of sampling, analysis and exchange of


information among enforcement authorities

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Also provide

Scientific advice and technical support to the


central government and the state in matters of
framing the policy and rules in areas which have
a direct or indirect bearing on food safety and
nutrition.

The food authority can constitute a central


advisory committee consisting of various
stakeholders such as industry, agriculture,
consumers, research organizations, food
laboratories and representatives from various
ministries. 39
The committee would advice the Food
Authority on

The performance of its duties

Identify potential risks

Pooling knowledge

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The food authority shall also establish
scientific panels to advise on

--The food additives, flavours


--Pesticide and anti bodies residues
--GM foods
--Biological hazards

-- Contaminants in the food chain

-- Labeling etc, Sampling and analysis


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Packaged food should be labeled according to
specifications

Labeling and presentation of food including


appearance, packaging, arrangement should
not mislead the consumers

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No misleading advertisement which is against
the provisions of the act should be made

Food should not make false claims about


quality, grade etc.

Selling unsafe misbranded food is prohibited

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Food which is prohibited in the interest of
the public health should not be sold.

Special license is required in certain types


of food such as therapeutic value

The standards for import of food would be


laid down by the Food Authority

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The State Government shall appoint
commissioner of food safety for the state

The Food Authority and the State Food Authority


are responsible for the implementation of the act

The Food Commissioner in the state and the


Food Safety Officer responsible for his area of
jurisdiction

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Food Safety Officer can take sample of any
food or any substance which appears unsafe

Seize any article of food which appears in


contravention of the Act

The Food Authority notify food laboratories


and research institutions accredited by National
Accreditation Board for testing the samples

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Adjudicating officer not below the rank of the
additional district magistrate to look into the
violation

Appellate tribunal for appeal

Penalties

Person who sells any food not in compliance of


the Act liable to a fine of Rs 2 lakhs

For manufacturing, selling or storing of


substandard food Rs 5 lakhs
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Selling misbranded food Rs 3 lakhs

Misleading by false claim Rs 10 lakhs

Containing extraneous matter Rs one lakh

Manufacturing, storing and selling food under


unhygienic conditions Rs one lakh

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Adulterated food but non injurious two lakhs
Injurious 10 lakhs

For manufacturing, selling unsafe food

Not resulting in injuries -- Imprisonment six


months and Rs one lakh fine

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Non grievous injuries one year and Rs 3 lakhs
fine

Grievous injury six year Rs 5 lakh fine

Causing Death seven years and Rs 10 lakh fine

Damages or compensation to the victims/kin


upto Rs 5 lakhs

Due diligence
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Stella Liebeck vs McDonalds

The jury awarded Liebeck $200,000 in


compensatory damages. This amount was
reduced to $160,000 because the jury found
Liebeck 20 percent at fault in the spill. The jury
also awarded Liebeck $2.7 million in punitive
damages, which equals about two days of
McDonalds' coffee sales.

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Criticism

Act does not say that food is unsafe if it does


not meet the stipulated standards unlike
Prevention of Food Adulteration Act

Penalties relatively stronger for small producers

No grades penalties as per the size of business

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FSSA was formed after two years of
passing the act i.e. 2008

Became operational from 5th Aug 2011

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Monginis

Reputed trusted brand for 25 years

Plans to diversify into catering, fast foods


and chocolates

A strong control system for safe production


for its plants to grow rapidly and maintain
the higher quality standards

Cakes highly perishable


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The shelf life of the cakes is 48 ours

200 varieties of cake are made to order


every day

They differ in design, shape, flavour and


weight

Mostly done through manual labour


coming from low income families from
slums
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Workshop for 25 top executives from various
departmentsto make them realize the link
between safe production, customer satisfaction
and the companys growth
Look at every nook and corner of the factory

Changes in the layout for worker entry, raw


material receipt, trolley movement and wastage
disposal
Sensitive area separated to have positive
airflows
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Maintenance of the compound wall, floor
tiling
Proper house keeping and pest control
Workers were taught personal hygiene
Machinery parts touching food made from
stainless steel
Supplier training and certification
upgrading vendors facilities by adopting
HACCP principles of cleanliness and
hygiene 60
Better recall method for unsafe food
conducted drills
Management Review meeting was planned
for continuous upgradation of HACCP
system
Elaborate control and monitoring system
which necessitates workers to record critical
activities
Responsibilities assigned to key personnel
with background in audit for verification.
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25 executives were trained training
focus on awareness and importance of
the system and exercises to determine
critical control pointsuccessful
executives were formed into HACCP core
team

Organising factory visit helped in


implementing of proper system Bajaj,
Tata Indica, Crompton ??? May be to
understand inventory management and
vendor development 62
Trained 400 workers helped to co-opt
the workers in the implementation of
HACCPFormation of HACCP workers
committee

In house training programme manual


writing, flow chart preparation formation
of documentation team

Training to cake shop dealers and


suppliers in good manufacturing practices
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What are the differences between ISO 22000 and
HACCP certification?

There are not many differences between HACCP and


ISO22000 certification. HACCP (short for Hazard Analysis
Critical Control Points) is the main platform for international
legislation and good manufacturing practices for all sectors
of the food industry.

HACCP is a risk management tool recognised


internationally for use in the proactive management of food
safety issues.

ISO22000 incorporates the HACCP principles and puts


these in a broader framework which is aligned with
generally recognised principles of Management Systems
that drive continual improvement of performance.
Vitamin pre-mix, tri magnesium citrate, lactobacillus
(probiotic preblends), asparaginase enzyme, beetroot juice
concentrate, butter milk, mango lassi, sweet lassi, oil
medium chain triglycerides, tapioca starch, Maggi spice,
Neslac, a variant of Lactogen, resource dialysis and
resource renal are among the product approval applications
of Nestl India closed by FSSAI.

Other products for which the approval process will not be


carried forward by the regulator till a fresh application is filed
and clarifications given include Tata Starbucks sea salt and
caramel sauce; Kelloggs Hot Chinese Oats;
GlaxoSmithKlines Actigrow and Horlicks Coated Oats;
Piramals Nicoveg; M&Ms compound chocolate; Hersheys
ice breakers breath freshening mints; Heinzs phased
modified oil; and Hindustan Unilevers tomato ketchup with
modified starch.

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