Metastudy on food testing laboratories in india

METASTUDY ON FOOD TESTING LABORATORIES IN INDIA

FOOD AND AGRIBUSINESS STARTEGIC ADVISORY & RESEARCH (FASAR) YES BANK LIMITED

NEW DELHI

FEBRUARY 18, 2019

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Contents Executive Summary ................................................................................................................................... 3

1 Overview of Food Testing Laboratory Infrastructure in India .................................................... 7

2 Mapping of Testing Infrastructure against Production and Processing .................................. 14

3 Assessment of Demand and Supply of Food Testing Laboratories in India ........................... 19

4 Primary Survey – Key Findings ..................................................................................................... 24

5 Challenges and Recommendations ............................................................................................... 37

6 Initiatives by FSSAI .......................................................................................................................... 44

7 Proposed Ranking Matrix for Food Labs ...................................................................................... 57

Annexures ................................................................................................................................................. 62

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Executive Summary In a country like India, food safety appropriately remains a high priority for industry

stakeholders, regulatory agencies as well as the consumers. Food safety issues and the

enhancement of health security are of growing national and international concern. The Indian

food consumption basket has diversified from cereals towards higher value and more

perishable products, such as fruits and vegetables, dairy, meat and fish. Food testing and

analysis are the essential pillars of food safety ecosystem that assure wholesomeness and safety

of the food. As the country’s food safety regulator, FSSAI is also mandated to recognize and

notify laboratories through a well-defined regulation in order to improve and streamline the

food testing activity. This Meta Study on food testing laboratories in India was envisaged with

the intention of having a holistic overview of the food testing ecosystem in the country. It is of

critical importance to have an understanding of the existing infrastructure available for food

testing in the country in terms of capacity, provision of equipment, technical manpower,

geographical spread and testing capabilities. Hence, a judicious mix of secondary and primary

analysis was utilized to cater to assessment of these parameters. During the entire exercise,

feedback from all critical stakeholders in the food testing ecosystem such as APEDA, MPEDA,

EIC, NABL amongst others was considered and incorporated to derive key recommendations

and chart a way forward to strengthen the food testing infrastructure in the country.

Under the purview of this study, as a starting point, food testing labs in India have been

categorized based on their registrations (FSSAI notified, FBO owned labs, referral labs,

institutional labs and non FSSAI labs), geographical spread zone wise (North, East, West and

South) as well as their varying testing capabilities (Biological/Chemical/Residue Testing)

amongst others. It was found that around ~915 food and water testing labs exist at present in

India which includes NABL accredited labs, FSSAI notified Labs, States labs, Institutional labs,

Referral labs etc. Under the FSSAI network, ~265 labs are operational while 35 nos. are EIC

approved, 40 nos. are APEDA recognized while 72 nos. had received assistance from MoFPI.

Geographically, the North, East, West and South zones of the country covered 30%, 10%, 27%

and 34% respectively of all food testing labs in the country. In terms of testing abilities, a large

number of labs can carry out the biological, chemical or both tests for the food and agri

products (which covers a host of food items), while only a few of them (only 32%) can test for

pesticide residues in food products. Furthermore, a limited number of labs were found which

can test for specialized products like marine (16%), nutraceuticals (4%) and GM products (2%).

It is critical to understand the existing availability of food testing infrastructure against the

number of food processing units and production quantum in major producing states. Hence, an

attempt was made to calculate the same across included key categories such as Cereals, Edible

oil, Fruits & Vegetables, Milk, Meat, Fisheries and Sugar which together form more than 80% of

the total food production basket of India. When it came to cereals, it is observed that in a few

states like Andhra Pradesh, Telangana, Punjab, Odisha and Chhattisgarh, the number of FBOs

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being catered to by one food testing laboratory is very high. There is a need to increase the

capabilities of existing laboratories within the states to cater to the requirements of this sector.

In the F&V sector, the number of food processing units catered to by the food testing

laboratories, most of the major states were found to have sufficient infrastructure for testing of

F&V products. However, in a few states like Punjab, Andhra Pradesh and Uttarakhand the

FBOs per laboratory are found to be higher in number. Hence, enhancement of existing labs in

Punjab and setting up of newer facilities in Uttarakhand is required. In the dairy sector, it was

observed that in few states like Madhya Pradesh, Rajasthan and Uttar Pradesh, the FBOs being

catered to by one laboratory is on much higher side. Though, these states have good number of

NABL accredited laboratories available, the requirement is to increase the scope of such

laboratories within the states. When it came to meat sector, while most states have sufficient

infrastructure for testing of meat, Madhya Pradesh was found to be an exception with 850 FBOs

to be catered to per lab. In the case of Aqua/Marine sector, all major maritime states were found

to have adequate food testing infrastructure with an exception of the state of Goa. Hence,

attempts to improve food testing infrastructure availability in Goa should be focussed upon.

For Oils & Fats, while most states have sufficient infrastructure for testing, in a few states like

Uttar Pradesh and Tamil Nadu the FBOs per laboratory is comparatively higher. There is a

need to increase the capabilities of existing laboratories within the state to cater to the

requirements of this sector. In case of sugar sector, all major sugar producing states were found

to have adequate food testing infrastructure.

As all of the FBOs are mandated to undergo compliance based testing periodically, an

assessment of the demand generated through these existing FBOs for food testing and the

requirement for infrastructure in the four regions of the country was carried out. At 100%

compliance by FBOs towards food testing the deficit in laboratories is estimated at 284 labs,

with the maximum requirement in South (124 labs), followed by the East (70 nos.), West (58

nos.) and North (31 nos.). At 100% compliance by FBOs and the HORECA segment towards

food testing, the deficit in laboratories is estimated at more than 700 labs, with the maximum

requirement in South (312 nos.), followed by the West (210 nos.), East (130 nos.) and North (91

nos.)

In addition to the secondary data assessment, a robust primary survey was also undertaken

across the country covering various categories of food testing labs, government and private

sector stakeholders, as well as food safety experts. Based on the feedback collected and

subsequent analysis, it was derived that around 78% of the labs were found have NABL

accreditation while 57% were FSSAI notified. Other major accreditations held by the surveyed

labs included BIS, AGMARK, MoEF and AYUSH. A general consensus pertaining to multiple

accreditations was that; it is a resource, cost and time consuming adherence. In terms of in-

house ability for testing, most of the surveyed labs had a chemical based testing set up.

Microbiological and pesticide residue testing was found to be a comparatively more capital

intensive service, hence, lesser quantity of labs possessed the same. Presence of chemical testing

was found the highest in FSSAI notified private labs while referral and FBO labs saw maximum

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presence of biological testing. Procurement and maintenance of high end testing equipment was

also found to be a major challenge faced by small and medium private sector labs owing to lack

of samples and minimal capacity utilization. In terms of manpower capability, scouting, hiring,

training and monitoring of qualified personnel is a major cost head for private sector labs. In

terms of Turnaround time (TAT) and capacity utilization, the average TAT for state,

institutional and referral labs ranged between 8 to 14 days. The TAT varies owing to the

number of parameters to be tested during a specific time frame. In private labs, both FSSAI and

non FSSAI labs, the average TAT ranged between 3-4 days for chemical based testing while it

stretched to 7-10 days if microbiological parameters are also involved.

Based on the secondary and primary research, major identified challenges and their probable

recommendations were derived. The major challenges highlighted have been in the domains of

equipment & machinery, manpower availability, skill development, regulatory, R&D, capacity

utilization as well as consumer awareness. In order to address these challenges, specific

recommendations were also drafted which are summarized below:

Stricter implementation of food testing regulations: In order to boost capacity utilization &

ensure better compliance, it is essential to enforce ground level monitoring & inspection by

Food Safety Officers. Monitoring of FBOs and their database update is essential. Timely

surveys for identification of FBOs is also required. This may be implemented through

outsourcing to a credible 3rd party in coordination with the state food authorities. Outlook

towards GMO and finalization of “Guidelines for safety assessment of food derived by GM

technology” should also be taken up at the earliest.

Training & Capacity Building: Dedicated training programs for all stakeholders in the food

testing value chain and sensitization of FBOs towards compliance & inspections is required.

For DOs and FSOs, a specialized training programme for food inspections to ensure timely

inspection and help in identification of the FBOs engaged in the manufacturing of

adulterated or unsafe products should be rolled out

Lab-Industry-Regulator Forum: During the primary survey, it came to light that the FBO and

food testing fraternity have multiple issues and recommendations to discuss with FSSAI,

which, however, they are unable to do due to limited means of communication. This will

also be an opportunity for the laboratories to interact directly with the FBOs and understand

their requirements and challenges. Formation of a laboratory association which works

closely with the industry as well the regulator can also be explored

MoFPI to provide grant only to NABL/FSSAI Recognized Laboratories: MoFPI currently provides

assistance for establishing a food testing lab by agencies/private sector organizations/

universities including deemed universities. MoFPI should evaluate providing this assistance

compulsorily to NABL recognized laboratories and also preferably to FSSAI recognized/

referral laboratories, so that the equipment add to the existing capacity of food testing

laboratories which are available to the food processing industry.

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Single Window System: There exist multiple accreditations and recognitions for food testing

laboratories in India viz. NABL, FSSAI, EIC, BIS etc. These multiple accreditations and

recognitions create unwanted duplication of work and are high on investment in terms of

cost, time & human capital. These accreditations and recognitions should be brought under

a single platform to avoid duplication of work and save on resources. Initiatives has already

been taken on this front by EIC. FSSAI should join this common platform for notifications of

its labs.

Linking FBOs to INFOLNET: INFOLNET envisages to bring together all stakeholders to a

common platform for the establishment of a transparent food testing network. Currently the

FBOs are not a part of this system and the sample being received by the food testing lab has

to be registered in the system by the lab itself. Streamlining of processes (data entry) and

sensitization of FBOs with regards to INFOLNET is suggested.

Consumer Awareness: In order to improve overall awareness levels, it is recommended to

launch a national level awareness programme in partnership with all stakeholders including

the Central and State Agencies, Street vendors, universities and colleges, NGOs, small and

big food industry players should be rolled out. A nationwide campaign on Good

Agricultural Practices across all food sectors and training and awareness program about the

Act and best agricultural practices for the primary producers should be undertaken as well.

