Meat Food Safety Regulation and Certification

Need and various aspects of food testing and notified NABL, Referral and Reference labs:

Access to safe, reliable and nutritious food supplies is a basic need for all people. Food industry in India is evolving every day. There are thousands of food companies, manufacturers, restaurants, processing companies, food carts and cloud kitchens that are catering to the demands of rapidly growing urban and semi-urban cities across India. Hence it is of utmost importance that the food production process should pass through stringent quality tests to ensure that what we consume is safe across all parameters.

The safety of the food supply appropriately remains a high priority for industry stakeholders, regulatory agencies and consumers. In such instances, accurate data derived from sound, validated analytical methods are required to enable industry stakeholders and regulators to make sound scientific decisions.

Food testing laboratories play a very important role in this whole process. Food products tested can range from agricultural commodities to processed foods, from the field to the store. The testing can be done on raw materials, the product during its processing and production, as well as the finished products. Food testing is integral to the efficient production of safe, quality products. With the food industry increasingly subject to scrutiny, testing to ensure compliance with food safety regulations and to protect public health, is a must.

Food control system in India:

Food control plays an important role in assuring a high quality, safe and nutritious food supply for the public, for their good health and for the economic benefits derived from trade in safe and high quality food. What makes food safe is through an effective food control system. Food control system is a mandatory regulatory activity of enforcement by national and local authorities to provide consumer protection and ensure that all foods during production, handling, storage, processing and distribution are safe, wholesome and fit for human consumption; confirm to safety and quality requirements; and are honestly and accurately labelled as prescribed by law (FAO). There are primarily three facets of the national food control system imports, exports and domestic. In India, domestic and import food trade is covered under Food Safety Standards Act (2006) and export trade is covered primarily under the Export (Quality Control and Inspection) Act (1963).

There are four important pillars for an effective food control system

• Legislation/Regulation
• Inspection
• Testing
• Enforcement

Food testing is all about Quality and Integrity of data. The growth and infrastructure of the modern global food distribution system heavily relies on food analysis (beyond simple characterization) as a tool for new product development, quality control, regulatory enforcement, and problem solving. Laboratories are an essential component of a food control system.

Challenges faced in food testing

• Dynamic standards and its harmonization
• Fit for purpose of analytical methods is critical in building trust in control systems
• A critical issue will be how to detect untargeted compounds and determine their identity in foods
• Food authenticity and food fraud

Accreditation body and the need for accreditation:

Accreditation is a formal declaration by a neutral third party that the certification program is administered in a way that meets the relevant norms or standard of certification program.
Accreditation is a procedure by which an Authoritative Body (Accreditation body) gives formal recognition that a Body (laboratory) is competent to carry out a specific task (testing/calibration).
Accreditation uses specific criteria developed to determine technical competency of the laboratory. This is generally an independent evaluation of laboratory’s technical competence.

Benefits of accreditation:

• International recognition (Once tested may not be checked further)
• Access to Global market
• Saving in terms of time and money as it reduces or eliminate the need of re-testing
• Increased confidence in the test reports generated
• Customer needs and enhanced confidence and satisfaction
• Lab can demonstrate its commitment to quality with robust Quality management system
• Systematic and better operational control of lab work
• Assurance of accurate and reliable results
• Regulatory and importing countries requirements
• Use of NABL symbol as indication of accreditation
• Accreditation gives equivalency to laboratories
• Rise in business

Importance of accreditation for Food Business operators:

• Minimizing Risk of producing Faulty Food Products entering the market
• Avoid expensive retesting
• Eases export and import issues regarding Food safety

In India National Accreditation Board for Testing and Calibration (NABL) is the national accreditation body under Quality Council of India, Ministry of Commerce and Industry, Govt. of India. NABL grants accreditation to testing & calibration laboratories as per ISO/IEC 17025. NABL operates its own system as per ISO/IEC 17011:2004 Conformity Assessment: General Requirements for Accreditation Bodies accrediting Conformity Assessment Bodies. NABL Accreditation is a voluntary program except in case of regulatory bodies it may be mandatory to have accreditation.

