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Residue Monitoring System Issuance of Health Certificate GAP including ethical practices in export

Residue Monitoring System Issuance of Health Certificate GAP including ethical practices in export. MAMTA RANI ASSISTANT DIRECTOR 06 September 2011. About Us. Export (QC&I) Act, 1963 – The Act governing quality of exports

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Residue Monitoring System Issuance of Health Certificate GAP including ethical practices in export

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  1. Residue Monitoring SystemIssuance of Health CertificateGAP including ethical practices in export MAMTA RANI ASSISTANT DIRECTOR 06 September 2011 EXPORT INSPECTION AGENCY - DELHI

  2. About Us • Export (QC&I) Act, 1963 – The Act governing quality of exports • EIC set up to advise Govt. on measures for sound development of exports through QC & I to include notification of standards & certification systems • Powers of Central Government under the Act • Notify commodities for compulsory PSI • Specify standards for export and type of QC & I • Establish or recognize Agencies for QC & I • Nearly 1000 commodities were notified. EXPORT INSPECTION AGENCY - DELHI

  3. EIC (CA)-STRUCTURE • Apex Body – Council, Chairman, 18 members, Member Secretary- Director, EIC • Specialist Committees • EIC – The Central Competent Authority • CEO Director, office at Delhi • Regional Competent Authorities– 5 EIAs at Mumbai, Kochi, Kolkata, Delhi and Chennai, under administrative & technical control of EIC • 28 Sub-offices & labs EXPORT INSPECTION AGENCY - DELHI

  4. SYSTEMS OF EXPORT INSPECTION & CERTIFICATION • Consignment wise inspection • In-Process Quality Control • Self-Certification • Approval and monitoring of processing and manufacturing units based on food safety management systems such as GMP/ GHP / HACCP. EXPORT INSPECTION AGENCY - DELHI

  5. EIC-ROLE IN WTO REGIME • Regulatory role to • address health & safety concerns of importing countries • compulsory certification for Marine products, Egg products, Milk products, Honey products, Poultry Meat products etc. • Voluntary export certification – Tea, F&V, Spices, Basmati Rice • Equivalence Agreements/MOUs with trading partners for recognition of EIC’s certification • Certificate of Health (Food items), Authenticity (Basmati Rice-EC) • Laboratory Testing • Support for Export Inspection & Certification • Commercial testing (facilities extended to industry) • Import testing of food items-EIA Labs identified by MoH&FW EXPORT INSPECTION AGENCY - DELHI

  6. EIC - ROLE IN WTO REGIME CONTD…. • Training and technical assistance to industry to upgrade to International standards • Represent India’s interests in International standards bodies/ WTO - views based on practical experience • Continuous dialogue with importing countries for problem solving on non-tariff related issues • Problem oriented research – studies on issues related to quality of Indian exports • Maintain information database on regulatory requirements of trading partners • Issue of Certificates of Origin under various preferential tariff schemes for duty concessions for exporters by foreign customs EXPORT INSPECTION AGENCY - DELHI

  7. INTERNATIONAL RECOGNITIONS • EC - CA for marine products and issuance of authenticity certificate for basmati rice; egg products, dialogue on for dairy products, poultry meat & honey • Italy- MOU for marine products. • USA (USFDA) - recognized for Black Pepper; initiated dialogue for others. • Australia (AQIS) - recognized for marine products –seeking for dairy products, spices etc. • Sri Lanka (SLSI) - recognized for 85 products regulated by Sri Lanka (food, cement, engineering items, electrical appliances, milk products etc. • Singapore – The MRA’s covers Food & Agriculture. • Korea- Recognized for certifying food products • Japan- Recognized for certifying F& FP, Poultry products • Russia – Recognized for Marine Products Others - Other EU countries, Canada, Argentina etc- under negotiation EXPORT INSPECTION AGENCY - DELHI