Delegation of Power to State Laboratories for Procurement: Since, food safety implementation

and monitoring rests at the state level, a State Level Advisory Committee should be

constituted with the Food Safety Commissioner as Chairperson and all the stakeholders as

its members. The Director of the State Food Testing Lab, officers of the Food Authority and

representatives from the industry associations should also be included as its members. As a

result of this system, at state and district level, better handling of licensing regulations and

facilitation of integration of local bodies with the food safety administration would be

possible

Manpower Availability & Optimization: An action plan in coordination with State/UT

Governments should be drawn for overcoming the shortage of manpower of Food

Regulatory Bodies. As a short-term measure, professionally qualified persons should be

engaged on short-term contract till adequate manpower is made available. Each State/UT

should frame its recruitment regulations according to its size and population and regular

exams should be conducted to recruit qualified & trained personnel. A minimum number of

technical staff required for proper functioning of food testing laboratory should be

earmarked.

In line with the recommendations proposed, FSSAI has already been involved in a number of

initiatives to give an impetus to the food testing infrastructure in the country. These range from

probable PPP models for lab infrastructure development, onboarding all food labs on

INFOLNET seamlessly, deployment of training programs, National Milk Quality Survey and

mobile food labs as well as development of an International Training Centre For Food Safety

And Applied Nutrition (ITC-FSAN) amongst other initiatives. A competitive ecosystem in the

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food testing sector is essential to get the best out of existing food labs & boost compliance by

FBOs. In order to motivate the good and earnest labs to keep up the worthy practices followed

in food testing and also to encourage the lesser competent labs to strive towards better business

practices, a detailed ranking matrix is proposed. This ranking matrix, will also help in

generating more business through the FBOs for the more competent and proficient labs.

1 Overview of Food Testing Laboratory Infrastructure in India

1.1 Introduction Food Safety appropriately remains a high priority for industry stakeholders, regulatory

agencies as well as the consumers. Efforts are being put in at each level to reduce the risks

related to food and with the emergence of new safety challenges and complexities stakeholders

are trying to establish and upgrade mechanisms to comply with the requisite norms. Given the

scenario, importance of Food testing laboratories in the Indian food ecosystem cannot be

undermined. Food testing laboratories ensure an effective food safety mechanism in the

country. The scientific analysis in the food testing laboratories determines whether the food

tested is fit for human consumption and devoid of any form of adulteration / contamination.

In India, National Accreditation Board for Testing and Calibration Laboratories (NABL), a

Constituent Board of Quality Council of India is the nodal agency for the accreditation of food

testing laboratories. NABL has been established with the objective to provide Government,

Industry Associations and Industry in general with a scheme for third party assessment of the

quality and technical competence of testing and calibration laboratories.

On the other hand, FSSAI is the nodal agency governing the food safety scenario in India. As

the country’s food regulator, FSSAI is also mandated to recognize and notify laboratories

through a well-defined regulation in order to improve and streamline the food testing activity.

The authority thus has formulated regulations for recognition and notification of laboratories to

improve and streamline the process of notification of food laboratories. This regulation not only

provides a legal foundation for the operation of the laboratory system that already exists under

the ambit of FSS Act 2006, but also ushers transparency by defining the procedural

requirements for the recognition and notification of food testing laboratories. In addition,

through a policy and provision in the regulation, the authority has also enabled recognition and

notification of food testing laboratories that are situated abroad provided they are accredited by

the Indian accreditation board or accreditation board of their own country. The authority has

recently received applications from food testing laboratories situated in the neighboring

countries like Srilanka and Bangladesh for their recognition and notification as FSSAI notified

laboratories. The FSSAI Act provides for the establishment of food testing laboratories for

analysis of food samples. As per Sec 43 (1) of FSS Act, the Food Authority may notify food

laboratories and research institutions accredited by National Accreditation Board for Testing

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and Calibration Laboratories (NABL) or any other accreditation agency for the purpose of

carrying out analysis of samples of Food analysts under this Act.

FOOD SAFETY AND STANDARDS ACT, 2006 No. 34 OF 2006 [23rd August, 2006]

“An Act to consolidate the laws relating to food and to establish the Food Safety and Standards Authority

of India 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 for human

consumption and for matters connected therewith or incidental thereto.”

As on September 2018, FSSAI has notified a total of 172 laboratories for the purpose of carrying

out analysis of food samples taken under the Food Safety and Standards Act 2006 and rules and

regulations made thereunder. Besides these, there are around 19 referral laboratories notified by

FSSAI (2 overlaps with FSSAI notified laboratories) as well as 88 state food testing laboratories

as a part of its network (12 common laboratories under notified laboratories as well as state

laboratories). This brings the total number of laboratories in the FSSAI network to 265. The

segment -wise composition of all the laboratories recognized and notified by FSSAI are as

below:

1.2 Overview of Food Testing Laboratories in India The Meta Study on Food Testing Laboratories in India estimates a total of around 600 food

testing laboratories in India. These laboratories include all NABL accredited laboratories (for

food products- including those owned by private sector, institutions, FBOs, state/central

government), FSSAI notified laboratories, State laboratories, laboratories assisted by MoFPI for

upgradation and few other institutional and private sector laboratories. Many of these food

testing labs can also test for water (drinking water, packaged drinking water and water used for

food processing). Additionally there are around 300 laboratories (NABL accredited) who can

test water, packaged drinking water and/or water used for food processing, taking the total

number of food and water testing labs to more than 900 laboratories.

172

FSSAI Notified Laboratories

19

Referral Laboratories

88

State Laboratories

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Other than these labs, there is another pool of food testing laboratories which exist within the

ecosystem which largely includes small players operating in the food testing space and a larger

pool of food testing labs which exist with the Food Business Operators to carry out their

regular/routine tests for raw material as well as finished goods. However the number of such

laboratories existing in the ecosystem is difficult to determine. In total, these small laboratories

along with the labs existing with FBOs are likely to exceed 1,000-1,500 in number, taking the

total number of food testing laboratories in India to more than 2,000 laboratories. A brief

snapshot of food and water testing laboratories scenario is provided below.

Exhibit 1: Snapshot of food and water testing laboratories in India

Total Food and Water Testing Labs in India ~ 915 Labs

Includes NABL accredited labs, FSSAI notified Labs, States labs, institutional labs, referral labs etc. Excludes in house FBO labs which are non NABL accredited and other labs (non NABL, non FSSAI, non EIC,APEDA recognized)

NABL accreditation ~ 775 labs Includes labs for food and water testing

Total Food Testing Labs in India • ~600 Labs Total Food Testing Labs in India - NABL Accredited

• ~462 Labs

BIS Recognized Labs ~ 229 labs Includes packaged drinking water, packaged mineral water in addition to other food based and non-food based product categories as per Group I List, may include labs with NABL accreditation as well

FSSAI Network ~ 265 Labs • 172 FSSAI notified • 88 State Labs • 19 referral Labs

• 172 FSSAI notified • 19 referral Labs • 88 State Labs • 171 NABL accredited

EIC Approved labs: 35 • 35 NABL Recognized • 30 FSSAI Notified/ Referral

APEDA Recognized Labs: 40 • 40 NABL Recognized • 37 FSSAI Notified/ Referral

MoFPI Assisted: 72 • 51 NABL Recognized • 41 FSSAI Notified/ Referral

Source: NABL, EIA, MoFPI, APEDA, FSSAI

Exhibit 2: FSSAI’s Lab Network

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Exhibit 3: Snapshot of Accreditations and Notifications in Food testing Labs in India

Source: NABL, EIA, MoFPI, APEDA, FSSAI

1.3 NABL Accredited Laboratories

265

1

1

11

17

76

159

Notified Labs

Referral Labs

State Labs

9

FSSAI/ Referral*

APEDA Recognized

EIC Recognized

MoFPI Assisted

37

11 18

41

11 18

16

9

Exhibit 4: Institutional Breakup of NABL Accredited Labs

11

63% 14%

11%

9% 3%

NABL Labs: Institutional Breakup

Private Labs

Institutional Labs

Labs owned by FBOs

Government Labs

State Labs

38%

52%

10%

In house Open to Others Partially open to others

There are around 462 NABL

accredited laboratories for food and

food products in India (As of Sept 1,

2018 NABL data). This universe

consists of laboratories across all

states in India, which are open to

testing for others, partially open to

others or are in house laboratories.

These food testing laboratories are

either owned by the private sector

(majorly as a food testing business

entity), Institutions (open for others

for testing or internal testing and R&D), Government agencies – carrying out third party testing

and/or in house tests and R&D), State Laboratories (under the FSSAI network of laboratories-

carrying out tests for legal samples and others) as well as laboratories owned and operated by

FBOs (carrying out food testing/ R&D for in house operations and/or for others as well). Of all

the above stated categories, the maximum laboratories fall under the private sector category

followed by institutional laboratories and Laboratories owned by FBOs. The universe of Food

Testing Laboratories is much larger than those accredited by NABL. Besides the NABL

accredited Laboratories there are additionally around 132 laboratories which are not accredited

by NABL, but are operational in the field of Food Testing. Some of these laboratories are

APEDA/ EIC approved for testing of export products, while some have received assistance

from MoFPI for their upgradation.

1.4 Laboratories owned by FBOs The Food Business Operators form a very significant part of the overall food testing ecosystem.

Being the end consumers of the services, they are the ones driving the demand for food testing

and allied services. Within the food processing industry as well there are estimates on the sizing

and types of FBOs governing the industry. It is estimated that large corporates form 20% of the

industry, while the MSME segment contributes the remaining 80%.

Interestingly few of these large corporates

have established their own laboratories,

some of which are state of the art and

Total Food Processing Industry

Large Corporates 20%

MSME 80%

Source: NABL, YBL Analysis

Exhibit 5: NABL Accredited Testing Facilities by FBOs

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NABL accredited. There are around 50 NABL accredited laboratories owned and operated by

various Food business operators. Of these, 52% laboratories are open to others for testing, 38%

cater only to in-house requirements while 10% are partially open to others for testing. Some of

the key companies who own the NABL accredited laboratories include ITC, Nestle India Ltd.,

Tilda Hain, Britannia, Markfed, Patanjali

Food & Herbal Park, Mother Dairy,

Karnataka Co-operative Milk Producers Federation Limited, LT Foods, Synthite Industries,

Dabur, Marico, Akay Flavours & Aromatics Pvt. Ltd, Coca-Cola, Eastern Condiments, Jain

Irrigation Systems Limited, Parry Agro amongst others. Many of these corporates own more

than 1 such laboratories. Majority of the labs owned by FBO can test for food and agri products,

while a few specialized labs can also test for marine products and pesticide residues. Besides

these NABL accredited laboratories, there are numerous other small laboratories which exist

within the processing plants of the FBOs for their day to day testing of raw materials and final

products. The number of such laboratories existing in the ecosystem is difficult to determine, as

there is no central repository or database that capture such laboratory details.

