MRL and Food Safety Update India - California Specialty...

USDA – June 2016 • 1

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Dr. Deepa Bhajekar, Director

MRL and Food Safety Update India

USDA – June 2016 USDA – JUNE 2016 • 2

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USDA – June 2016 USDA – JUNE 2016

INDIA PESTICIDE SCENARIO

! India is one the dynamic generic pesticide manufacturers in the world – 60 technical grade pesticides manufactured by 125 producers with over 10 MNC’s and local companies spreading across 500 formulators in the country

! Total agrochemical biz – Rs. 25000 Cr = approx 4 billion USD --- 6.8 billion USD by 2017 (local and export) 50 : 50

! The per hectare consumption of pesticide in India is 0.6 Kg per hectare vs. 3 Kg per hectare in the rest of the world (average)

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! The Insecticides Act 1968 – All Insecticides to undergo registration with Central Insecticides Board and registration committee (CIBRC) before they can be made available for sale.

! Pesticide Management Bill 2008. It repeals the Insecticide Act 1968

! The Central Insecticide Board and Registration Committee (CIBRC) registers pesticides In India and recommends them for various crops

! A total of 234 pesticides have been registered by CIBRC including Endosulfan the use of which was banned in India in May 2011

! The FSSAI is responsible for setting the MRLs which have been registered by CIBRC

! The MRLs are set per crop • 4

Pesticide regulations


PESTICIDE REGULATIONS

Pesticide regulations in India are governed by the following Acts / Rules ! The Insecticides Act 1968 – Rules 1971 ! The Environmental (Protection) Act 1986 ! Hazardous Waste (Management & Handling) Rules 1989 ! Water (Prevention & Control of Pollution) Act 1981 ! Prevention Of Food Adulteration Act1954 – NOW FSSA –

FSSR – 2006-2011 ! The Factories Act 1948 ! Bureau Of Indian Standards Act

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DRAFT NOTIFICATION – RESPONSE TO WTO-SPS 23.11.2015

! FSSR – 2011 – Contaminants, Toxins and Residues – Regulation 2.3 relating to residues

! 2.3.1: Insecticide Residues on Agricultural Commodities and Resultant Processed Food

! Note: All these MRL/tolerance limit values are provisional for a period of five years and not fixed on the basis of actual data in the Indian context. They may be reviewed after five years or as and when the relevant scientific data is made available to FSSAI, whichever is earlier.

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! 2.3.2: Restriction on use of Insecticides ! Table for 199 pesticides put up for review of MRL in

mg/kg for different food matrices – milled grains, wheat grains, milk, potatoes, eggs, fruits, fresh vegetables, rice, meat, chilli, groundnuts, maize, soya-bean, tomatoes, cumin, dry fruits, tea, grapes, sesame seeds, oil seeds, coffee, cardamom, oil

! For some odd uncommon pesticides MRL is fixed at LOQ – 0.02 mg/kg.

! For registered Insecticides where label claim is not available for the said commodity – MRL is fixed at LOQ

! Pesticides banned as per the Insecticides Act 1968 are tabulated against the specific food listed - 20

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! 2.3.3: Drugs, Pesticides and Antimicrobials including Antibiotics for Veterinary use registered under Drugs and Cosmetics Act – 1940 (23 of 1940) – Codex harmonization

! For all pesticides used for topical application, the regulations/codex MRLs/tolerance limit may be adopted wherever available. If no regulations/codex MRLs/tolerance limits are available, risk assessment based on the metabolism data and withdrawal period shall be done; which is to be considered in conjunction with its MRL/tolerance limit, if any, as pesticide; to find out the residues left in the tissues/ milk/ eggs as well as the crops in which it is allowed to be used. Thereafter, appropriate MRLs/ tolerance limits may be fixed. • 9


! The MRL / tolerance limit wherever fixed on the basis of monitoring data a review of identified pesticides Vs Crops shall be undertaken w.r.t extent and quantum of use including toxicological profile of pesticide. In case the use in negligible the same MRL can be continued or a GAP study is to be undertaken

! Wherever the MRL/tolerance limits are fixed without any data, it should be prefixed with “T” (Temporary).

