Ref: TFMA / Press Release / 2014-15 / No.0119 14.07.2014 To The Editor, The Hindu, The New Indian Express, Business Line, The Times of India Madurai. Dear Sir, Greetings. On behalf of our Association, President Thiru S.P.Jeyapragasam, Hon.Secretary Thiru S.V.S.S.Velshankar, Vice President Thiru Perrys P.Mahendravel, Joint Secretary Thiru M.Karthikeyan, EC Member Thiru N.Giridharan and Thiru P. Baskaran met Health Secretary of Tamilnadu Dr.J.Radhakrishnan I.A.S., and Food Safety Commissioner of Tamilnadu Thiru Kumar Jayant I.A.S., in person at Chennai on 14.07.2014, Monday and submitted a memorandum to remove the defects and shortcomings of the Food Safety and Standards Act 2006, Rules and Regulations 2011. We request your goodself to publish the same in your esteemed Newspaper.

Thanking you With kind regards (S.P.Jeyapragasam) President Encl: As above

Ref: TFMA / FSSA/ 2014-15/ No.0121 14.07.2014 To Thiru Kumar Jayanth I.A.S., Commissioner, Food Safety Department, Chennai. Sir, Sub: To remove the defects and shortcomings in the Food Safety and Standards

Act 2006, Rules and Regulations 2011. Greetings. On behalf of our association, we would like to thank you for organizing a meeting with C.R.Dalal, Director FSSAI and forwarded our memorandum with 21 valid points to the FSSAI Authorities at New Delhi to remove the defects and shortcomings in the Food Safety and Standards Act 2006, Rules and Regulations 2011. Today in this meeting we are suggesting the following demands which your goodself has to forward to the FSSA Authorities at New Delhi and do the needful.

1. The first and foremost thing is the quality of the agricultural produces, the FSSAI authorities have fixed the quality of the agricultural produces and other food products same as the old PFA Act 1954. The quality standards of the agricultural produce has to be fixed according to the present day standards, otherwise food business operators will be affected.

2. Under the FSS act, the FBO has to register by paying Rs.100/- if his turnover

below Rs12 lakhs per year and has to take license by paying Rs.2000/- if it is more than Rs.12 lakhs, for interstate sales he has to pay a fees of Rs.7000. This will severely affect the small, medium level Food Business Operators. We feel that, this fees has to be Rs.100 for registration, Rs.500 for Food business operator who’s turn over is more than Rs.12 lakhs, Rs.1000/- for food business operators who are doing other state business.

3. It has been mentioned under this act, 3.2.1 Colouring matter, under section 4, for

synthetic food colours Red (Ponceau4R), Yellow (Tartrazine), Blue (Indigo Carmine), Green (Fast Green) can be added.

Tartrazine has also been approved by the drug administration authority that it can be added in certain medicines and life saving drugs.

-2- It has also been mentioned for yellow colour, Tartrazine can be added in the following food items.

1. Ice Cream, Milk lollies, Frozen Desserts, Flavoured Milk, Yoghurt, Ice cream Mix

Powder. 2. Biscuits including biscuit wafer, pastries, cakes, confectionery, thread candies,

sweets, savouries (dalmoth, mongia, phululab, sago papad, dal biji only); 3. Peas, strawberries and cherries in hermetically sealed containers, preserved or

processed papaya, canned tomato juice, fruit syrup, fruit squash, fruit crushes, fruit cordial, jellies, jam, marmalade, candied crystallized or glazed fruits;

4. Non –alcoholic carbonated and non –corbonated ready to servie synthetic beverages including synthetic syrups, sharbats, fruit bar, fruit beverages, fruit drinks, synthetic soft-drink concentrates;

5. custard powder; 6. Jelly crystal and ice candy; 7. sausages, Corn Flour, Corn Syrup, Rasagolla, Coffee extract, flour confectioned,

smoked fish,baked foods,flour for baked food, Packed paneer, cakes and pastries, coconut water

Pulses and grams are mainly procured from North India for catering the demand in Tamilnadu. Expecting a better price for the produce, the farmers and the millers in North India are adding Tartrazine powder for dhall and other items. The addition of tartrazine powder to the dhall cannot be checked visually. The food business operators in Tamilnadu convert this dhall to flour. When the flour is checked by the authorities, they are issuing notice to the food business operators that the food is unsafe because of the addition of tartrazine powder. This should not be described as unsafe food. Under this act, a food item is said to be unsafe when the colours not in the schedule are added to the food. The authorities has to clarify the above, because under the same act it says tartrazine can be added for yellow colour to certain food items, and it says it is an unsafe food if it is added to a food item not in the schedule.