1.5 Regional Distribution of Food Testing Laboratories The food testing laboratories in India are well represented regionally with a comparatively

higher concentration in southern India, followed by Northern, Western and Eastern part of the

country.

The states considered under the respective zones include:

North: Jammu & Kashmir, Himachal Pradesh, Uttarakhand, Uttar Pradesh, Punjab,

Haryana, Delhi, Rajasthan

East: All NER States including Sikkim, West Bengal, Odisha, Jharkhand, Chhattisgarh,

Andaman & Nicobar Islands

West: Maharashtra, Gujarat, Madhya Pradesh, Goa, Daman & Diu

South: Karnataka, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, Pondicherry

The Food testing laboratories in India are mainly established at business centers or larger cities,

due to business traction at these hubs and centers. NABL and FSSAI laboratories are distributed

in almost the same proportions in the 4 regions. Laboratories which have been recognized by

EIC and/or APEDA are largely concentrated in the southern and western region of the country,

given the export oriented business concentration in the two regions. Exhibit 6: Regional Distribution of all Food Testing Labs in India

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Source: NABL, EIA, MoFPI, APEDA, FSSAI, YBL Analysis

Exhibit 7: Regional Distribution of NABL accredited and FSSAI notified laboratories

Source: NABL, FSSAI, YBL Analysis

In the Southern region of the country, the laboratories are well spread across the states of Tamil

Nadu, Kerala and Karnataka (~78%). Within these states, the laboratories are largely

concentrated in the cities of Bengaluru, Chennai, Kochi, Hyderabad and Ernakulum.

Exhibit 8: State-wise Distributions of Food Testing Labs in Southern Region

South 36%

North 28%

West 29%

East 7%

Regional distribution of NABL food testing labs

South 37%

North 30%

West 28%

East 5%

Regional distribution of FSSAI food testing labs

REGIONAL DISTRIBUTION OF ALL FOOD TESTING LABS~600 Labs

North 30%

West 27% East 10%

South 34%

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In the Northern region of the country, the laboratories are well spread across various states with

maximum concentration existing (79%) in the states/UTs of Delhi, Uttar Pradesh, Haryana, and

Rajasthan. Other laboratories are present in Punjab and the hill states of Himachal Pradesh,

Jammu & Kashmir and Uttarakhand. The region witnesses concentration of laboratories in the

key cities of Delhi, Ghaziabad, Noida, Gurugram, Panchkula/Chandigarh and Jaipur. The

distribution of laboratories across cities spans to around 50 cities - much higher than other

regions of the country.

Exhibit 9: State-wise Distributions of Food Testing Labs in Northern Region


Unlike other regions, the concentration of laboratories in the Western Region is largely

concentrated in Maharashtra and Gujarat (85%) followed by Madhya Pradesh. The

concentration of laboratories is seen in the key cities of Mumbai, Pune, Ahmedabad and Indore.

Exhibit 10: State-wise Distributions of Food Testing Labs in Western Region

36%

21%

21%

12%

9% 1%

South Zone

Tamil Nadu

Kerala

Karnataka

Telangana

Andhra Pradesh

Pondichery

20%

21%

19%

19%

12%

4%

2% 3% North Zone

New Delhi

Uttar Pradesh

Haryana

Rajasthan

Punjab

Himachal Pradesh

Jammu & Kashmir

79%

78%

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In the Eastern region of the country, the concentration of laboratories is largely limited to the 3

states of West Bengal, Odisha and Assam (69%). Other laboratories are scattered across the

states of Chhattisgarh, Jharkhand, A&N Islands, Bihar and few other north eastern states.

Exhibit 11: State-wise Distributions of Food Testing Labs in Eastern Region


1.6 Testing Abilities of Food Testing Laboratories With respect to food testing there are 3 types of critical tests that need to be conducted to ensure

that the food is safe and contaminant free. These tests can be broadly classified as chemical tests,

microbiological tests and test for heavy metals and residues. Besides these, there are few

58% 26%

12% 3% 1%

West Zone

Maharashtra

Gujarat

Madhya Pradesh

Goa

Daman

55%

7%

7%

5%

5%

4% 3%

3%

2%

2%

3%

2%

2%

East Zone West Bengal

Odisha

Assam

Chhattisgarh

Jharkhand

Andaman & Nicobar

Bihar

Manipur

Meghalaya

Mizoram

Nagaland

Tripura

Sikkim

69%

85%

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specific specialized tests like GMO testing that are required for specific food products and can

be conducted by limited number of laboratories.

Chemical tests include tests for Moisture, Water Soluble Extracts, Total Ash, Crude Fibre, Total

Solids, Total fats, Protein, Carbohydrates, saponification value etc. Biological tests on the other

hand include tests like Aerobic Plate Count, Yeast and Mould Count, E. Coli, Coliforms,

Salmonella spp., Listeria monocytogens and many more.

Heavy metals and residues can enter the food chain through various channels and impact the

human metabolism and can accumulate in the body causing severe toxicity. This makes it

important for food industry to ensure that their products are free from these toxic elements by

regularly testing their ingredients and products for compliance with the regulatory

requirements.

The common heavy metals fund in food include lead, arsenic, cadmium, tin, copper etc.

The segment below analyses the testing capabilities of all NABL accredited food laboratories.

The segment also captures the key food categories that can be tested by the laboratories in India.

The chart below clearly indicates that a large number of labs can carry out the biological,

chemical or both tests for the food and agri products (which covers a host of food items), while

only a few of them (only 32%) can test for pesticide residues in food products. Further there are

very limited number of labs which can test for specialized products like marine (16%),

nutraceuticals (4%) and GM products (2%).

Exhibit 12:Region-wise Testing Abilities of Food Testing Labs in India

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1.6.1 Biological & Chemical Testing in Food As highlighted previously, biological and chemical tests are the basic level of tests which are

carried out by the food testing labs. While both the categories of tests hold their own relevance

and significance in the food testing domain, it is observed that there are very few labs which can

actually test for both categories. Maximum laboratories can test for chemical parameters, fewer

for microbiological or both.

Exhibit 13: Testing Competency in Biological and Chemical Testing Across Key Categories

Source: NABL, FSSAI, YBL Analysis

Within the Food and Agri segment also, the competency of labs varies against specific products.

While maximum number of labs can test for cereals, pulses and their products, herbs, spices and

0

1

4

7

30

4

7

13

46

122

2

5

8

42

117

3

4

41

53

150

GM Products

Nutraceticals & Functional Foods

Marine/Aquaculture

Pesicide Residue

Food and Agri products

Region Wise Testing Abilities of Food Testing Labs in India (~462 labs)

South North West East

~ 17 Labs

~ 66 Labs

~ 148 Labs

~9 Labs

~ 419 Labs

414

56 15

241

23 6

236

13 4

Food and Agri products Marine/Aquaculture Nutraceticals & Functional Foods

Chemical Biological Both

18

condiments, there are as few as only 30 labs for poultry products 19 labs for edible colors and

flavors.

Exhibit 14: Testing Competency in Biological and Chemical Testing Across Key Products


1.6.2 Residue testing in food Residue testing in food requires higher competency and precision, both in terms of equipment

and manpower. There are only 148 laboratories of the total NABL accredited laboratories which

can test residues in food. Within the residue testing competency also, there are some common

residues (like pesticides, trace elements) which can be tested by majority labs, while other

residues like phenols, halogenated hydrocarbons, antibiotics etc. can be tested only by few labs.

Exhibit 15: Residue Testing Competency of Food Testing Labs in India


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50

100

150

200

250

300

Chemical Micro Biological

6

8

12

12

14

15

41

44

104

Phenols

Polyhalogenated Biphenyls

Chlorinated Dioxins & Dibenzofurans

Halogenated ydrocarbons

Polycyclic Aromatic Hydrocarbons

Polychlorinated Biphenyl

Antibiotics

Mycotoxin

Pesticides

14

2 Mapping of Testing Infrastructure against Production and

Processing This chapter captures the analysis of availability of food testing laboratories against the number

of food processing units and production quantum. To analyze the number of food processing

units catered by a single laboratory data has been collated through various sources like annual

survey of industries and FSSAI FBO registration and NABL. The production data is captured

through respective government department website like National Horticulture Board, National

Dairy Development Board, Ministry of Agriculture and Farmers’ Welfare and others.

The key categories included in the analysis are Cereals, Edible oil, Fruits & Vegetables, Milk,

Meat, Fisheries and Sugar. These categories together form more than 80% of the total food

production basket of India. In each of the aforesaid categories, the top 10 states with respect to

processing units established have been shortlisted and the corresponding production and food

testing laboratories (with scope for testing the category) under consideration has been

evaluated. The evaluation has been done basis the assumption that all processing units get their

products tested and the requirement of food testing laboratories is universal. A snapshot of the

sector wise findings is captured below:

2.1 Cereals India’s total cereal production is around 252 Mn MT (2016-17), while the total number of

established units for cereals and its products is estimated to be around 19,000 units (as per ASI

2014-15 data). The top 10 states in terms of number of processing units account for over 83% of

the total processing units in the country. These 10 states also contribute to around 60% to the

production and 54% to the food testing laboratory infrastructure (with the relevant scope of

testing) in the country. Evaluating the number of food processing units catered by the food

testing laboratories, it is observed that – while most states have sufficient infrastructure for

testing of cereals, in few states like Andhra Pradesh, Telangana, Punjab, Odisha and

Chhattisgarh the FBOs per laboratory are observed to be very high. There is a need to increase

the capabilities of existing laboratories within the states to cater to the requirements of this

sector. States like Chhattisgarh, where the total number of laboratories is very small, need a few

more multipurpose laboratories which can cater to all sectors of the state. However, it is also

pertinent to note that that not all FBOs go ahead with regular testing from third party

laboratories. The numbers provided below are based on the assumption that all FBOs within the

state (whether large or small) require food testing laboratories.

15

Exhibit 16: Testing Infrastructure Mapping against Production and Processing for Cereals

Source: FSSAI, ASI, MoAFW, NABL,YBL Analysis

2.2 Fruits & Vegetables India’s total F&V production is around 279 Mn MT (2016-17), while the total number of

established units for F&V and its products is estimated to be around 1100 units (as per ASI

2014-15 data). The top 10 states in terms of number of processing units account for over 84% of

the total processing units in the country. These 10 states also contribute to around 50% to the

production and 70% to the food testing laboratory infrastructure (with the relevant scope of

testing) in the country. Evaluating the number of food processing units catered by the food

testing laboratories, it is observed that – while most states have sufficient infrastructure for

testing of F&V and its products, in a few states like Punjab, Andhra Pradesh and Uttarakhand

the FBOs per laboratory are found to be higher in number. In the case of Andhra Pradesh the

number looks higher since majority of the food testing laboratories are located in Hyderabad

which is now a part of the Telangana state, however, these laboratories still cater to a part of the

need of the processing units of Andhra Pradesh as well. There is a need to increase the

capabilities of existing laboratories within the state of Punjab, as there are sufficient laboratories

in the state. In the case of Uttarakhand there may be a need to establish new laboratory

infrastructure as currently only 3 NABL accredited laboratories exist in the state (which are

open to testing).

