While
the news of Food Safety and Standards Authority of India (FSSAI)
postponing the deadline yet again for conversion, renewal of existing
registrations for FBO’s under the Food Safety and Standards (Licensing
and Registration of Food Businesses) Regulations 2011 has been welcomed
by the hospitality industry in one voice; it doesn’t give a permanent
consolation to the industry. Of course, the fourth extension held on
February 4, 2014 might be a shrewd move by political masters for another
six months, for whom this is the time to appease the vote banks. But
the one thing that’s sure is the new regulations that are framed after
prolonged consultations are here to stay and cannot be buckled for long.
The hotel and restaurant industry is by and large in favour of
the regulation, except for few flaws in the “technical and regulatory”
aspects of it. They wanted “calibrated” and “consultative” approach
before it being enforced upon the industry. Yes, of course, in a country
where major chunk, almost 70 per cent, of food service business is in
the unorganised sector, any talk of food safety and hygiene standards
would be an impractical proposition without addressing the ground
realities. However, the marathon consultations and workshops organised
over the last two years both by the authority as well as the industry
bodies across the country have created certain level of awareness about
the impending regulatory framework in the market.
The
FSSA lays down stringent procedures starting from designing the
commercial kitchens, layout, usage of equipments, procurements of
ingredients, handling and storage, hygiene of both the facility as well
as handlers, preparation, display to others. The FBOs have to keep
records of everything at every level of procurement till usage. The
units also have to keep the licencing authority updated on any change in
the lay out, expansion, change in product category for which licence
has been obtained.
The high level of safety and hygiene outlined
in the FSSA would necessitate very high levels of professionalism while
delivering food service. The professional consultants, hotel and
restaurant designers, facility planners, equipment manufacturers and
suppliers, food importers, vendors all have to re-adjust their role in
the industry so that their clients and customers are not inconvenienced
unnecessarily by the regulators.
Sense of caution
Professional
consultants find the new regulatory regime as an opportunity to improve
the food service delivery system in the country. The standards
although difficult to implement in the Indian context due to various
bottlenecks related to infrastructure, the general feeling is that it is
time we improved our food safety and hygiene standards to the
international standards. The hospitality consultants feel that hotel
and restaurant owners need to focus on safety aspects from the concept
stage of their units to create a safe and hygienic environment.
“Precautions
that need to be taken to ensure conformity with food safety norms have
to be taken from the conceptual stage itself. The concept includes
identification of the type of cuisine to be served; creation of a menu
listing the number of items to be prepared; and categorisation of the
equipment required to prepare the type of cuisine identified,” informs
Anil Bhandari, Chairman, abSmart Concepts. A time-and-motion study is
necessary before considering the design of the kitchen and secondary
spaces as it will help in making decisions related to the site plan,
floor plan, equipment layout, plumbing, ventilation, lighting and
materials to be used. In accordance with the Hazard analysis and
critical control points (HACCP) guidelines, importance is being given to
ergonomically-designed installations such as plumbing, drainage,
lighting, air-conditioning, exhaust, fire safety and accident-proof
systems, suggests Bhandari.
According
to M Ramvittal Rao, Director, Vittal Concept Design, any food and
beverage production space must primarily meet three kinds of safety
aspects - food safety, employee safety and fire safety. “The equipment
selected must be provided with certifications which have an
international stamp such as NSF, CE, UL, TUV, EnergyStar and others.
These certifications provide for all requirements for a safe working
kitchen environment. Additionally, wall surfaces need to receive matt
finish vitrified tiles with minimal joints or synthetic hard plastic
wall panels, floors should be laid with ten millimeter thick vitrified
composite tiles and still better resin bonded quartz sheets which will
last 15 years plus. The false ceilings in all kitchen areas should be
stainless steel,” he informs.
Highlights of the general Sanitary and hygienic requirements applicable for FBOs are as under
Layout And Design Of Food Establishment Premises
- As
far as possible, the layout of the food establishment shall be such
that food preparation / manufacturing processes are not amenable to
cross-contamination from other pre and post manufacturing operations
like goods receiving, pre-processing (viz. packaging, washing /
portioning of ready-to-eat food, etc).
- Floors, ceilings and
walls must be maintained in a sound condition to minimize the
accumulation of dirt, condensation and growth of undesirable moulds.
They should be made of impervious material and should be smooth and easy
to clean with no flaking paint or plaster.
- The floor of food
processing / food service area shall have adequate and proper drainage
and shall be easy to clean and where necessary, disinfect. Floors shall
be sloped appropriately to facilitate drainage and the drainage shall
flow in a direction opposite to the direction of food preparation /
manufacturing process flow.