  8. Our website (www.eicindia.org) EXPORT INSPECTION AGENCY - DELHI

  9. SPS/TBT EXPORT INSPECTION AGENCY - DELHI

  10. Residue Monitoring System • Residues • Substances having pharmacological action (both prohibited and permitted substances) (SUBSTANCES HAVING ANABOLIC EFFECT AND UNAUTHORISED SUBSTANCES, VETERINARY DRUGS (1) AND CONTAMINANTS) • Metabolites of substances • Substances transmitted to animal products (Heavy metals, pesticides, toxins, PCBs, dioxins, etc.) • Substances formed by biological action (bacterial toxins, aflatoxins, etc.) EXPORT INSPECTION AGENCY - DELHI

  11. Residue Monitoring System Preventing prohibited substances getting into the food chain, which are harmful or likely to be harmful to human health. Monitoring of substances which are harmful or likely to be harmful to human health to ensure that the level is within the prescribed limit (based on scientifically established risk analysis) in the particular food. EXPORT INSPECTION AGENCY - DELHI

  12. Basis of Residue Monitoring • GoI Notifications on products of animal origin: EXPORT INSPECTION AGENCY - DELHI

  13. Systems of Residue Control NRCP :EIC is implementing through MPEDA in aquaculture products RMP : EIC’s Annual Residue Monitoring Plans (RMP). Implemented by EIC in Egg Products, Milk Products, poultry meat products and honey EXPORT INSPECTION AGENCY - DELHI

  14. Why NRCP and RMP? • WTO Agreement: • SPS Agreement: Compliance of Sanitary and Phyto-Sanitary requirements of importing country- setting up country specific standards based on risk assessment & scientific evidences, Harmonization, Transparency, Mutual recognition • TBT Agreement: No importing country should impose Technical Barrier to Trade. Global food trade is Food Safety (The food free from health hazards). Consumer is entitled for safe, sound and wholesome food free from any physical, chemical and microbiological hazards • Requirement of Harmonization SPS and TBT agreements require National Standards to Harmonize with International ones EXPORT INSPECTION AGENCY - DELHI

  15. NRCP and RMP • Objective: • Monitoring and insurance of the acceptable residue levels of drugs, pesticides and contaminants in the food products. • Detection of any illegal treatment (s) • Establishing a system of corrective action in the event of detection of residues higher that the prescribed limits by issuing alert information and follow up visits • To ensure that the food products exported from India meet the prescribed regulatory requirements of the importing countries. • Scope: • Animals or animal origin products and processing meant for export by the approved processing establishments having implemented HACCP based own check system. EXPORT INSPECTION AGENCY - DELHI

  16. NRCP/RMP for EU • To fulfill the requirements of EU • EC is responsible to ensure high level of human health protection through its Food & Feed regulations. • EU food safety policy as 178/2002/EC for food and feed with integrated "farm to fork" approach, aims to harmonise existing national requirements in order to ensure the free movement of food and feed in the EU. • For import from third countries, - EC seeks guarantees equivalent to EC requirements on residues of veterinary drugs, pesticides and contaminants EXPORT INSPECTION AGENCY - DELHI

  17. Basis of animal origin products • Council Directive 96/23/EC dated 29.04.1996, stipulated in the Council Directive 96/22/EC as amended by Council Directive 2003/74/EC – requirements in relation to the planning and execution of national residue control plans (NRCP) for live animals and products of animal origin (third countries) • Commission Regulation (EC) No. 136/2004 – authorizes CAs of member states of EU to test samples for residues at BIPs (Border Inspection Posts) • Directive 97/78/EC - EU or the individual member state may reinforce checks at the point of import on identification of residue problem EXPORT INSPECTION AGENCY - DELHI

