Among the definitions in Food Safety and Standards Act, 2006, the word “claim” has a link with quality of food article.
In Chapter 1 Preliminary Section 3(d) of the Act, “claim” is defined as any representation which states, suggests or implies that a food has particular qualities relating to its origin, nutritional properties, nature, processing, composition or otherwise. That means, question of quality of food article arises when a claim, health or nutrition, is made by FBO. In Section 3(q) the word “food safety” has a link with intended use. It is defined as assurance that food is acceptable for human consumption according to its intended use. Question arises whether FBOs are fully authorised to decide intended use of their products, particularly proprietary, when decades long span of people’s faith regarding the product does exist. If yes, the question intensifies how the quality of food may be assured to people, particularly when intended use of food article is so twisted by FBO that it is contradictory to people’s faith or consumer perception.
Baked food and fried food, for example, are perceived by people as beneficial and injurious respectively for health. The bakery products, particularly bread and biscuits, are suggested by physicians to patients.
Namkeen
Meanwhile, fried foods – namkeen, bhujia, samosa, kachori etc. – are medically prohibited. People believe that intended use of the former is quite different than that of the latter. Health- conscious people prefer baked foods while fried foods are purchased for tongue–taste only. But as per definition of food safety in the Act, both the baked and fried products irrespective of consumer perception are equally acceptable for human consumption according to intended use. A fried food manufacturer can make a nutrition claim; for example, with added vitamins “fortified namkeen” might be claimed. Obviously such a claim will mislead a consumer, because in want of vitamins he or she may consume high amount of salt and fat via consumption of “fortified namkeen.” Such a claim does not represent a statement or suggestion or meaning that the food has particular qualities relating to its origin, nutritional properties, nature, processing and composition or otherwise. It is a true statement that “fortified namkeen” contains added vitamins. But originally namkeen is a high salt, high fat food article by composition. It is a fried product by processing which may be injurious to health. Therefore addition of vitamins to namkeen cannot transform it from non-nutritive to nutritive product category.
Exemption
Despite non-nutritive nature of high fat, high salt, high sugar processed food articles like namkeen, bhujia, sweets etc. those are not exempted from printing nutritional information on label. Only two such processed food articles viz. pickles and papad are exempted from printing nutritional information vide FSSR 2011 : 2.2.2. labelling of pre-packaged foods(3) nutritional information(v) (i). Nutritional data like fat, sugar and salt contents are misleading, if printed on labels of food products having imbalanced diet leading nature. A finger rule can be made for evaluating the imbalanced diet nature of a food product. A food product, 100 gm of which provide more than 20 gm of fats or 3 gm of common salt or 18 gm of sugar, meets out more than 50 per cent of Daily Values of these ingredients in 2000 Kcal diet. While making this finger rule, the Daily Value for fat is taken as 18 per cent of total calorie intake, since World Health Organisation (WHO) intake guidelines of dietary constituents for prevention of chronic diseases in adults suggests fat intake limit to be 15 to 30 per cent and lower side of this limit is safer for sedant work. In context of quality assurance to consumer, a food product which crosses the fat, salt and sugar limits does not deserve for printing nutritional information. It really deserves for statutory warning or any risk representative mark. In other words, any kind of nutrition or health claim including nutritional information on label of a non-nutritive product like namkeen, bhujia, sweets etc. is contrary to principle of quality assurance.
QA principle
Similarly quality assurance principle is also violated when nutritive products of wide public faith like bread, biscuit, and rusk are legally allowed to use harmful additives for functional improvement in colour, texture etc. For example, FSSR 2011 : 2.4.5. specific labelling requirements(16) allows sale of maida treated with improver or bleaching agents (including the oxidant benzoyl peroxide) if its bag carries the declaration – Wheat flour treated with improver/bleaching agents, to be used by bakeries only.
A consumer considers bread and biscuit quite safe and physicians also suggest these food articles to patients. Therefore the law should allow harmful additives in bakery products like bread and biscuits for any kind of functionalism with mention of statutory warning or risk representative mark only. The breads and biscuits are preferred by health-conscious people on the basis of processing i.e. baking which is considered to be quite safer as compared to frying process. If bakery industries are allowed to use harmful additives without mention of statutory warning or risk representative mark, consumers are betrayed and quality assurance principle is violated.
