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  • Food Safety & Standards Act,

    Food Safety & Standards Act, 2006
    It is comprised of two components i.e. (a) Safety and (b) Standards

    (a) Safety:
    Safety parameters prescribed under FSS Act, 2006 are as under:
    (i) Microbial contamination (Prescribed in appendix B)
    (ii) Pesticide residues ( Prescribed under Chapter 2.3)
    (iii) Veterinary Drugs ( Prescribed under Chapter 2.3.2)
    (iv) Metal Contaminations ( Prescribed under Chapter 2.2)
    (v) Aflatoxin M1( Prescribed under Chapter 2.2.1)
    (vi) Melamine in Milk (Due to adulteration Melamine in milk & Milk products, the import of these products is banned from China. No efforts was made to find out whether Indian Industries are using melamine to increase the nitrogen content in Milk & Milk products)
    In the survey, above parameters related to Safety have not been examined at all, which are essential Safety parameters to declare the Milk Safe

    (b) Standards

    (1) Milk samples had been analyzed by the FSSAI / State Govt. Laboratories, which has not obtained NABL accreditation in the area of Milk analysis till date as mentioned in Section 43 of the FSS Act 2006.
    (2) MOHFW rejected the Centre for Science & Environment report (published in 2006) on Pesticide residue analysis in Soft drinks (carbonated beverages manufactured by Pepsi & Coca-Cola) because CSE Laboratory was not accredited from NABL to conduct such tests.

    (3) JPC ( Joint Parliament Committee) recommended in its report (to avoid panic reactions to revelations) submitted in year 2004 in Para 4.78(4 ) which reads as under reads as under:
    ÔÇ£There must be code of conduct for disseminating the results of an investigation either from a NGO organized or from a
    Laboratory or anyone else. Today for example if a survey is done or a study conducted, or an analysis with respect to spurious food item is suddenly taken up, there is no code of conduct for reporting it in an orderly fashion. In order to avoid such a situation, the committee recommends that results must be validated so as to ensure transparencyÔÇØ
    Till date no code of conduct is formed by the MOHFW though for this meeting was called in 2007. Without proper code of conduct, any survey conducted by the FSSAI has no relevance but just to
    create the unnecessary panic in the country.

    4 Various types of detergents are available in the market. Each group has specific method of analysis. From the survey report, it is not clear which method has been adopted for analysis of detergent.
    (Copy of Wikipedia is enclosed for ready reference). Hence the report of the presence or absence of detergent cannot be relied upon. Copy enclosed and marked as Annexure-IV.
    5. Further survey report cannot be relied upon as the methodologies to be adopted for quantitative determination of urea, test for various
    detergents, neutralizers etc. were not circulated before carrying out the survey on milk and even competency of each laboratory was not examined after conducting Inter Laboratory Analytical Quality
    Assurance Programme, which is one of the pre-requisite for such type of National survey work to find out adulteration in the country.
    Even the method of sampling was not circulated before conducting all India based huge survey.

    6. The quality of water added in the milk will not be potable water. Further, addition of water itself makes the Milk unsafe food because balance of vitamins and minerals present naturally is disturbed. So as per definition given under Section 3 (ZZ) No.(IV) and (v) of FSS Act, it will be treated as unsafe food, which reads as under:
    (iv) By the substitution of any inferior or cheaper substances whether wholly or in part or
    (v) By the addition of any substance directly or as an ingredient which is not permitted.

    7. It is observed that Vision of the Authority to prescribe Science based regulations/ standards in the FSS Act. On perusal, it is observed the regulations/ Standards are just copied from PFA and re-arranged as Regulations.

    8. On Page 3 of the report published by USDA Foreign Agricultural ervice (GAIN Report No.: IN1104) observed regarding FSS Act are as under:
    ÔÇ£------- However these documents are essentially a retitled version of the Prevention of Food Adulteration Rules 1954 and its amendments, without any changes.ÔÇØ

    9 Further, it is evident from the fact that Act was implemented from 5th August 2011. It took 3 years to prescribe the so called Science based Standards. After expiry of 6 months advertisement has came in the Newspaper that comments are invited for the revision of the FSS Act, which had been prepared after three years long deliberation
    Hence it is proposed that FSSAI may be allowed to conduct any survey in larger Public interest till guidelines for code of conduct for National Survey is finalized as recommended by the JPC (Joint Parliamentary Committee) in the year 2004.

    Posted by: Anonymous | 7 years ago | Reply
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