  18. NRCP/RMP for EU • Council Directive 86/363/EEC and Commission Regulation (EC) 1881/2006 - Maximum Residue Levels (MRLs) for a wide range of pesticides and maximum levels (MLs) for certain environmental contaminants, respectively. • Annual submission – RMP for each food commodity from third countries to EC, (plans + previous year results by the 31st March every year) • Approval of Plan by EC- listed in the Commission Decision 2004/432/EC, (updated). • According to the last update India is eligible for export the products of aquaculture, eggs to EU. EXPORT INSPECTION AGENCY - DELHI

  19. Basis for plant products In the EU, as from 1 September 2008, a new legislative framework (Regulation (EC) No 396/2005 on pesticide residues is applicable, Covering approx. 1100 pesticides currently or formerly used in agriculture in or outside the EU. It lists MRLs for 315 agricultural products. These MRLs also apply to processed products, adjusted to take account of dilution or concentration during processing. To access the database, http://ec.europa.eu/sanco_pesticides/public/index.cfm EFSA - responsible for the safety assessment. EXPORT INSPECTION AGENCY - DELHI

  20. Benefits of RMP implementation Food products of animal origin • Supplier / farmer - food safety measures - safe food products • Establishment - controls / monitoring over farmer / supplier at primary production, storage and transportation levels. • All the stakeholders in the food chain - safe food products for human consumption • FP meant for export - free from prohibited substances. • Permitted level of Veterinary drugs / pharmacologically active substances, Pesticide residues, Heavy metals, etc. would be monitored. • Increase in Demand of safe food products – Increase in Export earning • Farmers - benefited from safe production - employment and earnings EXPORT INSPECTION AGENCY - DELHI

  21. NRCP – Salient features Implemented by MPEDA • EIC - CCA • Sampling from aquaculture farms and testing, as per schedule - by MPEDA • Test results compiled and submitted to EIC. • In case of failure of sample, if any, EIA concerned will initiate appropriate action to find root cause and prevent recurrence. Also, furnishes action taken report to EIC EXPORT INSPECTION AGENCY - DELHI

  22. RMP – Salient features Implemented by EIC - EIC – CCA, EIA- RCA Responsibilities of processors- • To ensure that the registered feed mills supplying feed to the producers / farmers and farms / producers supplying animal products) – records – EIA M.O Sampling Procedure: • Multiple sampling of same matrix from same source - avoided • The Representative samples - traceable to source of farm / producer • Samples - collected and secured in clean and inert containers & labelled • Samples should be sent to designated EIA lab/ EIC approved lab under controlled conditions. EXPORT INSPECTION AGENCY - DELHI

  23. RMP – Salient features Analysis and handling of samples: • The sample - secured storage at appropriate storage condition. • Analysis - as per the protocol given in the RMP by EIC. • Remaining samples - stored securely at appropriate condition. • Initial test - positive, the remaining sample shall be analysed for confirmation of results. • The test results shall be reported in the prescribed format • In case of failure, the results communicated immediately to the EIA concerned EXPORT INSPECTION AGENCY - DELHI

  24. RMP – Salient features Corrective Action in case of failure of samples: Processor to be kept on ‘ On-Alert’ and advisory issued to exporters, for; • Identification of the exact source • Stop procurement of raw material from the source. • Refrain from exporting the products processed from the identified source • Find the root cause for the failure of the samples from the identified source • Take corrective actions to prevent recurrence • Review the HACCP and revise if necessary • Conduct regular training for farmers / producers / suppliers to prevent recurrence EXPORT INSPECTION AGENCY - DELHI

  25. RMP – Salient features Corrective Action in case of failure of samples: (Contd.) • Assessment by the EIA official to find out the source and root cause of the contamination including backward linkages and assists in identifying preventative measure to stop the recurrence • The live stock concerned and the product is kept under official control • The source producer/farm is subjected to more checks EXPORT INSPECTION AGENCY - DELHI