4. Under this Act, there is no quality standards defined for South Indian traditional food items like Appalam, Vathal and Vadagam. And there is no information about whether any synthetic colour can be added to the above items. Your goodself has to clarify with the FSSA Authorities in New Delhi regarding the above matter.

5. Sugarcane Jaggery, Palm Jaggery and Palm Candy are prepared from Sugarcane Juice and Palm Juice by the farmers. Traditional foods like Puttu, Appam, Paniyaram, Athirasam are prepared using this jaggery and candy by the small, medium food business operators. Since the liking for golden coloured jaggery is more and also for better prices, the farmers are adding chemicals, colours, sugar, maida, urea, acids etc., to these items. The food business operators, who procure these items to produce the traditional foods are affected.

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Lab facilities and infrastructures are not enough to check this type of adulteration. The food business operators are the only affected, when these food items are checked for quality by the concerned authorities.

6. Under this act, the proprietary food manufacturer has to pay a fees of Rs.25000/- to

the FSSAI authorities for getting their product approved. This will affect the medium and small scale food manufacturer drastically. We feel that no fees has to be charged or a nominal fees of Rs.500/- should be charged for this purpose. In this act, product approval regarding the proprietary food is not defined properly. The act says proprietary foods like Atta, Suji, Dhall, Samosa, Gulab Jamun etc., This “etc.,” is causing confusion among the food business operators and the authorities.

7. Since, under this act, the chemicals which can be added for colour to the food items

is not defined properly, the notices served by the food safety and standards authorities to the food business operators in respect of above should be discharged.

8. In India during the past few years only, food items are sold in packages from 100

grams to 1KG. So there is only little awareness among the food business operators regarding the packing and labelling of food items. Till than they should not be punished for the same For e.g., Kesavan Maligai in Sivagangai district Tamilnadu has been penalized for Rs.10000/- for mistake in labelling of his product – Moong dhall in not printing the name of the food item, s as veg/non veg, batch no and best before date.

9. During the recent past the authorities are punishing the FBOS for their small

mistakes under misbranding and unsafe food. Till this act is clarified we request the food safety and standards commissioner to visit the concerned cities and meet the food business operators discuss with them and discharge the genuine food business operators from these cases.

10. There should be NABL accredited laboratories in all the districts. This accreditation

should be given to the labs which are run by non profitable organizations like our Tamilnadu Foodgrains Merchants Association, Madurai. The Tamilnadu Government should be urged to give subsidy for these labs.

11. We came to know that the authorities has been directed to take specific number of

food samples in a month. Till the defects and shortcomings are removed under this act it should not be followed.

-4- 12. Recently, the food safety and standards authorities took samples of the chicken from

KFC Coimbatore after a complaint the sample was sent for checking and no action has not been taken against the concern. At the same time, street vendor if he sells chicken with color the authorities are throwing away the chicken in the street which will spoil the livelihood of street vendor.

We request your goodself to take this matter to our Hon’ble Chief Minister of Tamilnadu Selvi J.Jayalalitha through Dr.C.Vijayabaskar, Hon’ble Minister for Health and urge the Central Government to remove the defects and shortcomings in the food safety and standards act.

At present, the deadline for getting Registered and License under this act ends on 05.08.2014. We request your goodself to urge to provide us another extension of One year from 05.08.2014 onwards till the shortcomings and defects of this act are removed. We request your goodself to urge the FSSAI Authorities to reform the present committee of the Food Safety and Standards Act, so that the new committee compromise of 1/3rd of Indian Agriculturist, 1/3rd of Food Scientists and 1/3rd of Food Business Operators, Manufacturers and Traders after fully examining the Indian conditions will constructively modify the Rules and Regulations of this Act. Thanking you, With Kind Regards, (S.P.Jeyapragasam) President