- Adequate control measures should be in place to prevent insects and rodents from entering the processing area from drains.
- No
person shall manufacture, store or expose for sale or permit the sale
of any article of food in any premises not effectively separated to the
satisfaction of the licensing authority from any privy, urinal, sullage,
drain or place of storage of foul and waste matter.
Equipment & Containers
- Equipment
and containers that come in contact with food and used for food
handling, storage, preparation, processing, packaging and serving shall
be made of corrosion free materials which do not impart any toxicity to
the food material and should be easy to clean and /or disinfect (other
than disposable single use types).
- Equipment shall be so
located, designed and fabricated that it permits necessary maintenance
and cleaning functions as per its intended use and facilitates good
hygiene practices inside the premise including monitoring and audit.
- Appropriate
facilities for the cleaning and disinfecting of equipments and
instruments and wherever possible cleaning in place (CIP) system shall
be adopted.
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Strong
compliance to food safety and hygiene standards would become a unique
selling proposition for hotels and restaurants going forward and would
enable them to derive higher return on investments, feels Pankaj Giroti,
Chief Advisory Mentor, TallOak Hospitality. “We strongly recommend to
the hospitality entrepreneurs to create right facilities. The idea is to
create hygienic facilities, ease of working and comforting atmosphere,
in addition to something that pleases one and all. Moreover, the aim is
always to reduce the cost of operation and increase efficiency
manifolds. As the old saying goes Back of the house supplements the
Front of the House,” he states. Complying with the HACCP and Food
Safety regulations, one needs to conduct a hazard analysis , identify
critical control points, establish critical limits, establish critical
control monitoring requirements, establish corrective actions, establish
record keeping systems and establish verification procedures.
Kitchen
designers strictly follow HACCP principals and now FSSAI, informs Neel
Kamal Chauhan of HPG Consulting. Explaining the various priorities when
comes to designing a kitchen, Neel said, “Avoiding cross flows,
adequate refrigeration, process monitoring, personal hygiene of the
staff, cross contamination, kitchen waste management are of vital
importance in a kitchen design. “Refrigeration is an integral part of
any kitchen design and is designed keeping in mind the incoming and
outgoing flow of perishables. Integration of refrigeration with BMS
(building management system) has become vital element in designs. Staff
accesses through hygiene control systems , air purification,
sterilization of processing equipment are also integral part of any
kitchen design,” Neel added.
Enumerating
the design priorities, Pradeep Mathur, Managing Director, Mathur
Hospitality said that any kitchen design should take into consideration
safety in relation to property, manpower, and equipment.
Easing the burden
While
new guidelines on food safety and security are a little stringent and
difficult to implement, there is technology available to assist those
who have genuine will and the wherewithal. Modern technological
gadgets and equipments have really changed the way commercial kitchens
are designed and operated in recent times. Whether it is flooring and
ceiling, storage and preservation equipment, modular kitchens and
ovens, chafing dishes, the modern commercial kitchens are a visual
delight. “Trend is to have an international standard kitchen, which is
efficient & easy to maintain. Earlier we used to maintain a line for
the equipment, but now we have to see that a kitchen looks nice in all
aspects while functioning. With new technologies and imported equipment
we are able to save space. Also, quite a few have dual or multi- usage/
purpose attachments, which allow a consultant to minimise internal
kitchen space and give space to front of house facilities. Technology is
also available to prepare & store International cuisines like
Continental, Italian, American and others, but Indian food is something
which requires last minute preparations and finishes. Probably
technology still has to meet the Indian cuisine preparation standards,”
says Mathur of Mathur Hospitality.
The Imperial New Delhi sets up food safety department
With
a vision to establish a structured, stringent and analytical hygiene
program across all levels of operations, The Imperial has launched a
‘Food safety and hygiene standards department’. This program aims to
provide training and direction in food safety and hygiene standards
maintenance at the hotel in compliance with FSSAI standards. The
department has been designed to implement many thought-provoking
strategies for a 360 degree food safety analysis program starting from
supplies to the services offered to the guest or to the hotel associate.
Commenting
on this initiative Vijay Wanchoo, Senior Executive Vice President &
General Manager, The Imperial New Delhi elaborated, “The launch of FSHS
department is a phenomenal step towards creating new benchmarks at The
Imperial. The department has a full fledged micro biological laboratory -
The Imperial Lab, equipped with the state-of-the-art technology to
maintain food hygiene standards and conduct analysis under a focused
approach.”