Need for Accreditation in food testing laboratories:

• To ensure accurate, reliable and reproducible test results
• To achieve consistency and uniformity in test results
• To meet customer requirements
• To meet regulatory requirement and Government agencies
• To ensure equivalence of results produced by different laboratories
• Global acceptance of test reports generated

Pre-requisite for Accreditation:

1. Pre-requisite for Accreditation through NABL is given schematically
2. General Information Brochure
3. Appropriate documentation
4. Training of laboratory staff on technical and management requirement
5. Preparation of QM, System procedures, SOP as per ISO 17025
6. Ensure training of personnel and Accommodation and environment
7. Ensure measurement traceability through calibration of equipment used
8. Participate in PT and ILC programs
9. Conduct Internal Audit and MRM
10. Meet regulatory requirement
11. Apply for Accreditation

Compliance Requirements in a food testing lab:

• Personnel: Qualified, suitably trained, experienced and motivated personnel in sampling and testing. The sampler shall have the minimum qualification of graduation.
• Sampling: Laboratory should be able to demonstrate that the sample drawn is true representative of the lot/consignment.
• Handling of Samples: Appropriate procedures and implementation to ensure that the samples are drawn, transported and received in lab and thus ensuring chain of custody.
• Equipment: Adequately equipped to carry out sampling, sample homogenization and analysis as per various regulatory requirements. Expertise to interpret the data generated as per the regulatory requirement. Availability of traceable Reference standards.
• Methods:Adopting appropriate method for sample preparation and analysis.
• Analysis:Preparation of Reference standards. Intermediate checks of Reference standards. Use of appropriate method calibration with due care on dilution factors applied, criticalities of the steps involved in extraction. Recovery correction in results.
• Method Validation (“fit for purpose methods”):As per the regulatory/importing countries requirement. Access of Validation document to the concerned analyst. Validity of a method Validation? Changes in Man, Machine and Method calls forrevalidation/verification.
• Applicability of method:Same method being used for different matrices without any verification/without checking the applicability.
• Internal Quality Control:A strong internal Quality control programme to ascertain that the methods are in control and to decide whether the results are reliable enough to be released. The use of control charts to monitor QC results.
• QC Samples:The cost/availability of CRM (in matrix) necessitates the use of QC materials (inhouse/external). QC samples analysed at intervals in an analytical batch, Blanks & duplicate analysis.
• Traceability in activities: Ensuring audit trails (If you didn’t write it down, it NEVER happened).
• Measurement Uncertainty (MU):Reporting of MU with the results in order to facilitate customer/decision making authority to take and appropriate decision and prevent loss in trade.
• Accreditation in compliance to ISO/IEC 17025:2017
• Regulatory approval to comply with importing countries requirement

Role of referral and reference laboratories:

In India there are about 200 notified food testing laboratories under FSSAI, eighteen FSSAI Notified National Referral Laboratories under section 43 (2) of FSS Act, 2006, Twelve national Reference laboratories and two ancillary national reference laboratories under regulation 3 of FSSR, 2018.

Role of referral laboratories:

• R&D activities, providing training and to perform other functions like analysis of samples, and investigation in collaboration with other labs.
• Surveillance samples on specified food commodities as decided by FSSAI
• Testing of food on appeal in case of a challenged analytical result at primary level.

Role of reference laboratories:

• Be resource center for provision of information for certified reference material and reference materials
• Develop standards for routine testing procedures and reliable testing methods
• Provide technical support in their area of competence
• Evaluate performance of other notified laboratories
• Coordinate and exchange of information among notified laboratories
• Collaborated for data generation of specific areas among network of notified and referral laboratories
• Ancillary NRL would support NRL in providing PT to notified laboratories in specific areas
• Ancillary NRL Assist NRL in method development/method validation/interlaboratory comparison

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