Risk analysis
“Risk” in relation to food article is defined in the Act (Chapter 1, 3(1) zm) as probability of an adverse effect on the health of consumers and the severity of that effect consequential to a food hazard. As per 1, 3(1) zn, “risk analysis” is made by assessing, communicating and managing it. There is made provision of issuing prohibition orders under section 33 of Act, if the health risk exists (1, 3(1) zl), which empowers the court to issue prohibition orders in cases where the food business operator is convicted of an offence under the Act. Under Section 35 of the Act the Food Authority is required to notify registered medical practitioners carrying on their profession in any local area specified in the notification, to report all occurrences of food poisoning coming to their notice to such officer as may be specified. In fact microbial food hazard results in a fast food poisoning for which physicians are expected to be well aware. But pesticides-insecticides, artificial colours & flavours, functional additives, antioxidants and preservatives, even used in prescribed limits in the food articles, might give rise to slow poisoning resulting into serious diseases in due course of time. Therefore the Food Authority is also required to evaluate the packaged food-borne diseases or slow poisoning symptoms in populace. The clinical trials on people’s proneness to food-borne diseases can basically provide rationale to estimation of how fast non-organic intensive farming practices, deforestation and artificial additives-based food processing be ceased in the country.
Imbalance
Unfortunately Indian people have been suffering from micro-nutrient mineral imbalance caused diseases due to deforestation, soil erosion and intensive non-organic farming, what Itspossible Nutraceuticals perhaps truly states in the publicity literature of its dietary mineral supplement CMD (Concentrated Mineral Drops) which is a packaged concentrated Utah Lake (an American lake containing full spectrum of minerals due to good soil conservation as a result of dense forestation) water.
To define “intended use” in terms of both FBO’s outlook and people’s faith, to exempt from printing of nutritional information on the labels of non-nutritive food articles, to make provisions of statutory warning or risk representative mark on labels of non-nutritive and harmful additives containing food articles and to evaluate the packaged food-borne diseases and slow poisoning symptoms in populace might be a few amendments in FSS Act which can strengthen quality assurance system. Nowadays quality control activities are not limited to laboratory work only. Its field is widened to extreme boundaries of all management disciplines including ecology of country. After a few surveys on food-borne diseases, FSSAI soon can accurately argue on why to go ahead for land reform, dense forestation and organic farming practices. Quality is not just matching the product characteristics with standard specifications. In fact, quality is delivered value to consumer.
In Chapter 1 Preliminary Section 3(d) of the Act, “claim” is defined as any representation which states, suggests or implies that a food has particular qualities relating to its origin, nutritional properties, nature, processing, composition or otherwise. That means, question of quality of food article arises when a claim, health or nutrition, is made by FBO. In Section 3(q) the word “food safety” has a link with intended use. It is defined as assurance that food is acceptable for human consumption according to its intended use. Question arises whether FBOs are fully authorised to decide intended use of their products, particularly proprietary, when decades long span of people’s faith regarding the product does exist. If yes, the question intensifies how the quality of food may be assured to people, particularly when intended use of food article is so twisted by FBO that it is contradictory to people’s faith or consumer perception.
Baked food and fried food, for example, are perceived by people as beneficial and injurious respectively for health. The bakery products, particularly bread and biscuits, are suggested by physicians to patients.
Namkeen
Meanwhile, fried foods – namkeen, bhujia, samosa, kachori etc. – are medically prohibited. People believe that intended use of the former is quite different than that of the latter. Health- conscious people prefer baked foods while fried foods are purchased for tongue–taste only. But as per definition of food safety in the Act, both the baked and fried products irrespective of consumer perception are equally acceptable for human consumption according to intended use. A fried food manufacturer can make a nutrition claim; for example, with added vitamins “fortified namkeen” might be claimed. Obviously such a claim will mislead a consumer, because in want of vitamins he or she may consume high amount of salt and fat via consumption of “fortified namkeen.” Such a claim does not represent a statement or suggestion or meaning that the food has particular qualities relating to its origin, nutritional properties, nature, processing and composition or otherwise. It is a true statement that “fortified namkeen” contains added vitamins. But originally namkeen is a high salt, high fat food article by composition. It is a fried product by processing which may be injurious to health. Therefore addition of vitamins to namkeen cannot transform it from non-nutritive to nutritive product category.