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CHALLENGES FOR HARMONIZATION ! A pesticide may have different patterns of use – due to

geographic location, climate and dietary and cultural preferences

! Variation in criteria for setting MRL’s based on national policies and legal standards, different methodologies in calculating MRL’s

! Crop grouping in various countries ! Definition of residue may differ in different countries

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MORE CHALLENGES

! Variety of pests ! Climatic variation – level of infestation ! Training on knowledge of use of pesticides ! Application methods, Spraying methodology and half

life – residue levels differ even if same level of pesticide is sprayed

! Post harvest handling ! Sampling methods for export – variation ! Analytical skill and infrastructure up gradation is not

even ** ! Modalities to fix MRLSs for processed foods given that

there would be a complex mix of various matrices • 12


ACTION BEING TAKEN IN INDIA

! Reviewing Status of Pesticide used globally per crop ! Establishing Uniform Protocol for data generation ! Prioritizing Compounds and generation of residue

data ! Commutation of available data and submission to

Codex ! Data bank used in harmonization of MRL in

individual crop importing countries and at national level

! More compounds being targeted for data generation ! Country regulations on MRL are being updated ! IPM being encouraged

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SOME SOLUTIONS ? ! Phasing out strong pesticides / banned pesticides ! Calculating the half-life and adjusting spraying time ! Supplementing the chemical pesticides with natural

alternatives ! If the MRL’s vary due to susceptibility of consumers based

on dietary pattern in different parts of the world ….harmonization ??

! Can we come to situation where we are aligned to agreeing on a common risk assessment data

! Transparency of risk assessment processes in different countries

! Addition of new compounds into the global pesticide database – acceleration in the speed ! Development of a universal position statement ! Bilateral trade agreement

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WHAT IS NEEDED ?

**Productivity **Protection **Profits **Growers **Industry **Regulators TRADE !!

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• The dose makes the poison – Paracelsus (1493-1541)


! Food and Nutrition board ! National Fisheries development board ! Sugar Board ! Coconut development board

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FOOD SAFETY UPDATE

! The Food Safety and Standards Authority of India (FSSAI) ! Established under Food Safety and Standards Act, 2006

consolidates various acts & orders in various Ministries and Departments.

! FSSAI has been created for laying down science based standards for articles of food and to regulate their manufacture, storage, distribution, sale and import to ensure availability of safe and wholesome food

! A single reference point for all matters relating to food safety and standards, by moving from multi- level, multi- departmental control to a single line of command --- an independent statutory Authority

! Ministry of Health & Family Welfare, Government of India is the Administrative Ministry for the implementation of FSSAI

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FSSAI ROLE

! Framing of regulations to lay down standards ! Accreditation of laboratories and certification bodies ! Scientific advice to the central govt. ! Collate data – food safety, outbreaks, emerging risks, rapid alerts ! Information network – issues of concern ! Training programmes for FBO’s ! Development of international technical standards ! Spread awareness about food safety ! Monitoring quality of food via FDA inspectors trained under FSSAI ! Conducting inspections of manufacturing locations

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CSE – CENTRE FOR SCIENCE AND ENVIRONMENT ! Recent issue of bromates in bread – India allows 50

ppm till 24th May. ! CSE brings out a report of 38 breads containing

bromate – 2 to 25 ppm highlighting the carcinogenic effects

! Bromate is banned in Canada, Brazil, EU although permitted in USA – 75 ppm.

! TOI headlines – FSSAI bans use of bromate in bread ! ! May 25 th – ban issued…notification will follow

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The food you eat can be either the safest and most powerful form of medicine or the slowest form of poison !

Thank you

[email protected] Cell : +919867242000

MRL and Food Safety Update India - California Specialty...

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