Exhibit 17: Testing Infrastructure Mapping against Production and Processing for Fruits and Vegetables

Cereals Processing (No. of units) Production (Mn MT) Testing Infra for cereals & products FBO/Lab

Andhra Pradesh 3446 11 5 689

Telangana 2936 5 9 326

Tamil Nadu 2555 12 28 91

Punjab 2297 28 9 255

Chhattisgarh 1050 7 2 525

Uttar Pradesh 938 47 13 72

West Bengal 839 18 11 76

Karnataka 784 10 16 49

Maharasthra 754 8 47 16

Odisha 704 7 1 704

India 19648 252 259 76

Top 10 states as a %

India's total 83% 60% 54%

16

Source: FSSAI, ASI, NHB, NABL, YBL Analysis

2.3 Dairy India’s total milk production is around 155.5 Mn MT (2016-17), while the total number of

established units for milk and its products is estimated to be around 47,500 units (as per FSSAI

data). The top 10 states in terms of number of processing units account for over 93% of the total

processing units in the country. These 10 states also contribute to around 78% to the production

and 70% to the food testing laboratory infrastructure (with the relevant scope of testing) in the

country. Evaluating the number of food processing units catered by the food testing

laboratories,

it is observed that in few states like Madhya Pradesh, Rajasthan and Uttar Pradesh the FBO per

laboratory are on much higher side. Though, all these states have good number of NABL

accredited laboratories available, the requirement is to increase the scope of such laboratories

within the states. Exhibit 18: Testing Infrastructure Mapping against Production and Processing for Milk

Source: FSSAI, ASI, NDDB, NABL, YBL Analysis

2.4 Meat India’s total meat production is around 7 Mn MT (2016-17), while the total number of

established

units for meat processing is estimated to be around 7200 units (as per FSSAI data). The top 10

F&V Processing (No. of units) Production (Mn MT) Testing Infra for F&V and products FBO/Lab

Maharasthra 164 22 32 5

Punjab 158 6 5 32

Tamil Nadu 147 13 16 9

Andhra Pradesh 131 23 4 33

Gujarat 95 23 11 9

Karnataka 78 16 10 8

Telangana 51 1 7 7

West Bengal 49 29 7 7

Kerala 42 5 12 4

Uttarakhand 39 2 1 39

INDIA TOTAL 1131 279 151



Milk Processing (No. of units) Production (Mn MT) Testing Infra for milk & dairy productsFBO/Lab

Maharasthra 11159 10.2 35 319

Uttar Pradesh 6615 26.4 12 551

Madhya Pradesh 6091 10.8 9 677

Rajasthan 5736 18.5 8 717

Tamil Nadu 5197 7.3 25 208

Punjab 3386 10.8 8 423

Karnataka 1971 6.4 17 116

Gujarat 1673 12.3 19 88

Haryana 1368 7.9 17 80

Andhra Pradesh 1208 10.8 5 242

India 47587 155.45 220 216



17

states in terms of number of processing units account for over 82% of the total processing units

in the country. These 10 states also contribute to around 70% to the production and 58% to the

food testing laboratory infrastructure (with the relevant scope of testing) in the country.

Evaluating the number of food processing units catered to by the food testing laboratories, it is

observed that – while most states have sufficient infrastructure for testing of meat, Madhya

Pradesh is an outlier with 850 FBOs to be catered to per lab. It is most likely that these units are

very small scale enterprises, who may not be getting the product tested very frequently.

However, to meet the exiting theoretical demand there is a need to increase the scope of testing

of the existing laboratories within the states, rather than setting up new laboratory

infrastructure.

Exhibit 19: Testing Infrastructure Mapping against Production and Processing for Meat

Source: FSSAI, ASI, DADF, Indiastat, NABL, YBL Analysis

2.5 Aqua/Marine India’s total fisheries production is around 11 Mn MT (2016-17), while the total number of

established units in processing is estimated to be around 400 units (as per ASI 2014-15 data).

The

top 10 states in terms of number of processing units account for 100% of the total processing

units in the country. These 10 states also contribute to around 80% to the production and 74% to

the food testing laboratory infrastructure (with the relevant scope of testing) in the country.


observed that Goa does not have any testing infrastructure for aqua/marine products. Exhibit 20: Testing Infrastructure Mapping against Production and Processing for Marine & Inland

Meat Processing (No. of units) Production (Mn MT) Testing Infra for meat FBO/Lab

Jharkhand 908 0.05 0

Tamil Nadu 893 0.55 15 60


Maharasthra 834 0.68 17 49

Rajasthan 806 0.2 3 269

Harayana 374 0.4 8 47

Kerala 370 0.5 11 34

Punjab 350 0.57 2 175


Himachal Pradesh 283 0.47 1 283

India 7277 7.02 105 69



18

Source: FSSAI, ASI, DADF, NABL,YBL Analysis

2.6 Oils & Fats India’s total oilseed production is around 25 Mn MT (2016-17), while the total number of

established units for oils and fats is estimated to be around 10,700 units (as per FSSAI data). The

top 10 states in terms of number of processing units account for over 86% of the total processing

units in the country. These 10 states also contribute to around 90% to the production and 79% to

the food testing laboratory infrastructure (with the relevant scope of testing) in the country.


observed that– while most states have sufficient infrastructure for testing of oils and fats, in a

few states like Uttar Pradesh and Tamil Nadu the FBOs per laboratory is comparatively higher.

There is a need to increase the capabilities of existing laboratories within the state to cater to the

requirements of this sector.

Exhibit 21: Testing Infrastructure Mapping against Production and Processing for Oil

Source: FSSAI, ASI, MoAFW, NABL, YBL Analysis

2.7 Sugar India’s total sugar production is around 28 Mn MT (2016-17), while the total number of

established sugar units is estimated to be around 500. The top 10 states in terms of number of

processing units account for over 94% of the total processing units in the country. These 10

Marine + Inland Processing (No. of units) Production (Mn MT) Testing Infra for marine FBO/Lab

Kerala 146 0.68 11 13

Andhra Pradesh 64 2.33 8 8

Tamil Nadu 53 0.70 12 4

Gujarat 37 0.83 3 12

Karnataka 35 0.70 2 18

Maharasthra 34 0.62 7 5

West Bengal 31 1.63 4 8

Odisha 19 0.47 1 19

Goa 9 0.12 0

Uttar Pradesh 0 0.54 0

India 428 10.80 65



Oil Processing (No. of units) Production (Mn MT) Testing Infra for edible oil FBO/Lab

Tamil Nadu 2537 0.92 25 101


Rajasthan 1241 5.71 15 83

Kerala 978 0.001 17 58

Maharashtra 874 2.4 33 26


West Bengal 443 0.93 9 49

Gujarat 419 4.1 24 17

Karnataka 306 0.87 14 22

Haryana 289 0.85 13 22

India 10712 25.3 216 50



19

states also contribute to around 97% to the production and 70% to the food testing laboratory

infrastructure (with the relevant scope of testing) in the country. Evaluating the number of food

processing units catered to by the food testing laboratories, it is observed that the testing

laboratories for sugar are sufficient in number in all states.

Exhibit 22: Testing Infrastructure Mapping against Production and Processing for Sugar

Source: FSSAI, ASI, ISMA, NABL, YBL Analysis

3 Assessment of Demand and Supply of Food Testing

Laboratories in India The underlying chapter on demand assessment analyses the demand generated through the

existing FBOs for food testing and the requirement for infrastructure in the four regions of the

country. The services of food testing laboratories is largely utilized by the Food Business

Operators (FBOs) operating in the domestic as well as export markets (for compliance testing),

new companies for product development and research and development projects.

The assessment for demand of food testing has been done based on the following key

assumptions:

Data for FBO has been considered based on the FSSAI data. The categories include dairy

units, vegetable oil processing units, meat processing units, export units, all other food

processing units, FBOs manufacturing any article of food and manufacturer/processor.

Other than these, the HoRECA (HOtel/REstaurant/CAtering) segment has also been

considered as an additional category for demand assessment

Number of tests to be conducted by each FBO considered at a minimum level of 2/ year

Number of food products per FBO assumed at 10 units

Other than the regular food testing to be conducted by FBOs, it is assumed that 20% of

the FBOs would also avail the services of Food testing laboratories for R&D purpose as

well as New Product Development.

Sugar Processing (No. of units) Production (Mn MT) Testing Infra for sugar and products FBO/Lab

Maharashtra 159 10.5 27 6

UP 119 7.1 8 15

Karnataka 61 4.9 12 5

TN 42 1.2 14 3

AP 24 0.6 2 12

Gujarat 19 1.1 12 2

Punjab 16 0.5 2 8

MP 15 0.5 4 4

Haryana 14 0.5 11 1

Bihar 11 0.5

India 513 28.3 132 4



20

On the supply side the laboratories which are NABL accredited and are available for

providing services to third party have been considered.

The average testing capability of a food testing laboratory is based on the zone wise

primary research conducted by the YES BANK team

Scenario building has been done at 5%, 20%, 50%, 80% and 100% compliance by FBOs.

Based on the above assumptions and scenario it is observed that if 100% FBOs adhere to the

food testing law under FSS Act, the theoretical demand exceeds the supply and hence the

current infrastructure is insufficient and there is a need to establish new laboratories which can

cater to the demand of the entire food business ecosystem. However, the assumption that 100%

FBOs adhere to the law is very critical in this case.

The primary survey conducted by the study team across India for food testing laboratories as

well as FBOs comes out with a contrary finding that most laboratories are currently

underutilized due to limited samples received by them. Once the sample inflow increases, there

will be an automatic growth and upgradation of the food testing laboratories which will be

driven by the “business” generated through the increased inflow of samples.