He added, “We plan to implement a ‘structured hygiene
program’ for material procurement, kitchen, food production, spa areas,
guest vehicles in the hotel premises as well as bathrooms in the
suites. In the later stages, we aim to make the lab accredited for
conducting tests and also an independent certificate provider for
commercial purposes.”
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“Hospitality
kitchens are no more just cooking areas,” says Neel Chauhan. Gone are
the times when commercial kitchens were just a cooking area, now with
the engagement of professional foodservice designers, technological
advancements in food production equipment and influx of international
hotel and restaurants operators, and varied international cuisines have
made a significant impact on kitchen designs. “Today’s kitchen has
parameters such as effective space utilisation, energy efficient, easy
for operations and should provide healthier and safer work environment
for the chefs. There is clear and certain distinction of the flow
starting from pre-preparation areas to food production and service. The
aesthetics inside the kitchen like right kind of flooring, walls,
ceiling is equally important,” he added.
There is also a trend to
go more Greener in terms of operations, waste disposal and recycling as
food safety guidelines mandates procedures for hygiene in kitchens,
notes Bhandari. Due importance is being given to ‘green’ or sustainable
hotels, non-polluting environmental clearances. Also, the growing
popularity of LEED Certification has led to a new thought of line in
terms of water and waste management. Investment in technology for water
and energy conservation methods, recycling of waste and built-in
hygienic safeguards to arrest kitchen pollution is increasing, informs
Bhandari.
Vendors Outlook
In
the last few years many of the major national and multi-national food
and beverage companies have started asking their local distributors and
wholesale dealers to obtain licenses under the FSSA. Under the Act,
vendors and distributors can be held liable for selling products after
its date of expiry, misbranding, and storing in unsafe conditions rather
than the manufacturer. The Act states that food business operators
functioning without license can be imprisoned for six months and fined
up to Rs five lakh. Dealers found selling substandard products are
liable to be fined up to Rs five lakh and those selling misbranded
products, up to Rs three lakh. Obtaining these licenses will make the
dealer conform to the stringent norms on storage, transporting, and
distributing food products. Conforming to the Act will ensure that high
food safety standards are maintained. The licences have to be renewed
annually.
The strong world-wide trends for health and wellness
have affected demand for modern kitchens. A lot of thought and planning
goes into the modern, new-age, ergonomically designed kitchen.
Vegetables and other perishables have to be kept fresh, and prepared so
that they preserve their nutritional value, using as little fat as
possible. Need and adherence to FSSA compliance is an Executive Chef’s
top priority today.
Commenting
on FSSA Act, Marco Pesce, Country Manager, Electrolux Professional
said, “For Electrolux, it is a great opportunity, as our equipments like
the Air-o-steam Touchline and Air-o-convect Touchline combi ovens,
Air-o-chill blast freezing systems, and pressure bratt pans support the
new age culinary techniques like sous vide and cook n chill support the
endeavours of the chef to keep up with hygiene and food safety trends in
the commercial kitchen. Thus, we are by far the leaders in the industry
in providing hi-end equipments which support the users’ requirement in
maintaining food safety and hygiene.”
With more and more
parameters coming in force, it is a matter of time that the Industry has
to follow Global standards which will help provide world class service
and with more professionalise approach this transition will become a
smooth affair.
Sanjeevak
Marwaha, Managing Director, Winterhalter India said, “With FSSA coming
into force Hospitality & Food Industry will take extra measures to
ensure cleanliness and hygiene. Winterhalter is extremely well placed to
address these concerns from FSSA segment, as all our products are
designed with a clear focus on delivering hygienically clean dishes to
our customers. Also, with our wide sales network and market leading
products, we are ready to partner the industry to embrace this change.”
He
also added that Winterhalter ensures safety and hygiene standards and
measures as per the regulatory norms. They import every single unit from
Germany, Switzerland and UK. Since all their products are certified as
per European Standards, they do not undertake any other certification
and testing of machines in India. Winterhalter Gastronom GmbH was
awarded certification for quality, environmental protection and
occupational health and safety by the Swiss Association for Quality and
Management Systems, and is amongst the first to get such a comprehensive
certification.
Rakesh
Tara, Country Manager – India, Angelo Po Grandi Cucine said, “Our
products like Chicken Star Combi ovens are one of the product from our
vast range which helps a Chef finish his work faster and in a very
hygienic way, besides this there are various other equipment which in
true sense are Chef’s companion. Besides our various equipments training
and service programmes, our company is actively engaged in uplifting
the conditions of the kitchen where food safety and hygiene are most
important parameters and now even government is getting serious to check
the hygienic conditions of the kitchen. This has also promoted us to
introduce more user-friendly washing functions in our Combi ovens.”