  26. RMP – Salient features • Provision for re-testing of positive samples • Re-testing of the positive samples - on request from the unit ( re-confirmation). • The control sample - tested in two different EIA labs/ EIC approved labs other than one tested earlier. • The result to be treated as positive even if one of the two samples is found to be positive on re-testing. • In case both the samples pass the MRL requirement on re-testing, the concerned EIA shall withdraw internal alert , which shall take effect from that date. • Recording and reporting: • All records relevant to planning, sampling and testing to be maintained at EIAs. • monthly / quarterly summary in the prescribed format to be submitted by the Sub-office to the EIA concerned, in the end to EIC EXPORT INSPECTION AGENCY - DELHI

  27. Issuance of Health Certificates • What is HC? – A document for a consignment of food product certifying that: • the consignment has been processed under proper sanitary and hygienic conditions, and that • the food product is safe for human consumption. issued by a competent authority, acceptable to the health authority of the importing country. EXPORT INSPECTION AGENCY - DELHI

  28. Health Certificates • Who demands? – Importing countries insist on Health / Veterinary / Sanitary/ Phyto-sanitary . • Why ? - provides confidence to the health authorities of the importing country EXPORT INSPECTION AGENCY - DELHI

  29. Health Certificates • Issuing authority?: Competent authority specified by the importing country. • Export Inspection Council of India – CA for F&FP meant for export to EU, countries other than EU. • EIA issues HC on behalf of EIC using the official rubber stamp (seal) of EIC • Some countries accept HC issued by official veterinary authorities. • If an EU approved establishment obtains HC from any • body other than EIC/EIA, its approval is liable to be withdrawn EXPORT INSPECTION AGENCY - DELHI

  30. Requisites to issue HC On request from approved processor/exporter On the basis of controls carried out, - on or before the date of shipment HC not issued after the date of shipment (indicated in the Bill of Lading) Note: HC is issued only for F&FP processed in establishments/factory vessels/freezer vessels approved by EIC/EIA, likewise milk products, egg products, honey etc. EXPORT INSPECTION AGENCY - DELHI

  31. Requisites to issue HC HC for consignments of F&FP meant for non-EU countries to be issued by the EIA concerned in the prescribed format given at Annexure XXII(A) of EI If any country has prescribed format of HC, the specific format will be used as required by the importing country. For e.g. Australia EXPORT INSPECTION AGENCY - DELHI

  32. Formats of HC • COMMISSION REGULATION (EC) No 1664/2006 – for HONEY AND OTHER APICULTURE PRODUCTS • COMMISSION REGULATION (EC) No 1250/2008 – • FISHERY PRODUCTS INTENDED FOR HUMAN • CONSUMPTION • COMMISSION REGULATION (EU) No 364/2011- for egg products (EP) HC is prepared in triplicate: Original (White) for importer; Duplicate (Pink) for HO; Triplicate (Blue) for office record EXPORT INSPECTION AGENCY - DELHI

  33. Formats of HC • Multilingual HC format is used for EU EXPORT INSPECTION AGENCY - DELHI

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  38. Certificate of Analysis for Aquaculture Shrimps meant for export to Japan If processor/exporter approaches EIA - consignments of Aquaculture Shrimps meant for export to Japan for the samples shall be drawn by an authorized EIA officer and the same shall be tested for Antibiotic Residues including Nitrofuran Metabolites, in EIA lab under its jurisdiction. The cost of testing to be borne by the processor. Format of Certificate of Analysis to be issued is given at Annexure XXVIII of Ex. Instructions. EXPORT INSPECTION AGENCY - DELHI

  39. Best Agriculture Practices in export Reforming agriculture and making the produce internationally competitive in quality & food safety. Green revolution – uncontrolled usage of chemical fertilizers, irrigation water & pest control products – adverse environment impact, degradation & increased salinity in soil, deforestation and depletion of water resources. EXPORT INSPECTION AGENCY - DELHI

  40. GAP- role in export Structured methodology, innovative technology without its adverse impact on environment, health & safety of people. GAP – collection of principles – on farm production, post production processes – - integrated pest management - integrated fertilizer management & - conservation agriculture EXPORT INSPECTION AGENCY - DELHI