3.1 Demand Assessment for Food Testing Laboratories by Food Business

Operators At 100% compliance (by FBOs for getting their products tested at least twice a year) the

theoretical gap that exists for the food testing lab infrastructure is as follows:

Exhibit 23: Theoretical gap in demand and supply of food testing labs in India

Zone FBOs

Total Samples to be tested in

a year (in lakh)

Number of NABL Labs

open to others for testing

Average testing

capacity per year for all

labs (in Lakh)

Surplus/Deficit in testing

capacity (in Lakh)

Number of labs required

@ 100 % compliance

East 32,487 6.6 29 1.9 -4.6 70

West 108,004 21.8 119 14.6 -7.0 58

South 126,625 25.6 148 13.9 -11.4 124

North 119,160 24.1 120 19.1 -4.7 31

Source: FSSAI, YBL analysis

The above table highlights the demand supply gap in food testing laboratories based on the

assumptions stated previously in this chapter.

The testing capacities for food testing laboratories used for the calculations is as follows:

Exhibit 24: Testing capacities across 4 zones

Zone Testing capacity/month

East 551

West 1026

21

South 783

North 1328

Source: YBL Primary Survey and Analysis

At 100% compliance by FBOs towards food testing the deficit in laboratories is estimated at 284

labs, with the maximum requirement in South (124 labs), followed by the East (70 labs), West

(58) and North (31). However, since the current compliance levels are much lower than this, the

laboratory requirement at various compliance levels is as estimated below:

Exhibit 25: Assessment of gap in food testing laboratories at various compliance levels

Lab requirement @ 5% compliance





East -23 -8 21 51 70

West -108 -82 -29 23 58

South -132 -91 -11 70 124

North -111 -89 -44 1 31

Total -374 -271 -63 145 284


Uptil 50% compliance level (by FBOs) the requirement of laboratories remains negative (i.e

there are sufficient labs). However, once the compliance levels by FBOs reach 80% or above

there will be requirement to set up new laboratory infrastructure in various parts of the country.

The graph below highlights the requirement of laboratories at various compliance levels

Exhibit 26: Requirement of laboratories at various compliance levels


-20

4

51

98 130

-99

-51

47

145

210

-121

-52

84

221

312

-107 -76

-13

49

91

East West South North

Lab requirement @

Lab requirement @ 20%


Lab requirement


22

3.2 Demand Assessment for Food Testing Laboratories by Food Business

Operators and HORECA segment Another level of demand assessment has been done considering the additional HORECA

segment as users of the food testing laboratories.

At 100% compliance (by FBOs and the HORECA segment for getting their products tested at

least twice a year) the theoretical gap that exists for the food testing lab infrastructure is as

follows:


Zone FBOs

Total Samples to be tested in

a year (in lakh)

Number of NABL Labs

open to others for testing

Average testing

capacity per year for all

labs (in Lakh)

Surplus/Deficit in testing

capacity (in Lakh)

Number of labs required

@ 100 % compliance

East 52,016 10.5 29 1.9 -8.5 130

West 200,383 40.5 119 14.6 -25.4 210

South 214,133 43.3 148 13.9 -28.9 312

North 166,491 33.6 120 19.1 -14.2 91 Source: FSSAI, YBL Analysis

The above table highlights the demand supply gap in food testing laboratories based on the

assumptions stated previously in this chapter.

The testing capacities for food testing laboratories used for the calculations is as follows:

Exhibit 28: Testing capacities across 4 zones

Zone Testing capacity/month

East 551

West 1026

South 783

North 1328 Source: YBL Primary Survey and Analysis

At 100% compliance by FBOs and the HORECA segment towards food testing, the deficit in

laboratories is estimated at more than 700 labs, with the maximum requirement in South (312

labs), followed by the West (210), East (130 labs) and North (91). However, since the current

compliance levels are much lower than this, the laboratory requirement at various compliance

levels is as estimated below:







compliance

East -20 4 51 98 130

West -99 -51 47 145 210

South -121 -52 84 221 312

23

North -107 -76 -13 49 91

Total -347 -175 169 513 743 Source: FSSAI, YBL analysis

At around 20-30% compliance level (by FBOs as well as HORECA segment) the requirement of

laboratories remains negative (i.e. there are sufficient labs). However, once the compliance

levels by FBOs reach 50% or above there will be requirement to set up new laboratory

infrastructure in various parts of the country (majorly in west, east and south). However, it is

important to note that feasible protocols and standards need to be brought in, before bringing

the HORECA segment under mandatory compliance for testing.

The graph below highlights the requirement of laboratories at various compliance levels

Exhibit 30: Requirement of laboratories at various compliance levels


-150

-100

-50

0

50

100

150

200

250

300

350

East West South North






24

38%

7% 15%

25%

8%

7% Private Lab - FSSAI Notified

FBO with Food Testing Lab

State Labs

Non FSSAI Labs

Institutional

Referral Labs

4 Primary Survey – Key Findings

4.1 Stakeholder Coverage For the purview of this study, a detailed sampling

plan was formulated in consultation with FSSAI

covering all kinds of food testing labs across

multiple states and UTs in India.

The major categories of labs considered during the

field survey exercise is enlisted in the table beside

In addition to food testing labs, key qualitative

insights were also sought from government officials

related to food testing was also sought

The sampling plan for this study covering 120

stakeholders is tabulated below:

Exhibit 31: Sampling plan for Primary Survey

Zone/ Categories

FSSAI Notified

State Lab*

Referral Non FSSAI

FBO (with or without

labs)

Institutional/ Others

Govt Officials

Total

North 13 6 1 7 12 3 5 47

East 3 2 1 3 - 3 1 13

West 11 4 1 7 6 - 2 31

South 9 2 4 8 4 4 1 32

Sub Total

36 14 7 24 22 8 9 120

Source: Yes Bank. *Proposed total for state labs was 20 nos. However, only 14 were covered under primary survey owing to lack

of response & data availability with state labs

Of these, a total of 96 food testing labs have been covered across 12 states and 23 cities. The major states covered for this survey include: Exhibit 32: Sample Coverage of food testing labs

Source: Primary survey & Yes Bank Analysis

North: Uttar Pradesh, Delhi, Rajasthan, Haryana, Punjab – 34 nos.

East: West Bengal – 12 nos.

South: Tamil Nadu, Telangana, Karnataka, Kerala – 27 nos.

West: Gujarat, Maharashtra, Madhya Pradesh – 23 nos.

Sr.

No. Type of Lab

1 Private Lab - FSSAI Notified

2 FBO (with or without Food

Testing Lab)

3 State Labs

4 Non FSSAI Labs

5 Institutional

6 Referral Labs

25

4.2 Key Findings

4.2.1 Accreditations Like any sector, food testing labs in India follow a set of accreditations which are obtained in

order to prove credentials, maintain sanctity, create visibility and consumer trust as well as

adhere to regulatory guidelines (domestic/international). The key accreditations and their

details are summarized in the table below:

Sr. No.

Type Of Accreditation

Particulars

1 National Accreditation Board for Testing and Calibration Laboratories (NABL)

The National Accreditation Board for Testing and Calibration Laboratories (NABL) undertakes the assessment and accreditation of Testing and Calibration Laboratories, in accordance with the international standard ISO / IEC 17025 and ISO 15189.

Accreditation areas include: Testing & Calibration - Testing: Biological, Chemical, Electrical, Electronics, Fluid-Flow, Mechanical, Non-Destructive Testing, Photometry, Radiological, Thermal, Forensic, Medical

- Calibration: Electro-Technical, Mechanical, Fluid flow, Thermal & Optical, Radiological

Benefits include: - Formal recognition of competence of a laboratory by an Accreditation body in accordance with international criteria has many advantages:

- Increased confidence in Testing/ Calibration Reports issued by the laboratory

- Better control of laboratory operations and feedback to laboratories as to whether they have sound Quality Assurance System and are technically competent

- Potential increase in business due to enhanced customer confidence and satisfaction.

- Customers can search and identify the laboratories accredited by NABL for their specific requirements from the NABL Web-site or Directory of Accredited Laboratories

- Users of accredited laboratories enjoy greater access for their products, in both domestic and international markets.

- Savings in terms of time and money due to reduction or elimination of the need for re-testing of products

2 FSSAI Notified

FSSAI Notified NABL Accredited Food Testing Laboratories valid for the purposes of carrying out Analysis of Samples Taken under Section 47of the Food Safety and Standard Act, 2006.

3 EIC Approved

The Export Inspection Council (EIC) is the official export inspection and certification body of India set up under the Export (Quality Control & Inspection) Act, 1963 to ensure sound development of India's export trade through quality control and inspection. It operates through its field organizations, Export Inspection Agencies (EIAs), headquartered at Chennai, Delhi, Kochi, Kolkata and Mumbai, and a

26

Sr. No.

Type Of Accreditation

Particulars

network of 30 sub offices including laboratories in important ports and industrial centers in India to carry out its functions.

Keeping this in view, EIC has reviewed and revised its laboratory approval scheme (Issue 4) for approval of laboratories that are technically competent having implemented quality management systems as per national & international standards and perform tests as per the guidelines/ procedures stipulated in the relevant standards of various export products.

4 APEDA Recognized

Authorized labs for sampling and analysis of agro products being exported under the purview of APEDA

As of May 2018, total of 44 APEDA approved labs in India with Maharashtra leading with 14 nos., followed by Tamil Nadu with 6 nos, Gujarat with 5 nos. and Karnataka with 4 nos. followed by the rest

5 Others BIS: Bureau of Indian Standards MoEF: Ministry of Environment & Forests AYUSH: Ministry of Ayurveda, Yoga and Naturopathy, Unani,

Siddha and Homoeopathy CPCB: Central Pollution Control Board AGMARK: Directorate of Marketing & Inspection, GoI Commodity Boards: Tea Board, Spices Board etc. MoFPI: Assisted by MOFPI in setting up or upgrading food testing

laboratories ISO Certifications

Based on the sample survey of food testing labs, a distribution of key categories of food testing

labs, accreditation wise is tabulated below. 78% of the labs were found to be NABL accredited

and over 57% were FSSAI notified.

Exhibit 33: Accreditations of labs covered under primary survey

Category of Lab NABL Accredited

FSSAI Notified

EIC approved

APEDA recognized

MoFPI assisted

Private Lab - FSSAI Notified 34 33 5 12 12

FBO with Food Testing Lab 2 0 0 0 0

State Labs 5 9 1 0 0

Non FSSAI Labs 20 2 0 0 1

Institutional 8 4 4 0 0

Referral Labs 6 7 1 0 0

TOTAL 75 55 11 12 13

Source: Primary Survey & Yes Bank Analysis

27

When it came to FSSAI notified private labs, 94% were found to be NABL accredited, 92%

FSSAI notified and 33% each being APEDA notified and having availed benefit from the

Ministry of Food Processing Industries.

