Indian food regulations in the global context

THE DOMESTIC food processing industry has come in for a rude shock after April 1. This sector, which has been reeling under uncertainties, could not attract the desired investment for years and will now face fierce competition from the developed and some of the developing countries. This is against the backdrop of an unequal playing field created over the years in the usage of food additives and consequent technologies.

As per the WTO agreement, the doors of the Indian economy have been opened to the world for trade and investment. The quantitative restrictions on almost all items have been phased out except the most sensitive ones since April 1.

The WTO uses the Codex Alimentarius Commission Regulations (CAC or popularly referred to as Codex) as a reference standard to settle disputes arising out of food trade between nations. Now, the Codex reference standards have become binding on all WTO members. Having signed the WTO agreement, the Indian food laws should have been modified gradually to ultimately harmonise with Codex. This would have prepared the local industry for international competition much ahead of lifting the quantitative restrictions.

In the present global health standards as practised by the rest of the developed world and WTO-Codex agreements, let us understand the prevailing Indian food regulations. In India, the Prevention of Food Adulteration Act (PFA) 1954 was enacted in 1954 to provide for the prevention of adulteration of food and thus aimed at providing food safety to the consumer. The British food laws were taken as the basis while formulating the regulations and thus got the first set of approved additives.

Role of safe additives ignored

This name `PFA' psychologically makes one feel that consumer safety is achieved in India by preventing only adulteration of food and that food adulteration is the major issue. The subsequent legislations, amendments and administration and even the scientific opinions appear to have been biased, as if they are making efforts to prevent adulteration of food. Thus the scientific opinions based on pure science practised in the rest of the world in providing safe additives for the development of the food processing sector were ignored, with a simple statement that `the conditions in India are different'. This gradually built a technology/ additive area gap with major parts of the world.

In India, food additives are treated as extraneous substances to food and have been put to more restrictions instead of being beneficially used. The restrictive policies on additive and other areas restricted the developments in the food processing sector as a whole. However, competition was confined within India and within the means of approved additives, which are common to everyone. In this scenario, there was nothing to complain about except a slow growth.Now, with the opening of markets, the domestic food industry in its `restricted' status is forced to compete with international food products produced with latest technologies and additives. In the developed and some of the developing countries, the food processing sector has emerged as a major industrial segment where 70 to 90 per cent of raw agricultural products are processed with many innovations. These innovations provide a variety of processes and additives to food professionals to make food more attractive, appetising, more convenient, transportation worthy and nutritionally rich along with improvement in shelf-life and thus contributing excellent marketable qualities to food products. The developed world felt that useful additives that are not found in nature must be man- made for proper food processing and handling.

Import surge

The Codex list on food additives adopted by the European countries or the U.S. FDA additives are far more in number and the limits thereof are far higher than what is being enforced in India. Thus, the food products made by these countries are better and have excellent consumer appeal than local items using the limited approved additives.

With the opening of markets, Indian supermarkets and food chains are flooded with imported and processed foods such as fruit juices, beverages, and bakery products including sugar confectionery. With the product advantage, these imported foods may drastically affect the domestic food industry and ultimately the farm economy itself. The imports cannot be stopped. In other words, we cannot stop importing products that conform to Codex standards and not to our present standards. We will not be able to prevent these imports unless we demonstrate that a higher level of health protection is required and it should be justified by pure scientific evidence.

At this stage, it is necessary to understand how the developed and some of the developing countries are viewing the safety of food additives. The world had considered food-borne toxigenic and pathogenic micro-organisms as the greatest hazard associated with food almost 25 years ago. The next in order are malnutrition, environmental contaminants, toxic natural constituents and pesticide residues. And in the last place are the food additives which are considered the least harmful at the levels consumed.

Recognising these real dangers, the world has moved to take care of hazardous issues arising out of food to provide total health to people. The major health problems the world over are due to consumption of foods contaminated with pathogens or microbially spoilt foods and are treated as `biological hazards'. Even untreated drinking water forms a major source of microbial contamination and we consume water 2-3 times as much as food itself. Diarrhea, intestinal infections, hepatitis and a variety of other deadly disorders are due to contaminated water which is taking millions of lives annually. Realising this great hazard, many countries have included drinking water in their food safety systems.

