Stop Toxic Adulteration : Open letter to FSSAI and AGMARK

Stop Toxic Adulteration in Food

Open Letter to Food Safety and Standards Authority of India (FSSAI) & AGMARK

To,

The Chairperson / CEO
Food Safety & Standards Authority of India
Ministry of Health
Govt. of India
New Delhi

&

The 

The Joint Secretary / Director, 

Incharge for AGMARK

Ministry fo Agriculture

Government of India

Dear Chairperson / CEO / JS/ Director,

Subject: Letter of 19^th Aug 2020 (attached) is legally ineffective and will have no impact on adulterated oil suppliers. : This appears to be an eyewash

Eat Right (adulterated food) is the joke of FSSAI,

if food adulteration is not controlled.

The mentioned letter on the subject is a baby step but this is a half-hearted incomplete attempt to address the serious concerned with public health.

FSSAI has issued the advisory in the form of a letter and it has no legislation under the court of law. In past, such advisories were questions in the court and courts refused to accept such directions unless issues as proper notification.

Unfortunately, the letter reminds the department about the power of food safety officers. The record of the department and the market flooded with adulterated and substandard products clearly indicates that this advisory will have no effect on the ground.

If they had any concern, commitment, and understanding of their moral and legal duty, citizens’ health can be saved from adulterated products. Unfortunately, as a citizen, with the experience I can say, this will have no positive impact on the ground. Corruption is due to these powers under the act. Your letter will only create more corruption opportunities. I will be happy to see the change on the ground this time under your leadership.

1.   As citizen, I also expect transparency in the function of FSSAI. FSSAI must honestly disclose how may oil samples were tested every week, how many were found adulterated, and how many suppliers were booked and factories sealed. Unless there is an action on the ground, do not expect this letter of FSSAI has any impact on the ground.

2.   It is sad to see that citizens of India are suffering due to adulteration and FSSAI is taking too long a time to issue a proper logical notification to protect public health. This letter also ignored many vital parameters which were suggested for controlling adulteration.

As a citizen of India, let me help FSSAI in formulating the proper standard and rules. If the technical advisory committee has any issue with any of the following suggestions, the same should be discussed in an open forum. The industry should know the reason for rejecting the following suggestions.

My humble request is the following points should be considered and included in the regulations to control the adulteration in India edible soil in India.

1)  Raw oils should NOT be allowed for blending under any pretext.

2)  Only refined oils meeting FSSAI standards are allowed for blending.

3) Colour of the edible oils, other than raw oils, must be mandatory parameters under FSSAI and Agmark in line with BIS.

4)  All blended edible oils must mention Fatty acid profiles on the product label to know the truthfulness of the blended oil and claims made on the label.

5) All oils, not added with rice bran oil must mention, must mention “Free from Oryzanol” on the label.

6)   All oil samples must be tested for Oryzanol content

7)  All raw oils and refined edible oil standards must specify mono-glycerides and di-glycerides parameters in FSSAI and AGMARK.

8) Mono-glycerides and di-glycerides parameters oils must be tested for these items in every sample.

9)  Raw Mustard oils (Kacchi Ghani) must have a minimum 35% erucic acid and diglyceride content is not more than 2%.

10)All Invoices must mention the license and registration number of the purchasing dealer to minimize mixing in tankers and in godowns: Modify Point no. “14 in FSSAI licensing condition - The Manufacturer/ Importer/ Distributor shall buy and sell food products only from, or to, licensed /registered vendors and maintain record thereof. The invoice/delivery challan in respect of the sale/movement of vegetable oils must mention the license/registration number of the purchasing dealer. " 

11) Modify Point no. “5 in FSSAI licensing condition. Every sale and movement of stocks of solvents-extracted oil,'semi-refined' or 'raw grade I’, 'fatty acids / acid oils produced during the refining of vegetable oils', edible groundnut flour or edible coconut flour, or both by the producer shall be a sale or movement of stocks directly to a registered user and not to any other person, and no such sale or movement shall be effected through any third party."

12) Ministry of Finance and Corporate Affairs, FSSAI and Agriculture Ministry must enforce Section-148 under Companies Act 2013 on all food companies.  This will ensure only good material and purchased by the company. This will be verified by the statutory auditors and should be made part of the annual report to shareholders and to ROC. This will ensure not only safe products but also proper GST collection for the government.

If any help is required in explaining these self-explanatory points, undersigned will be happy to explain all the technical and legal justifications in from of any expert in the country or outside India. Please provide the opportunity for the same before rejecting the above points in the public interest.

Appeal: My requests to all FSSAI leadership and officials, you all are paid salaries to sustain your decent lifestyles and families by taxpayers and your inaction is making the same taxpayers and their families sick due to adulterated foods. Is this morally and ethically right?

Your actions will speak louder than your words. Citizens are watching carefully are you ensuring that foods are delivered as per the laws or not.

I wish you all the best so that you have the courage to take a right stand against the wrong door and make the system FSSAI transparent before more citizens of India become victims of adulterated foods. FSSAI actions must be visible and should inspire confidence among citizens. Are we expecting more than the minimum required?

Waiting for proper elaborate notification on this vital concern of the citizens.

With best regards,

 

Vijay Sardana

 

CC:

1.    PM Office

2.    All Concerned Ministers

3.    All Concerned Secretaries

4.    All Concerned Departments

Copy of the letter issues: This letter has no legal standing. This is not a law. Please issue the proper notification.