Of the 14 surveyed state labs, 36% were NABL accredited, followed by 64% being FSSAI

notified. However, EIC recognition was only with around 7% of the surveyed state labs.

Food testing labs with Food Business Operators is primarily for in house use only. Their

main focus is on product development and testing of basic parameters, hence, high level

accreditations are seldom preferred by such laboratories since they are not commercial in

nature. Only 29% of FBO labs were found to be having NABL accreditation.

83% of the non FSSAI labs surveyed were found to be having NABL accreditation, while the

figure rose to 86% in referral labs and peaking at 100% in the case of institutional labs. All

surveyed referral labs were found to be FSSAI notified, while 50% of the surveyed

institutional labs were found to be having FSSAI and EIC notifications.

The West and South zones with their high export potential, logistics and maritime

infrastructure show a comparatively higher proportion of presence of APEDA and EIC

approved labs while in terms of assistance from MOFPI, the West zone labs contributed

maximum.

In addition to these major accreditations, several other key ones included BIS label,

AGMARK, MoEF and AYUSH.



78%

57%

11% 13% 14%

NABL FSSAI Notified EIC Approved APEDA recognised MOFPI assisted

28

4.2.2 Testing Methods Food and agro consumables are highly vulnerable commodities, prone to chemical, microbial,

physiological and other such related contaminations. It is of paramount importance that food

testing is made 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.

Sr. No. Testing Method Particulars

1 Chemical Chemical residues are the remaining parts of the substances

which are used during a particular process say for crop

production or for pest control.

The presence of the toxic substances in food could be either due

to the direct interaction of Fertilizers and Pesticides being used

in large proportion in order to increase the volume of the

production and to protect crops and animals from pests &

diseases.

The indirect sources like aquatic environment factors like –

water, soil are also considered as one of the reasons for toxicity

in food products.

Major parameters considered herewith include pH, acidity, fat

content, moisture etc.

2 Biological Microbiological testing of food is the examination of the

microscopic organisms in food. These organisms could be single

cell, multiple cell or without cell. Microbiology includes various

sub-disciplines like Virology, Mycology, Parasitology and

Bacteriology.

The microorganisms can be found in various foods & beverages

and they can be harmful if they enter into a human body. Some

of these microorganisms could prove to be resistant to one or

more types of antibiotics.

E.Coli, Salmonella, yeast and mould are some of the major

microbial contaminants in food products

3 Mechanical Softening point, viscosity, melting point, packaging material

strength, abrasiveness etc are few of the key parameters of

mechanical testing when it comes to food and agri products

4 Pesticide/Residu

e

Trace chemicals, especially pesticides, easily find their way into

the food cycle, affecting the health of consumers and disturbing

the ecosystem in general

https://testing-lab.com/food-testing/microbiological-testing-of-food/

29

4.2.3 Testing Competency Based on the sample survey of food testing labs, a distribution of key categories of food testing

labs, testing capability wise is tabulated below.


Category of Lab Chemical Biological Mechanical Pesticide /Residue

Private Lab - FSSAI Notified 34 34 21 25

FBO with Food Testing Lab 7 7 6 1

State Labs 13 8 8 4

Non FSSAI Labs 17 13 4 4

Institutional 8 4 2 4

Referral Labs 7 7 3 6

TOTAL 86 73 44 44 Source: Primary Survey & Yes Bank Analysis

Based on the questionnaire developed, the survey focused on four key categories of testing

being considered as tabulated in the table above. Wet chemistry and chemical analysis was

found to be present across the board, primarily due to the fact it consumes less time, has

lesser parameters, requires less TAT and lesser specialized manpower and equipment

A summary of the key findings in food testing infrastructure labs based on competency

present is summarized in the following graph

Exhibit 36: Testing Competency of labs covered under primary survey


94% 100% 93%

71%

100% 100% 94%

100%

57%

54% 50%

100%

58%

86%

57%

17% 25%

43%

69%

14%

29%

17%

50%

86%

Private Lab -FSSAI Notified

FBO with FoodTesting Lab

State Labs Non FSSAI Labs Institutional Referral Labs

Chemical Biological Mechanical Pesticide/Residue

30

Private Lab – FSSAI notified: Over 90% of the labs were found to be housing chemical and

microbiological testing facilities, followed by 69% each for pesticide/residue testing and

58% with mechanical testing. Higher investment appetite, anticipation of higher sample

inflow and the avenue of providing both facilities under one roof to attract more customers

was found to be primary reasons behind labs considering setting up of all three facilities in-

house (Chemical, biological and pesticide/residue).

FBO with Food Testing Labs: FBOs with financial wherewithal and brand consciousness

have in-house labs for both, product development and quality testing of raw material and

processed products. In order to reduce dependence on 3rd party labs, control over their

proprietary formulations and maintain trade confidentiality, such in house facilities are

developed and maintained. Hence, all such FBOs surveyed were found to have chemical

and biological facilities in-house. Pesticide/residue testing, since capital intensive, is

outsourced to trusted 3rd party entities based on long standing trade relationships. Only 14%

of the FBOs were found to possess in-house pesticide/residue testing facility.

State Labs: State laboratories at capital cities (or other key clusters in a state) were found to

be in a lesser developed condition when compared to private labs or FBO labs. Though high

presence of chemical facilities (over 90%), only 57% labs were found to house a biological

facility, followed by 29% with pesticide/residue testing. These labs face bureaucratic,

administrative and procurement (manpower/equipment) challenges thereby affecting their

day-to-day functioning & capacity to expand or perform better (in terms of TAT, covering

more parameters, attract more samples etc.)

Non FSSAI Labs: 71% of the Non FSSAI notified labs surveyed were found to have basic

chemical testing facilities, and 54% having biological testing facilities. Such non FSSAI labs

are comparatively operating on a smaller scale with limited outreach in terms of geography

and sample coverage. Hence, only 17% of this category were found to be having a

pesticide/residue testing facility.

Institutional Labs: Institutional labs primarily constitute of entities which are primarily

mandated for Centre driven R&D, National research programs, agency tie ups (APEDA etc.)

and academia. A key role in the upkeep, quality and operating efficiency of such labs is the

funding received (from University, Agency, CSR, Deemed Institute et al). Also,

administrative and expansion issues are faced due to lag in approvals and receipt of funds.

All institutional labs were found to house a chemical analysis facility, while only 50% of

these were found to house biological and pesticide/residue testing facilities.

Referral Labs: Referral labs are appellate authorities in food testing situated at key locations

across the country with specific geography focus. Owing to their critical role in ensuring

legal sanctity of food testing results and disputes, they were found to be well equipped with

all labs having a dedicated chemical and biological testing facility, and 80% of the labs

having a pesticide/residue testing facility. Wherein, such facilities were unavailable or

temporarily nonfunctional, the sample load was shared with other functional referral

laboratories.

31

50% 50%

Labs doing testing in other sectors

Labs doing only food testing

Around 50% of the labs surveyed were

involved in doing testing in sectors

other than food and agro products.

During the field survey, it came to light

that many labs already existing in

pharma and environmental testing had

moved to food testing owing to

business opportunities and similarity in

testing methods and equipment.

The major sectors in which labs

were found to be involved in testing

are:

o Pharmaceutical & environmental testing

o Petroleum & Chemical products

o Cosmetics & AYUSH

o Packaged Drinking Water


32

4.2.4 Equipment

In addition to qualified and trained human capital, accreditations, a food testing lab’s

capabilities can be primarily gauged by the kind of equipment which is deployed for

food testing and the number/variety of parameters it can cater to. A lab can increase its

outreach, capability, sample inflow and visibility by means of high end testing

equipment. On the contrary, such equipments and their procurement, installation and

maintenance are highly capital intensive in nature. The graph below highlights key high

end equipment and its availability across the various categories of labs surveyed.

Exhibit 37: Equipment Availability of labs covered under primary survey


Private Lab – FSSAI notified: Around 58% and 29% of these labs reported presence of a

GCMS and GCMSMS equipment, followed by 29% & 14% for LCMS and LCMSMS and 56%

with availability of an ICPMS. IRMS being a highly expensive and specialized equipment

was found only in 19% of private FSSAI labs. IRMS is considered to be an essential

equipment for testing of honey and its derivative products, if any.

FBO with Food Testing Labs: As mentioned in the preceding sections, major food

processing companies have in house labs for product development, product testing and

maintaining proprietary data. LCMS and GCMS were found to be the major equipment

present in such labs with 29% reporting the same. If at all, additional parameters are require

d to be tested, FBO labs have tie ups with established commercial labs to which these are

outsourced to.

State Labs: Laboratories at state level have to move through a channelized procurement

process to upgrade existing or buy new equipment. Also, lab configuration to suit high end

equipment needs to pass through multiple approvals which came out as a key constraint in

58% 58%

47%

58% 56%

19%

29%

14%

29%

14% 14% 14%

29%

43%

29%

29% 29%

0%

38%

4%

17%

4%

17%

4%

50%

38%

25%

75%

50%

0%

86%

71%

86%

71% 71%

29%

GCMS GCMSMS LCMS LCMSMS ICPMS IRMS

Equipment Availability

Private Lab - FSSAI Notified FBO with Food Testing Lab State Labs

Non FSSAI Labs Institutional Referral Labs

33

maintaining or procuring high end equipment. As a result, only 29% of state labs reported

presence of a GCMS, 43% GCMSMS, 29% LCMS and 29% each for an LCMSMS & ICPMS.

Non FSSAI Labs: In non FSSAI labs, only GCMS (38%), LCMSMS (4%) and an ICPMS (17%)

were found to be present amongst the high end equipment. GCMSMS, LCMS and IRMS was

negligibly present in any of these labs.

Institutional Labs: Institutional labs owing primarily to a R&D mandate as well as

improvement of food testing protocols & culture, reported a healthier presence of high end

equipment with 50% of them reporting presence of a GCMS, 75% with LCMSMS and 50%

reporting presence of ICPMS.

Referral Labs: Referral labs also emerged with an 80% presence of key equipment like

GCMS, GCMSMS, LCMS, LCMSMS and ICPMS. All key equipment was found to be present

in over 70% of the surveyed labs

4.2.5 Sampling & Capacity Utilization

Sampling plays a key role in maintaining the sanctity of the sample as well as directly

impacting the outcome of a test being done. If a sample doesn’t comply with the necessary

standards, it may misrepresent the actual information, thereby leading to scenarios wherein

an entire potential export consignment is impacted, a brand image may get tarnished,

consumer mistrust may emerge and overall businesses may get affected.