Biological hazards represent 93 per cent of the incidents of food-borne illnesses. In the U.S. alone this is resulting in more than 10,000 deaths each year. Even in India, though no data are available, this is a common and major health hazard taking several lives. As this has been considered a serious health problem, the HACCP (Hazard Analysis Critical Control Points) system has been introduced in the U.S. and other countries to control this.

Pesticide residues are another serious safety problem. The organochloride insecticides, that is, DDT and BHC, are either banned or severely restricted from usage in most countries. These banned pesticides have formed the bulk of pesticides consumed in India for the past five decades. Again, synthetic pyrithroids (which cause cancer in humans) are used extensively only in India. Pesticides are used even just before the harvest. These pesticide residues are found even in mother's milk in India and this explains the dimension of the threat posed by pesticides.

The world over, food additives have been recognised as no more health issues at their present consumption levels. Extensive and repeated toxicological studies were carried for over three decades to establish the safety of present approved food additives. The acceptable daily intake (ADI) limits were recommended by various groups including the Food and Agricultural Organisation / World Health Organisation (FAO/WHO) groups. Great care was taken while establishing the ADI limits. The `no observable dose' levels in animals were reduced by 100 or even 1000 times in some cases of additives and these reduced dose levels have been recommended as ADI levels to create undoubted safety factor. This can well take care of any small variance in the sensitiveness among people. Thus, these ADI levels have become dependable, and international opinion on additives appears to be valid, that is, ``they are safe at the levels consumed".

It is worthwhile to understand how the developed world, particularly the European Union and the U.S., are regulating food additives to achieve health and also deriving maximum advantage out of them. For this, two important additives of food, namely, artificial sweeteners and food colours will be examined in detail.

The European Union allows artificial sweeteners - polyols, acesulfame, aspartame, cyclamate, saccharine, thaumatine and neohesperidine - in good quantities in a variety of processed foods. The quantities permitted are as high as 5500 ppm in the case of aspartame in chewing gums. This could be to meet the technological requirement of sustained release of sweetness while chewing. Also, saccharine is permitted to the extent of 500 ppm in confectionery. That the artificial sweeteners are permitted at these levels in a variety of foods suggests the safety of these additives even at these high permitted levels.

In contrast, in India till recently, only saccharine was allowed in aerated waters to the extent of 100 ppm. Now, aspartame and acesulfame are permitted in small quantities in limited products.

Food colours

On food colours, in the U.S., these are used in food products as per good manufacturing practices (GMP) and the food processing sector can add colour as per the product requirements. Thus, colour can be used as per the product demand and as such there is no maximum limit or quantitative restriction prescribed on their usage.

The FDA makes it perfectly clear that there is no such thing as artificial, natural or even unnatural colours. There are colours that are `certified' and in food industry these colours are referred to as `artificial'. Others, which are exempt from certification, are `natural' colours. Whether a colour additive is certifiable or exempt from certification has no bearing on its overall safety and both have undergone rigorous testing before being permitted. The FDA is very clear that the present approved `colour additives' are safe at the levels they are consumed in the U.S. Even the usage levels suggested in Codex list are far higher and are broad-based. As to the question whether natural additives are safer because they are chemical-free, the FDA answer is `no', with an explanation that all are made up of chemicals whether it is natural or synthetic. Example, Ascorbic Acid.

The processed food consumption is highest in the U.S. and consequently the additive intake including food colours and artificial sweeteners are the highest in the world. Thus, the present approved additives including food colours have undergone 40 to 50 years of human consumption at these high usage/permitted levels in the U.S. without any adverse reports. This prolonged safe usage is in itself practical proof that the food additives are safe even at the U.S. intake levels and the system followed to achieve the health of their people are right.

