Dr Satya Prakash, former director, Central Food Laboratory, Kolkata talks to Environment Health Bulletin on the status of labs in India.
Food Safety and Standards Authority of India (FSSAI) had notified Rules on 5th August 2011 under FSSA Act 2006 to give guidelines to food industry for hygiene and regulations/ standards for safe and wholesome food for human consumption.
A nationwide project, Food and Drug Capacity Building Project was designed to improve the quality and safety of food and drugs by strengthening the regulatory framework and incorporating components of consumer education with the assistance of World Bank. The project remained in operation from 2003 to 2008 to improve the capacity of laboratories at central and state levels along with other regulatory programme. For this purpose the government of India took nearly Rs.320 crore soft loans from World Bank.
Due to WTO agreement, it was mandatory to have laboratories accredited from an authority meant for this purposes for obtaining reliable and reproducible results. It is just like an audit of working of laboratories by an outside agency i.e. third party assurance. In India, NABL (National Accreditation Board for Testing & Calibration Laboratories) is the agency approved by the international agencies like APLAC and ILAC. It is similar to NABH for Hospitals. It was included under World Bank Capacity Building Project that government Food and Drugs Laboratories (Centre and States) are to be accredited from NABL.
Each laboratory in the country that required assistance was identified and provided in terms of equipment, infrastructure and manpower (up to 5 years only). In the absence of manpower and infrastructure, the equipment supplied under Capacity Building Project could not be utilized or opened at all. Although it was one of the conditions of the World Bank, that equipmentshould be purchased only when the manpower and infrastructure was available. The equipment, which was opened, is not functional due to various difficulties faced by the food analyst in their states. Thus, entire purpose of upgrading laboratories under Capacity Building Project remained as it is.
Though FSSAI had laid down a mandate to perform various functions but FSS Act comprised of two components namely i.e. (a) Safety and (b) Standards Safety parameters includes microbial contamination, pesticide residues, veterinary drugs, metal contaminations, Aflatoxin B1, B2, M1 and M2, naturally occurring toxic substances (agaric acid, hydrocyanic acid, hypericine and saffrole), melamine in milk and milk powder, packaging materials used in packaging food shall be of food grade, utensils and crockery used for cooking and serving conforming to BIS specifications, dioxins, chemicals used as food additives, hormones, presence of genetically food, Nutraceuticals, dietary supplements, organic food etc.
The above mentioned safety parameters are not being examined at all because most of the Authority and State Food Laboratories do not have infrastructure and manpower to analyze them.
Science based standards/ regulations are to be laid down to ensure safe, hygienic, pure and wholesome food to its citizen in the global scenario as per vision of Authority. On perusal, it is observed that regulations/ standards are just copied from PFA Act and re-arranged as Regulations. This fact is mentioned on Page 3 of the report published by USDA Foreign Agricultural Service (GAIN Report No.: IN1104) observed regarding FSS Act are as under:
“-- However these documents are essentially a retitled version of the Prevention of Food Adulteration Rules 1954 and its amendments, without any changes.”
On February 13, 2012, the jurisdiction of the referral Laboratories was changed without following any procedure to benefit specific laboratory by an executive order. In the past, the matter was discussed and approved by the CCFS and notified in the Gazette after approval of Law Ministry.
The Food Laboratories are backbone of the Food Safety & Standards Programme to be implemented in the country. The working conditions and quality of analysis of laboratories under FSSAI are required to be strengthened/ managed properly so that Authority has a proper check on the food articles supplied in the market for consumption to the common man as per various provisions of FSS Act 2006 and Rules 2011. At present the working conditions of the labs are anything but functional. (See Box: Working Conditions of the Lab)
Working Conditions of the Lab
Central Food Laboratory, Kolkata: There has been no officer to analyze the samples for chemical analysis since 2010 because all 7 sanctioned posts are lying vacant. Recently in July 2012, a Chief Technical Officer was appointed. The other two other officers available for analysis are Microbiologist and Jr. Microbiologist.
Food Research & Standardization Laboratory, Ghaziabad/ Central Food Laboratory, Ghaziabad: The senior posts of the laboratory viz. Director, Microbiologist, Chief Technical Officer, Senior Analyst and two posts of Junior Analysts are lying vacant for a long time, which are essential requisite for proper functioning of an appellate/ referral laboratory. Further, Director, Central Indian Pharmacopeia Laboratory, Ghaziabad (Drugs) was continued as notified Alternate Director of Central Food Laboratory, Ghaziabad despite Central Indian Pharmacopeia Laboratory was abolished in the year 2008. The laboratory is not accredited from NABL till date, though the process of accreditation was started in 2003 as per direction of DGHS. In the Laboratory, the lower posts are also not being filled up but staff was recruited on contract basis. Most of sophisticated equipment of the Laboratory are not in working condition in the absence of AMC and electricity.
Central Food Laboratory, Mumbai: The posts, infrastructure and equipment were procured/ created in the year 2008 at a cost of Rs. 17 crore approximately. The Mumbai laboratory is not functional till date. The life span of electronic equipment is generally 5 to 7 years afterwards their spares are not available and will no longer be under warranty.
Central Food Laboratory, Kolkata Extension Centre at Raxaul: The analysis of imported food articles in extension centre, Raxaul (of CFL, Kolkata) is being looked after by the staff of Laboratory Assistant level since April 2009. Laboratory assistants are not authorized/ competent to analyze the samples independently. As per rules, their duty is to assist the analyst/ chemist in analysis. The analysis done by the laboratory assistants is being faxed to Kolkata laboratory and junior microbiologist signed them in sitting in Kolkata itself for issuing the reports. The samples of imported samples of Milk and Milk products coming from Nepal were released without conducting test for melamine content. Further no safety parameters can be analyzed in that extension centre including microbiological parameters.