Exemption
Despite non-nutritive nature of high fat, high salt, high sugar processed food articles like namkeen, bhujia, sweets etc. those are not exempted from printing nutritional information on label. Only two such processed food articles viz. pickles and papad are exempted from printing nutritional information vide FSSR 2011 : 2.2.2. labelling of pre-packaged foods(3) nutritional information(v) (i). Nutritional data like fat, sugar and salt contents are misleading, if printed on labels of food products having imbalanced diet leading nature. A finger rule can be made for evaluating the imbalanced diet nature of a food product. A food product, 100 gm of which provide more than 20 gm of fats or 3 gm of common salt or 18 gm of sugar, meets out more than 50 per cent of Daily Values of these ingredients in 2000 Kcal diet. While making this finger rule, the Daily Value for fat is taken as 18 per cent of total calorie intake, since World Health Organisation (WHO) intake guidelines of dietary constituents for prevention of chronic diseases in adults suggests fat intake limit to be 15 to 30 per cent and lower side of this limit is safer for sedant work. In context of quality assurance to consumer, a food product which crosses the fat, salt and sugar limits does not deserve for printing nutritional information. It really deserves for statutory warning or any risk representative mark. In other words, any kind of nutrition or health claim including nutritional information on label of a non-nutritive product like namkeen, bhujia, sweets etc. is contrary to principle of quality assurance.
QA principle
Similarly quality assurance principle is also violated when nutritive products of wide public faith like bread, biscuit, and rusk are legally allowed to use harmful additives for functional improvement in colour, texture etc. For example, FSSR 2011 : 2.4.5. specific labelling requirements(16) allows sale of maida treated with improver or bleaching agents (including the oxidant benzoyl peroxide) if its bag carries the declaration – Wheat flour treated with improver/bleaching agents, to be used by bakeries only.
A consumer considers bread and biscuit quite safe and physicians also suggest these food articles to patients. Therefore the law should allow harmful additives in bakery products like bread and biscuits for any kind of functionalism with mention of statutory warning or risk representative mark only. The breads and biscuits are preferred by health-conscious people on the basis of processing i.e. baking which is considered to be quite safer as compared to frying process. If bakery industries are allowed to use harmful additives without mention of statutory warning or risk representative mark, consumers are betrayed and quality assurance principle is violated.
Risk analysis
“Risk” in relation to food article is defined in the Act (Chapter 1, 3(1) zm) as probability of an adverse effect on the health of consumers and the severity of that effect consequential to a food hazard. As per 1, 3(1) zn, “risk analysis” is made by assessing, communicating and managing it. There is made provision of issuing prohibition orders under section 33 of Act, if the health risk exists (1, 3(1) zl), which empowers the court to issue prohibition orders in cases where the food business operator is convicted of an offence under the Act. Under Section 35 of the Act the Food Authority is required to notify registered medical practitioners carrying on their profession in any local area specified in the notification, to report all occurrences of food poisoning coming to their notice to such officer as may be specified. In fact microbial food hazard results in a fast food poisoning for which physicians are expected to be well aware. But pesticides-insecticides, artificial colours & flavours, functional additives, antioxidants and preservatives, even used in prescribed limits in the food articles, might give rise to slow poisoning resulting into serious diseases in due course of time. Therefore the Food Authority is also required to evaluate the packaged food-borne diseases or slow poisoning symptoms in populace. The clinical trials on people’s proneness to food-borne diseases can basically provide rationale to estimation of how fast non-organic intensive farming practices, deforestation and artificial additives-based food processing be ceased in the country.
Imbalance
Unfortunately Indian people have been suffering from micro-nutrient mineral imbalance caused diseases due to deforestation, soil erosion and intensive non-organic farming, what Itspossible Nutraceuticals perhaps truly states in the publicity literature of its dietary mineral supplement CMD (Concentrated Mineral Drops) which is a packaged concentrated Utah Lake (an American lake containing full spectrum of minerals due to good soil conservation as a result of dense forestation) water.
To define “intended use” in terms of both FBO’s outlook and people’s faith, to exempt from printing of nutritional information on the labels of non-nutritive food articles, to make provisions of statutory warning or risk representative mark on labels of non-nutritive and harmful additives containing food articles and to evaluate the packaged food-borne diseases and slow poisoning symptoms in populace might be a few amendments in FSS Act which can strengthen quality assurance system. Nowadays quality control activities are not limited to laboratory work only. Its field is widened to extreme boundaries of all management disciplines including ecology of country. After a few surveys on food-borne diseases, FSSAI soon can accurately argue on why to go ahead for land reform, dense forestation and organic farming practices. Quality is not just matching the product characteristics with standard specifications. In fact, quality is delivered value to consumer.
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