Up-gradation of Food Analysis Laboratory - Challenges faced by Food Analysis

Laboratory, Madurai
Discrepancy in test report from laboratory allegations by enforcement personnel
DO/ FSO
FSO will be lifting suspected samples based on the organoleptic qualities of Food like
color, odor and extraneous matter, and label declarations.
Reasons for discrepancy
Color
National Food Authority FSSAI is continuously updating the regulatory standards of
various Foods in order to harmonize with International standards like CODEX. In this
process, FSSAI has allowed certain permitted food colors up to 100ppm in almost all
foods except Tea, Oils and Fat, milk products and bread. For eg; Sunset yellow and
brilliant green in Snacks and savories.
Action plan: Monthly updates of FSSAI on Food Safety and Standards (Food Products
and Food Additives) Regulations, 2011 may be included in the monthly review meeting
of Food Analysts and Designated officers.
Presence of Larvae/ Insects/ Fungi
Due to inadequate technical man power in Food Analysis Laboratories, the received
samples were not opened immediately for analysis. Since there is a long gap between
receipt in laboratory and opening of the sample, naturally there is a chance of
development of the larvae, insect and fungi. Hence, the growth of the above may be
neglected when analyzed.
Action Plan: The Food Analyst, Madurai informed the Designed Officers to make a note
of such complaints on sample request form VI, this will make Analysts alert to prioritize
analyzing such kind of samples. It may be followed by all Designated Officers.
Extraneous matter
We have two kinds of extraneous matter, one is organic, which is allowed up to 2% and
other Inorganic, which is allowed up to 0.5%. Organic extraneous matter includes
straws and other agricultural by product and if present will be below the prescribed 2%.
Only samples with inorganic extraneous matter like stone, sand, metals, etc will fall
short of the requisite standards.
Labelling Defects
Till October 2017, the labels without any one of the following No Batch/Code/Lot
number, with packers address but without manufacturer address, with packers address
but without importers address, Veg or Non Veg declaration, Nutritional Information,
FSSAI Lic No (brought under labelling regulation in 2016-17), etc., were not taken into
account, considering the status of the vendor. Hence, there may be discrepancy
between FSO& DO suspecting and Food Analyst report. Now FSS (Packaging and
Labelling) Regulation, 2011 are strictly followed.

Operation of High-end Instruments Such as Chromatography and Spectrometers

The operation of the above instruments, highly skilled technical expertise is a necessity.
It needs a different setup for handlings the sample and instruments right from sample
preparation to interpretation of data from Instruments. As most of the existing technical
personnel of the laboratory do not have exposure to such kind of microlevel analysis,
with the little knowledge of instrumentation and sample preparation it has become
practically difficult to standardize the instrumentation and methods along with large
influx of samples.
Hence, training may be imparted with application scientist onsite or few people from
laboratory may be trained at FSSAI capacity building training programs.

Building - For Microbiology laboratory and Micro Analysis

The existing buildings of the Food Analysis Laboratories do not have enough space and
are not designed to accommodate the high end instruments and Microbiology
laboratory. Each high end instruments like GCMSMS, LCMSMS, ICPMSMS, etc.,
require physically separated space with temperature controlled dust free environment in
order to avoid cross contamination. Microbiological analysis of food samples for highly
pathogenic organisms like Listeria, Clostridium, Salmonella requires a Biosafety Level II
laboratory with unidirectional workflow design with change rooms and highly ventilated
air conditioning system (HVACs) [positive and negative pressures] to avoid
contamination and to favour biohazard containment.
Since the existing building of Food Analysis Laboratory cannot accommodate
Microbiology laboratory and the micro analysis (heavy metals, pesticide residues,
antibiotic residues and toxins), a new building needs to be constructed, which are
necessary to upgrade the laboratory and to obtain NABL accreditation for complete food
testing.
Others requirements include - provision for uninterrupted portable water supply and
power supply (backup) in order to maintain instruments and reagents.
Sampling for Microbiological Analysis as per Food Safety and Standards
Regulation, 2011
As per sampling guidelines of FSSR, 2011, sampling for Microbiology is quite different
from the rest of the analytical parameters.
There are two types of sampling plan for Microbiology
1. Two class attributes sampling plan (applicable for pathogens)
2. Three class attributes sampling plan (applicable for hygiene indicators)
The above sampling plans requires multiple sample units (minimum of 5 units for
hygiene indicators and large number of units for critical sample like infant formula) for
microbiological analysis, which are not followed while sampling by Food Safety Officers.
(Details annexed)
Sampling of food articles in loose condition for Microbiological analysis require aseptic
sampling procedures and maintenance of cold chain throughout sampling and
transportation, which are also not followed. The samples collected without following the
guidelines received in the laboratory in a state unfit for Microbiological analysis.
Hence, Designated Officers and FSOs may be given instructions to follow the sampling
guidelines, while sampling for Microbiological analysis.
It is also requested that instructions may be given to send food poisoning and other
complaint samples accompanying a letter with complete background of the case.

Necessity of Technical (Analyst) Manpower at the Office of Commissioner of

Food Safety
A senior technical person may be inducted into the office of Commissioner of Food
safety for the ease of communication and guidance to the food analysis laboratories and
related matters. A Senior Technical personnel is necessary to exclusively address and
communicate with laboratories related to FSSAI updates on the regulations of Food
standards and Food additives, introduction of new technical tool like laboratory
networking (infolnet), strengthening programs for laboratories, food safety on wheels
and survey schemes like National Milk survey, noon meal scheme, NGT samples, etc.
The provision of technical manpower at headquarters will also address the difficulties
such uniform reporting system, training programs for laboratory personnel, recognition
and accreditation of laboratories and related matters like competency testing, budget
requirements of laboratories (in terms of infrastructures and chemicals), prohibition of
food articles and related matters, packaging and labelling regulations, analysis fee
enhancements, referral lab reports, updates on appendix A and B.