Central Food Laboratory, Ghaziabad Extension Centre at Sonouli: Similar are the conditions at Sonouli situated at Indo-Nepal Border established since June 2008. The staff appointed for Sonouli Laboratory is posted in FSSAI. Time to time, staff is posted from Ghaziabad to run the laboratory on ad hoc basis though regular posts were created in the year 2008, but not filled so far. Thus, Govt. money is wasted on TA/DA without any useful purpose.
In Raxaul and Sonouli, no chemical or glass dealers are available. All the supplies are to be procured from outside to run the laboratory. In small towns of UP and Bihar, most of the time, there is no electricity for hours continuously. If electricity is available, the voltage is too low to run costly sophisticated equipment. Same is the situation in Raxaul and Sonouli. These laboratories were brought under the control of food authority but neither do they have a no-objection certificate from the fire department nor any regular AMC of equipment are being done.
The working conditions of the state food laboratories are not better than the authority laboratories. In Delhi itself, where I had worked as Public Analyst from 1996 to 1999, the post of microbiologist along with other sanctioned posts for the laboratory have not been filled till date. Recently, food laboratory, Delhi was accredited by the NABL in chemical parameters.
In a few places—Bihar, Chhattisgarh, Jharkhand, Uttar Pradesh (Gorakhpur and Varanasi), most of North Eastern states—the posts of public analyst/ food analyst are lying vacant due to non–availability of suitable persons as their pay scales are low. Thus, these laboratories are not functional at all. The financial positions of the state laboratories are in poor condition in comparison to the authority laboratories. The statutory work of checking of imported food articles has been assigned to private laboratories, Export Inspection Agencyand Kolkata University. The authority has no control on their staff.
Public knew the hazards of pesticides only when CSE published its first report regarding pesticides in carbonated beverages in 2003. Government formed the Joint Parliamentary Committee (JPC). JPC gave its recommendations in 2004, but none of these recommendations were implemented by the Ministry of Health and Family Welfare (MoHFW) in its true sense. The present condition of the five central and 68 state food laboratories working under control of Food Authority regarding Pesticide residue analysis is dismal. (See Box: The Central and State Labs)
The Central and State Labs
None of the laboratories of FSSAI are competent to analyze the 149 pesticides residues prescribed under FSS Act, 2006.
Central Food Laboratory, Kolkata can analyze few pesticide residues, while state food laboratories are not in a position to analyze/ monitor pesticide residues in food products at ppm level.
None of the laboratories are analyzing/ monitoring pesticide residues in fruits and vegetables by the validated method prescribed by the MOHFW including Central Food Laboratory, Kolkata.
Practically, no sample is lifted by the food inspector/ food safety officer for the problem of maintaining fruits and vegetables in cold storages.
None of the Food Laboratories (5 Central & 68 states) are NABL accredited for analyzing/ monitoring pesticide residues in fruits and vegetables products as required under Section 43 of the FSS Act, 2006.
No samples of carbonated beverages (Pepsi and Coca Cola) are being analyzed/ monitored by the FSSAI laboratories (Central & State) since 2008, because none of laboratories have imported sophisticated instruments as required, as per AOAC method. The validated AOAC method for analyzing carbonated beverages was prescribed by the MOHFW in the year 2008 on the demand of international giants like Pepsi and Coca Cola at 1 ppb level. The method recommended required approximately Rs 5 crore for procurement and running of imported costly and sophisticated equipment. For no other processed food products such exercise was conducted.
Similarly for taking one sample of mineral water/ packaged drinking water 16 bottles of 1 litre of same batch is required for drawing four samples as per FSS Act. None of the business operator will keep 16 bottles of the same batch for sale at a time. Thus, Food Safety Officer will not be able to draw sample or have no money to pay to the business operator. Hence, practically no samples are being lifted for quality check of mineral water/ packaged drinking water. The analysis is to be carried out by GC-MS/ LC-MS to carry out analysis at 0.1 ppb level, which most of the laboratories do not have. If having, not in working condition due to various reasons with some exception.
Recently under RTI, when information was asked from FSSAI regarding samples analyzed along with methodology adopted for Pesticide Residue Analysis for various food articles. FSSAI replied that information is not available with them.
Most of the state laboratories do not have pesticide standards for analysis, which cost nearly Rs 3000-4000/ per pesticide having expiry period of one year or so.
Pure gases required for pesticide residues analysis are not available even in Kolkata; it can be procured from Mumbai only. Thus, any one can imagine the condition of state Laboratories situated in small cities/towns.
In the recent survey of milk conducted by FSSAI none of the milk samples were analyzed for safety parameters like pesticide residues, heavy metals, microbial contamination, Mycotoxins, veterinary drugs and melamine. The method adopted for examination of detergents was not proper as there are various types of detergents are available in the market. The service centers of suppliers of foreign sophisticated equipment are situated in metro cities only. Hence for smooth running of equipment, services of Instrument Engineer are required from time to time. Practically, these are difficult to get in 640 districts of the country.
Immediately, all present food laboratories are to be accredited from NABL for obtaining reliable & reproducible data as per requirement of Section 43 of FSS Act 2006. The Gap analysis was conducted thrice by the MOHFW after spending huge public money without any corrective measures. In view of the facts stated above, first the existing food laboratories have to be strengthened in terms of manpower, infrastructure and equipment on priority basis before proceeding for opening of new 125 food laboratories as proposed by the FSSAI.