  41. Basic elements of GAP Farm selection & Farm management Rational use & application of pesticides Judicious use of fertilizers Soil conservation & soil management Irrigation & water conservation Integrated pest management Produce storage & handling Pre – harvest application of pesticides Harvesting practices EXPORT INSPECTION AGENCY - DELHI

  42. Basic elements of GAP Contd…. Post harvest treatment Workers health, safety & welfare Traceability – from farm to fork/back tracking from fork to farm, batch/lot recall Protection of environment EXPORT INSPECTION AGENCY - DELHI

  43. Standardization of good agricultural Practices GlobalGAP - key reference for GAP in global market place- GLOBALGAP Secretariat GlobalGAP standards cover entire range of agriculture including animal husbandry & fisheries – (next slide) Consists of set of normative documents covering GLOBALGAP general regulations, the GLOBALGAP control points & Compliance criteria and the GLOBALGAP checklist. EXPORT INSPECTION AGENCY - DELHI

  44. GLOBALGAP STANDARD STRUCTURE EXPORT INSPECTION AGENCY - DELHI

  45. Harmonization with GLOBALGAP • Variations In Agriculture Practices – Country/Region Wise • Agro climatic variations, Cultural practices, regulatory framework • Two routes:- • Introducing national requirements in GLOBALGAP Standards and getting its approval by Global GAP secretariat through National Technical working Group • Benchmarking national standards such as IndiaGAP, MalaysiaGAP, KenyaGAP etc.- address essential elements good agriculture practices covered under GlobalGAP EXPORT INSPECTION AGENCY - DELHI

  46. Harmonization with GLOBALGAP • In India, both the streams of standards – under the aegis of NTWG set up by QCI and another FSSAI with assistance from QCI • India GAP standards prepared - GAP-Basic requirements, fresh fruits & vegetables, combinable crops, green coffee, & tea EXPORT INSPECTION AGENCY - DELHI

  47. Certification of Good Agricultural Practices • More than 100 independent and accredited certification bodies in more than 80 countries. • Open to all producers worldwide • FSSAI led IndiaGAP cover: • Certification Criteria • Certification Process • Certification body requirements ‘Draft available at QCI website’ EXPORT INSPECTION AGENCY - DELHI

  48. Certification of Good Agricultural Practices • NABCB (National Accreditation Board for Certification Bodies) of QCI – • Accreditation of certification bodies based on ISO Guide 65 along with relevant scheme – GlobalGAP or IndiaGAP • Two options: • Individual certification: Multisite without implementation of QMS, Multisite with implementation of QMS, Basic progressive model • Group certification EXPORT INSPECTION AGENCY - DELHI

  49. Certification of Good Agricultural Practices • Ensure conformity to standards on IndiaGAP standards • IndiaGAP-Standard intending for Bench marking with GlobalGAP • IndiaGAP – basic requirements (progressive in nature) • Evaluation against control points and compliance criteria (CPCC) • Compliance to relevant statutory and regulatory requirement applicable in area of operation • Before certification process applicant shall:- • Selection of farms for GAP certification • Assigning identification number to the different units of the farm • Establish legal identity & registration • Selection of certification model depending upon nature of operation • Training on IndiaGAP to farmers EXPORT INSPECTION AGENCY - DELHI

  50. Certification of Good Agricultural Practices • Establishing documented system to meet the requirements & its implementation • Training of inspectors/auditors • Conducting internal evaluation and appraisal of the system by trained farm inspectors • Taking corrective action and improving the situation • Appointment of certification body • Documents for introducing IndiaGAP certification: • IGAP-01 – certification criteria (voluntary) • IGAP-02 – Certification process (voluntary) • IGAP-03- group certification (voluntary) • IGAP -04 – basic module (voluntary) • IGAP -05 – certification body requirements (voluntary) EXPORT INSPECTION AGENCY - DELHI

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