The Codex Alimentarius Commission (“CAC”), established by the Food and Agriculture Organization of the United Nations and the World Health Organization in 1963, lays down the international standards and model codes about food, food production, and food safety for countries to incorporate in their national legislations. The Codex food safety standards has also been recognised by the World Trade Organization (“WTO”) after the WTO Agreement on the Application of Sanitary and Phytosanitary Measures (“SPS agreement”). Developed in response to the increasing movement of food across international borders and concerns about the absence of standards in some countries where food products had originated, most of these standards relate to the food manufacturing and processing industry.
In India, food safety regimes have, to check compliance with regulatory standards, traditionally relied on inspection of products or the premises of production, after production has been completed. With the new Food Safety and Standards Act, 2006 (“the Act”), there has been a partial shift towards a methodology where the focus is on prevention. With such a methodology, there will be schemes that rely on quality of the product and standards are tailormade for each organisation based on their operations. This is the foundation of the Hazard Analysis and Critical Control Points (“HACCP”) methodology under which all potential hazards in the production process are outlined and an action plan is developed to counter all of those hazards. This involves a deeper understanding of the raw materials used and the various processes for creating the final product. The Food Safety and Standards (Licensing and Registration of Food Business) Regulations, 2011 provides guidance on good manufacturing practices such as those for design of premises, quality of materials used for production, and sanitary and personal hygiene norms for employees.
The success of a HACCP-based approach needs firstly, the hiring and training of skilled manpower to document and monitor every aspect of the production process; secondly, investment in systems which ensure the consistent application of standards to avoid the hazards identified beforehand; and thirdly, a firm commitment from the management to adhere to the standards at any cost along with a multi-department effort within the organisation to report any malfunctioning element in the process.
For example, Metro Cash and Carry, which operates numerous wholesale cash-and-carry stores in the country, follows a HACCP approach for their food products. They have a quality department at each store and quality personnel consistently seek reports from every department in the store handling food to analyse their performance and keep a tab on the application of the prescribed standards.
The biggest challenge for small and medium-sized enterprises is to come up with the HACCP plan in the first place. Since these plans require specialised scientific knowledge of food products, most companies rely on external consultants for help in developing them. The World Health Organization (“WHO”) has therefore suggested that the food safety authorities provide food vendors with a basic HACCP plan containing applicable information such as the basic principles of food microbiology, sources of contamination, and transfer of food borne diseases.
There are other novel initiatives that have helped promote food safety and the economic interests of street food vendors. Thailand launched the Clean Food Good Taste Project (“CFGT”) to promote food safety amongst the street food vendors in the country. A CGFT logo marking the CGFT certification on an establishment indicates that the vendor meets the requisite standards for food safety. This system is unique as it uses a multi-agency approach in formulating and implementing the food safety regime with respect to small or street food vendors. Vendors and consumers are able to participate in setting standards and inspections and they are encouraged to set up vendor and consumer associations to disseminate information.
The inclusiveness of this project ensures that vendors have adequate information to implement the conditions and consumers, aware of the standards required for a CFGT certified establishment, can even report violations to the authorities. A vendor-training mechanism on good sanitary practices, which equips vendors to incorporate their practices, helps make the project sustainable. A vendor has to opt for a CFGT certification and this helps bring serious individuals and organisations into the process.
The success of the project is rooted in an economic approach, as propagated by the HACCP methodologists, that investments made to adhere to these certifications result in better quality. Product consistency will result in additional gains and will offset the initial investment made to achieve the standards. The Thailand experiment has good potential of being replicated in India. A public-private partnership model to reduce bureaucratic red-tape will help boost consumer confidence and hopefully elevate food safety standards in India.
(Aruj is the Chief Bhukkad at Bhukkad, a natural fast food brand. Bhukkad’s second outlet is opening soon at 80 Feet Road in Koramangala, Bangalore. The previous two posts in this series are here and here.)