The major factor impacting the Turnaround Time (TAT) of a sample is the number of

parameters of testing it is undergoing. It is understood that chemical section based tests

consume considerably less time, and if a sample is to be tested on microbiological

parameters, the time needed is much more. An outline of the average turnaround time ( in

days) for different categories of labs surveyed is represented below: Exhibit 38: TAT of labs covered under primary survey


6 4

8 8

14

10

Non FSSAI Labs FBO with FoodTesting Lab

Referral Labs Private Lab -FSSAI notified

State Labs Institutional

TAT (in days)

34

Non FSSAI Labs: As highlighted earlier, only 54% of these labs are involved in

microbiological testing. Hence, their average TAT arrived to around 5 days as only chemical

analysis is being carried out.

FBO with Food Testing Labs: FBO labs primarily deal with in-house samples only, and

hence, the constraint of time and TAT is relatively less. However, they also have an upper

limit within which the results are to be furnished which came to around 4-5 days as

microbiological parameters are also to be executed.

Referral Labs: The average TAT for a referral lab came to around 8 days from date of

receipt of samples.

Private Lab – FSSAI notified: Private FSSAI notified labs doing both chemical and

microbiological testing for a food sample reported an average TAT of 8 days. It was

reported that if only chemical parameters are to be tested, then the TAT would be around 2-

3 days. However, owing to microbiological testing as well, the TAT on an average goes up

to 7 to 8 days. TAT may vary depending on any parameter being outsourced to another

partner lab in a different geography, thereby resulting in delay due to unforeseen

circumstances (logistics, manpower, unavailability of manpower etc.)

State Labs: State labs reported the average stipulated TAT to be 14 days. However,

constraints were voiced regarding the same, as public holidays and weekends are included

in the same thereby narrowing the actual window. It was suggested that the stipulated TAT

be excluded of weekends and holidays and only working days should be considered.

Institutional Labs: Average TAT was reported to be 14 days for institutional labs.

The graph below highlights the capacity utilization levels of surveyed labs based on the existing

set up in terms of equipment, scope and manpower availability on best effort basis. The

utilization is highly variable owing to a number of internal and external factors (seasonality,

festivities, inflow from other labs owing to equipment failure, random check drives etc.)

Institutional labs have need based and noncommercial sample inflow, hence their capacity utilization

levels may not remain standard & are highly variable)

Exhibit 39: Capacity Utilization of labs covered under primary survey


46%

72%

84%

56%

57%

52%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Private Lab - FSSAI Notified

FBO with Food Testing Lab

State Labs

Non FSSAI Labs

Institutional

Referral Labs

Capacity Utilisation (%)

51%

35

4.2.6 Manpower/Human Resource

In addition to the equipment, it is critical for every food testing lab to deploy qualified,

trained and aware personnel to operate the equipment optimally. This results in good and

accurate quality output in terms of test results, less time consumption, customer satisfaction,

contingency management and overall trust by the consumer.

As per feedback received during primary survey, in addition to the non-technical and

administrative manpower, 3 key sets of personnel are essential to smooth functioning of a

food testing lab (depending on the facilities housed, scope and equipment deployed in the

lab). These include the following

o Chemists: Senior, Junior, Assistant

o Microbiologist: Senior, Junior

o Food Analyst: Qualified in Food Analyst Exam

Exhibit 40: Availability of Manpower in labs covered under primary survey


Presence of Chemists was found to be the maximum in Referral labs owing to their wide

quantum of work and accountability as the appellate authority (around 30 nos.) followed by

private labs FSSAI notified with an average chemist strength of 15. FBO labs, state labs, non

FSSAI labs and institutional labs reported an average chemist staff strength of 6 to 10 nos. It

was highlighted that across the board, if required, chemists are brought in on contract basis

depending on the requirement. This holds true especially in state and institutional labs as

they have a specific channel for recruitment, and if staff is not available through the channel

at short notice, contractual human capital may be tapped into.

Microbiologists are specialized personnel excelling in the subject and hence, their strength

when compared to chemist or other technical manpower is relatively lower. Private FSSAI

notified labs reported an average strength of 4 nos., followed by FBO and referral labs with

3 nos., and non FSSAI/institutional labs with 1 nos. State labs seldom reported any presence

of microbiologist. This is highlighted by the fact in the earlier sections that state labs

reported the least availability of a microbiological facility within their premises. Hence, full

time personnel for such expertise was negligibly found.

15

6 11 10

7

30

4 3 0 1 1 2 1 0 1 1 0 0

9 3

13

6 4

23

Private Lab -FSSAI Notified

FBO with FoodTesting Lab

State Labs Non FSSAI Labs Institutional Referral Labs

Chemist Microbiologist Food Analyst Non Technical Staff

36

4.3 Summary of key findings

Of the surveyed samples, around 78% of the labs were found have NABL accreditation while 57% were FSSAI notified. Owing to a comparatively higher contribution to exports and trade, presence of EIC and APEDA notified labs was found to be more in Western and Southern areas of the country. Other major accreditations held by the surveyed labs included BIS, AGMARK, MoEF and AYUSH. A general consensus pertaining to multiple accreditations was that; it is a resource, cost and time consuming adherence. Steps in the direction to consolidate the same was suggested by the stakeholders.

In terms of in-house ability for testing, most of the surveyed labs had a chemical based testing set up. Microbiological and pesticide residue testing is considered to be a comparatively more capital intensive service, hence, lesser quantity of labs possessed the same. Fluctuating inflow of samples owing to seasonality and trade also hampered revenues and subsequent investments. Also, non-chemical based testing requires specialized personnel (microbiologist and others) which is a challenge for the organisations to hire, train and monitor over a longer period of time. Institutional and Referral labs were found to be having a better facility set up in terms of all kinds of testing be it chemical, microbiological or residue based.

Procurement and maintenance of high end testing equipment is a major challenge faced by small and medium private sector labs owing to lack of samples and minimal capacity utilization. The AMCs and upkeep of such equipment (GCMS/LCMS/GCMSMS/LCMSMS/ICPMS etc. amongst others) is a very high cost faced by the labs. As most of such equipment is imported, the costs naturally rise when it comes to servicing and repairs. Also, those labs having older models of these equipment find it hard to upgrade the same due to the reasons listed above. Institutional and referral labs had the highest availability of such high end equipment owing to direct access to funds, defined procurement channel (though delays in procurement is a challenge) and a relatively higher sample inflow owing to their mandate for mandatory compliance and monitoring of the general food safety security of the country.

In terms of Turnaround time (TAT) and capacity utilization, the average TAT for state, institutional and referral labs ranged between 8 to 14 days. The TAT varies owing to the number of parameters to be tested during a specific time frame. In private labs, both FSSAI and non FSSAI labs, the average TAT ranged between 3-4 days for chemical based testing while it stretched to 7-10 days if microbiological parameters are also involved. Operational and manpower cost to private labs suffers highly due to lack of sample availability, which inherently impacts its capacity utilization. State, institutional and referral labs have a steady mandated inflow of samples, however, it’s the private sector and smaller labs in general which were found to have comparatively lower utilization rates (ranging between 45%-55%)

Scouting, hiring, training and monitoring of qualified personnel is a major cost head for private sector labs. Herein, an evident issue of attrition is also seen with qualified manpower moving out to other organisations after a period of time. Referral and institutional labs had a comparatively higher number of chemists (~30 nos.), while in other categories of surveyed labs, the number varied between 6-10 nos. Also, when it came to maintaining dedicated microbiologists it is considered to be a major cost head by the private labs.

37

5 Challenges and Recommendations

5.1 Challenges

5.1.1 Equipment & Machinery In addition to adequate space, configuration & skilled manpower, equipment and machinery is

the cornerstone of any quality testing set up. The overall outcome of a test, the quantum of

parameters and samples being tested and the optimization of TAT is highly dependent on the

efficiency, run time, maintenance and competency of equipment. As an outcome of the primary

survey, key challenges pertaining to equipment were highlighted by the stakeholders which are

enumerated below:

- Procurement Channel: In the government sector, procurement of high end equipment is a

centralized process which necessitates multiple bureaucratic and formal approvals. This also

holds true for upgradation/ replacement of existing equipment, bringing in CRMs or

installing additional parts to an existing equipment. The delay in approvals is time

consuming, causes huge downtime and affects the overall operations of the lab. In the

private sector, the high gestation period coupled with the highly capital intensive NABL

accreditation process at the beginning of a lab’s operation cycle creates difficulties in

sustaining operations of a lab. This holds true as the lab in its nascent stage is still setting up

its operations, brand, creating visibility and word of mouth in the market.

- Maintenance of Equipment: High end equipment such as LCMS/MS, GCMS/MS, ICPMS,

IRMS and others are highly advanced and technical in nature. It requires designated and

certified engineers for its upkeep and maintenance. As most of these equipment are

imported, the penetration of their maintenance centres is limited to metros and tier 1 cities

at most. Hence, this leads to lag in service being provided in time, leading to precious loss of

operational costs and downtime.

- Lack of upgradation, high cost and dependence on imports: As highlighted earlier, most of the

high end equipment is imported, which results in huge import duties being paid and a

substantial transit time while procuring new equipment, parts and ancillary equipment.

Also, lack of knowhow in terms of specs of required equipment by newly set up laboratories

leads to unintentional costs & delays in procurement. There is a need to upgrade the current

infrastructure and to create more to meet the needs of the growing sector

- Lack of Availability of information: Food testing is a continuously evolving sector. Information

regarding updates and alterations in global trends, advancement in technology and

equipment is seldom available nor communicated to food laboratories.

5.1.2 Manpower Availability - High attrition in private sector laboratories: Quality testing is a highly specialized skill set

which requires core technical knowledge and awareness about the sample & its dynamics. A

food sample is not the same as a soil sample or a packaging material sample. Post hiring for

freshers, it needs continuous monitoring and training for personnel to reach to a certain

38

level and quality in food testing. This consumes capital and time, post which a person may

leave or move out to another lab or allied field/sector. Average attrition rate in private

laboratories was found to be around 30%.

- Time consuming recruitment channel in govt. laboratories: In government sector laboratories,

vacancies are generally advertised and recruitment is done through centralized channel.

Sometimes, delay in approvals and confirmations or bureaucratic decisions causes delay in

filling of critical posts in time which leads to daily operations being hampered negatively.

- Non availability of technical manpower/Shortage of FSO’s at ground level: Non-availability of the

technical manpower has been one of the primary reasons behind underutilization of food

testing laboratories. The availability of food analysts is also very low in the country. Also,

Food Safety Officers (FSOs) at ground level are the workhorses who ensure adequate

inflow, surveillance and monitoring of samples in a particular designated geography. They

are responsible for quality sampling, connecting with local food

processors/retailers/marketers, dissemination of relevant information and maintaining

broad communication between the FBOs/retailers and food testing authorities. However,

many states reported vacant posts for FSOs and additional charges for existing FSOs leading

to them handling multiple geographies. In some States/UTs officers in Health Department

are holding additional charge of food safety department.