With
food preparation becoming a visible activity and show kitchens becoming
popular, along with functional efficiency of the gadgets and
equipments, the whole look and feel of the equipments have become
increasingly important now. Commenting on how much this is putting extra
pressure on manufacturers and vendors on R&D, Tara explained,
“There is lot of pressure on manufacturers to make beautiful equipment
which can be placed in front of the guests, instead of the closed
kitchen as in earlier times. Hence, chic and sleek looking equipment is
the need of the hour. Beautiful monoblocks with practically all colors
are available from our stable and features like Combi oven with
personalised signature for branding, smoker kit and pasteurisation kit
are some of the new features of our products which place us above other
manufacturers.”
‘FSSA: Extreme idea of deterrence would create life-long resistance to the Act’
Dr
V Pasupathy is a renowned Food Scientist and a Certified Lead Auditor
on Food Safety Management Systems in the country. He has conducted
umpteen workshops for Food Business Owners (FBOs) and hospitality
industry stakeholders on the impending Food Safety & Standards Act
(FSSA). In the light of FSSAI differing the deadline for
conversion/renewal of existing licence for the fourth time for another
six months, HospitalityBiz approached Dr Pasupathy to understand the
loopholes in the Act, which makes its enforcement impossible and
impractical.
- A self declaration act till date is not understood by state governments as they believe in blind enforcement.
- Our
views and technical issues were sought by the FSSAI by March 31,
2011. But till date no answer or explanation has reached the industry.
We were not even called for a discussion on these.
- Penalties are
10 to 200 times higher compared to the earlier PFA . Extreme idea of
deterrence can become life long resistance and that is what has happened
to this law.
- Much of the discourse on preconditions for the FBO
s are to do with civic amenities . Local government bodies have
miserable track record of performance and industry cannot be a victim
for their non performance.
- In right earnest hotel industry
across India conducted workshops. I have personally travelled , taken
8- hour workshop in each location covering more than 10000 owners and
professionals. So our commitment cannot be doubted. No FBO is objecting
to punishment for adulteration nor objects to hygiene assurance.
- Industry is scarcely represented in the Central Advisory Council. This makes the law unenforceable.
- The standards indicated are unreal as such raw materials don’t exist in India.
- Pesticide
residue level is a laughing stock as neither central government nor
state government nor universities nor scientists nor academicians who
are behind the drafting can show us any sample in this country without
these residues.
- There is huge contradiction between stakeholding
Ministries of the government like Chemicals & Fertiliser ,
Agriculture Ministry and Health Ministry. No one has answers but they
expect FBO s to follow them.
- No state government budget or
Central government budget has any plans for argumentation of the FSSAI
with provision for laboratory facilities or resources deployment , etc .
In
short, FSSA is unenforceable not because industry rejects or
underestimates the significance of food safety. As entrepreneurs
customers are important to them and their well being is paramount.
Business men don’t get dismissed or reelected nor do they apply for
transfers. For most of them the business they do is their social
identity card.
If drainage systems work ,if garbage clearance
happens on time, if government slaughter houses are professionally run,
if fruit and vegetables market have bare minimum hygiene, if ground
water is without pesticide residue, FSSAI will become the act that it
wants to be or else it will continue to be an incomplete bridge. As a
scientist, I am positive but worried. My nation needs food safety but
through a methodology that is more practical.
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A
lot of hotels are applying international standard, not only
International brands but also local ones. Apart from FSSA, ETL approvals
or HACCP certification is becoming mandatory in India also. The new
Electrolux Hood Type dishwashers come with ETL Sanitation Approval and
comply with DIN 10512 standards. The excellent washing and rinsing
performances of the dishwashers result in the highest standards of
cleanliness (the wash water is free from food residue) and hygiene
(total detergent removal), and the high quality rinsing results in
complete sanitation.
“Our
machines are HACCP certified, and allow HACCP monitoring via an
integrated PC network, thus equipping the Chef with ready solution to
maintain high level of hygiene efficiency. Most importantly, Electrolux
Touchline ovens provide fully automatic cleaning, from four pre-set
cycles including the new green functions of the integrated cleaning
system. This eco-friendly cleaning option optimises the consumption of
rinse aid, electricity and water; reducing up to 50 per cent of the
running costs; saving energy time after time and preserving the
environment. At the end of the Shift, a Chef can leave a perfectly clean
oven, ready for next day’s cooking,” added Pesce.