Contrary to the ongoing trends in the rest of the world, in India, food colours are constantly under the threat of a ban. With such consistent negative information, even enlightened Indian consumers are frightened at the sight of food products made with approved food colours. The usage of synthetic food colours has been further restricted and the maximum limit of colour usage has been reduced to 100 ppm from 200 ppm. No scientific explanations were given for these restrictions and this, in this present international scenario and after 40 to 50 years of experience with these colours at far higher levels!

There is a popular belief that all natural colours are safe. Turmeric powder is used extensively as culinary additive and for colouring foods in sufficiently good quantities in India. The FAO/WHO group after extensive toxicological work recommended 0.1 mg as the acceptable daily intake level for curcumin, that is the active colour pigment present in turmeric. The same FAO/WHO group recommended an ADI level of 7.5 mg for Tartrazine, a synthetic approved food colour. Tartrazine provides similar colour shade to that of curcumin pigment. This suggests that our strong belief that all `naturals are safe' is not correct as the synthetic food colour Tartrazine is 75 times safer than the natural colour curcumin (Turmeric).

The Codex standards are binding on all WTO members. However, ever since the harmonisation process was initiated in India, it has been debated as to which additives are permitted out of the Codex list. Having signed the agreement, at this stage, we cannot be selective in implementing the Codex product standards as this will be challenged by any other WTO member to gain entry for their foods manufactured using the rest of Codex additives. This selective implementation also harms the domestic food industry. It is therefore time we accept the Codex additives and implement their usage levels, as these are the additives under usage in other parts of the world without any health problem for years. In the case of any serious objection / doubt on safety / toxicity of any particular additive, we can take this up with the Codex committee. This will also help the international community for an overall improvement of health systems.

In order to harmonise our systems, the following steps need to be considered:

(1) Adopting Codex product safety parameters by normal system may take over two yeas. As time is already running out, it is wise to implement all Codex additives/ product safety parameters by an `ordinance'. This will instantaneously align Indian manufacturers with the international community to produce foods and processed foods.

(2) (a) At the same time, we can continue the present Indian food safety (PFA) standards to accommodate our ethnic foods and their specific raw materials as they are not in Codex.

(b) Over a period, we can consolidate the safety specifications for Indian ethnic foods and their specific raw materials and get them included in Codex. This will facilitate exports of Indian ethnic foods.

(3) Health scenarios are uniform for the human race and we can adopt them when they are proved elsewhere. While Codex can be implemented as far as product safety parameters are concerned, for label declaration, the important aspect to be considered is that the terminology used on label should be easily understood by the common Indian. Here there is a strong case to retain major portions from the Indian Food Safety (PFA) Act, unless something more useful is available from Codex. For products meant for export, we can follow the Codex labelling system.

(4) The safety parameters ought to be health related and the major emphasis while laying standards should be health oriented.

Real issues of health

Food additives have to be regulated as is done in the rest of the world. As per the world experience, regulating food additives alone cannot be considered as achieving health. It is important to address the total health imperatives for India as practised in the rest of the world for real and major improvement in health standards.

India achieved number one status in many areas of agricultural production including vegetables and milk. With this agricultural wealth, vast scope awaits for post-harvest technologies to fabricate/process novel foods, competing with world leaders. The present global scenario requires innovative rules and adoption of apt technologies / information to compete in unified markets. Unless India adopts policies which are successful elsewhere, it will not be able to improve the present 2-3 per cent utilisation of agricultural produce for value additions through processing.

The country should be conscious about improving the health of the public. The misconceptions about health hazards should be dispelled through systematic scientific information to the public as being practised in the U.S. India needs to look at initiatives to improve the overall health of the people as practised in the developed world. Now, a majority of the countries has already moved from providing safety to improving the overall health of their people, by regulating microbial standards, toxic materials, pesticide residues and providing clean drinking water and looking at other parameters. This is apart from addressing the real dangers posed by food-borne toxigenic and pathogenic micro- organisms, pesticide residues, and veterinary drug residues in milk and meat, while regulating the food additives in the form described above.

B. Raghuramaiah

Vice-President & Fellow Member, Association of Food Scientists and Technologists (India)

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