5.1.3 Skill Development - Training & capacity building not focused & targeted as per industry and personnel needs: Most of

the training programmes attended by lab personnel are not in line with their requirements

as technicians, adhering to their skill sets and lack avenues for practical application. Eg.

Technician getting trained on an equipment which is unavailable in his/her lab and hence,

skills cannot be tested once a technician gets back after training. Also, limited of avenues for

training and keeping up with global trends due to non-availability of training infrastructure

in vicinity of lab, thereby resulting in travel costs and time being spent by laboratories.

- FSO’s belonging to medical and health sector: Many states/UTs deploy medical personnel as

FSOs and for sample collection instead of dedicated food safety and food technology

personnel.

5.1.4 Regulatory • Multiple accreditations: Viz. NABL, FSSAI, EIC, BIS et al create unwanted confusion &

mandates high investment in terms of cost, time & human capital. NABL accreditation post

lab set up is a highly capital intensive task consuming more resources especially at a time

when sample inflow, visibility and brand awareness of a lab is less.

• Packaged drinking water is already included in the definition of food. Hence, it

is recommended that the definition of drinking/ portable water should also be

added to Section 3 (1) (j). The water that is served as drinking water in the

eateries should be brought under the purview of the Act.

39

• Administrative Set up: Food safety as a subject is under the Department of Health. Hence,

food safety always competes with healthcare which is generally given more importance in

terms of funds and resources. Also, the responsibility for surveillance and enforcement of

food laws lies solely on the State Governments. However, due to non-availability of

adequate resources, the states face a handicap when it came to improving infrastructure and

manpower without the central government assistance. Many States do not have a separate

food safety department either.

• Mandatory pesticide residue testing for FSSAI accreditation: Laboratories found this pre-requisite

condition of having pesticide testing capability to be an impediment for garnering visibility

and market outreach

• Enforcement: After more than a decade of enactment of the FSS Act, clarity regarding the

regulation, stance and acceptability of GM food is still not available. Awareness in the public

domain regarding the same also need to be improved.

5.1.5 Research & Development - Negligible R&D in addition to quality testing: Food testing laboratories, both public and

private, seldom indulge in independent R&D to formulate/evolve latest techniques,

training modules or protocols for food testing. No incentive or promotion for the same to

keep up with global standards.

5.1.6 Capacity Utilization - Lack of inflow of samples: Laboratories, after detailed feasibility and high capital investment

are set up but suffer on account of low capacity utilization due to less no of samples in food

space severely impacting the viability of the instruments. Samples from

drugs/pharmaceuticals are found to be more due to stricter enforcement due to which

several laboratories have seized food testing and have commenced drugs’ testing. Low

capacity utilization in private laboratories & lack of equipment & manpower in government

laboratories is hampering food testing industry growth.

5.1.7 Consumer Awareness - Consumer awareness towards food safety generally low: Overall consumer awareness regarding

food constituents, packaging material, nutritional information, mode of preparation and

other such quality parameters of food commodities is still negligible in India, more so in

rural geographies. As a result of less awareness, the demand pull in terms of samples

making their way to food testing laboratories is also low. This is more so in areas with less

industrialization and less presence of food processing industries.

o Knowledge pertaining to value added food, fortified food and other such variables also

needs to be improved at both, the FBO and the consumer level. FBOs should be

monitored and instructed to communicate with the consumer in a way that such value

additions are easily understood and accepted. Consumers are seldom aware of these

40

terms and their health implications. Though large number of products is sold by

manufacturers under these claims, these terms are not clear to manufacturers either. The

same knowledge and technical information also needs to be improved when it comes to

FSOs and other ground level staff as their awareness levels pertaining to the same is also

low or differently interpreted.

- Lack of connect between industry & food laboratories: Upcoming or newly set up laboratories

face a problem in getting samples due to lack of market visibility and industry connect.

Food testing in India traditionally has been relationship and trust based due to which a FBO

may send a sample to a farther place than required being assured of good and timely

results. A survey by CIFTI and FICCI has revealed that about one-third of the industry is

unaware about the FSS Act and its regulations. This lack of information among the food

suppliers, sellers and buyers is one of the major challenges in the present food safety regime.

- Lack of FBO conviction and accountability: Stringent actions should be undertaken in a time

bound manner against FBOs who may be involved in illicit activities such as working

without licenses etc. and heavily fined.

5.2 Recommendations

5.2.1 Stricter implementation of food testing regulation:

As per the FSS regulation on food testing FBOs need to get their products tested at least once in

every 6 months and appropriate records of laboratory test results need to be retained for a

period of one year or the shelf-life of the product, whichever is higher. Rather than merely

maintaining a record of the test reports, these should be uploaded on the FSSAI portal and

should be linked to the licensing/ registration of FBO. This shall compel all the FBOs to get their

products tested as per the laid regulations.

Optimum utilization of the food testing labs by collection and analysis of more food samples

is of paramount importance. FSSAI may prescribe a minimum number of samples to be

collected by each Food Inspector. Persons involved in sampling and analysis should be

accountable for cases which fail in court due to wrong sampling and wrong analysis.

Cancelled licenses of FBOs during the three years for not meeting the quality norms should

also be made public so as to improve awareness.

FSSAI should monitor FBOs and update their database consistently. Timely surveys for

identification of FBOs is essential. This may be implemented through outsourcing to a

credible 3rd party in coordination with the State Food Authorities

Food Inspectors should maintain database of inspections conducted. All the States/UTs

should maintain an e-database of failed testing reports that will not only help in better

monitoring of FBOs but also shift the present system of random inspections to a more

targeted and streamlined mode of monitoring.

Finalize “Guidelines for safety assessment of food derived by GM technology" and

implement them soon. FSSAI should also work to upgrade the GM food testing

41

infrastructure and make use of the already present laboratories in the country and equip

them with latest technology. FSSAI should also educate the citizens of the country as to

what constitutes GM foods as a vast majority of people are not aware of the concept of GM

foods.

5.2.2 Training Programs:

The food testing laboratories are of the opinion that more specific and targeted training

programs need to be conducted by FSSAI, specifically for the highly technical and to

methodological tests (like pesticide and heavy metal detection), so that each lab has a

competent person to handle such specific tests.

For DOs and FSOs, a specialized training programme for food inspections to ensure timely

inspection and help in identification of the FBOs engaged in the manufacturing of

adulterated or unsafe products should be rolled out.

Awareness amongst FBOs is also equally important for which development of specific

training modules for the manufacturers, importers, sellers, distributors and the FBOs which

is industry specific and for a shorter period should be planned should be formulated and

rolled out. Regular trainings for FBOs and small industries will adequately equip them to

comply with the standards of the FSS Act. Such programs can also act as a mechanism to

check the status of FBOs, the validity of their licenses and as a tool to keep them updated of

the changes in the food safety environment in the country.

All Central, State and Private food testing laboratories should ensure availability of a

mandatory minimum number of qualified staff specially Food Analysts so as to ensure

optimal operations and capacity utilization. FSSAI and the State Food Authorities should

also ensure that only qualified graduates with Science (and allied) background are

employed in the labs.

5.2.3 Organize a lab-industry- regulator forum:

It is requisite to establish a platform (annually or bi-annually) where the FBOs, laboratories and

regulator can come together on a common platform to discuss the pertinent issues, challenges

and expectations from each other. This will also be an opportunity for the laboratories to

interact directly with the FBOs and understand their requirements and challenges. Formation of

a lab association which works closely with the industry as well the regulator can also be

explored.

5.2.4 MoFPI to provide grant only to NABL/ FSSAI recognized laboratories:

The Ministry of Food Processing Industries currently provides assistance for establishing a food

testing lab by agencies/private sector organizations/ universities including deemed

universities by providing grant-in-aid of 50% of cost of laboratory equipment and 25% of the

cost of technical civil work to house the Equipment and furniture and fixtures associated with

the equipment for general areas and 70% of cost of lab equipment and 33% of technical civil

work and furniture and fixtures for difficult areas. The Ministry should evaluate providing this

assistance compulsorily to NABL recognized laboratories and also preferably to FSSAI

42

recognized/ referral laboratories, so that the equipment add to the existing capacity of food

testing laboratories which are available to the food processing industry.

5.2.5 Single Window System

There exist multiple accreditations and recognitions for food testing laboratories in India viz.

NABL, FSSAI, EIC, BIS etc. These multiple accreditations and recognitions create unwanted

duplication of work and are high on investment in terms of cost, time & human capital. These

accreditations and recognitions should be brought under a single platform to avoid duplication

of work and save on resources. Initiatives has already been taken on this front by EIC. FSSAI

should join this common platform for notifications of its labs.

5.2.6 Linking FBOs to INFOLNET Improving overall accountability and monitoring of FBOs:

The INFOLNET System prepared by FSSAI brings together all stakeholders to a common

platform for the establishment of a transparent food testing network. Currently the FBOs are

not a part of this system and the sample being received by the food testing lab has to be

registered in the system by the lab itself. This becomes tedious for the lab, consuming

unnecessary man-hours. Instead the sample input should be uploaded on the INFOLNET

system by the FBO sending the sample for testing. This would not only save time and

resources but will also reduce the chances of any error in the entry (as the FBO would know

the product description in greater detail and with greater accuracy).

Licenses for FBOs should be issued post optimal scrutiny. FSSAI should also examine the

FBO's previous track record with regards to compliance with the FSS Act. Any previous

non-compliance should be taken seriously.

The DOs and FSOs should inspect the premises of FBOs and guide the manufacturers to

maintain proper hygienic conditions. There should be surprise inspections. Every effort

must be made so that the FBOs do not evade the inspection process.

FBOs and training labs should be sensitized in advance and given timely intimation

pertaining to any change in clause of the Act or alterations in packaging/labelling

regulations so as to enable adequate time to conform to the changed standards. Phased

rollout of regulations with proper training to the FBOs is essential for enforcement of such

norms.

5.2.7 Consumer awareness

Consumer awareness is a critical factor that shall drive the demand for good quality food.

Currently, the consumer awareness towards food constituents, packaging material, nutritional

information, mode of preparation and other such quality parameters of food commodities

remains low and more so rural geographies. As a result of this limited awareness, the demand

pull in terms of samples making their way to food testing laboratories is also low. Also, overall

awareness within the public and eateries needs to be improved, because such awareness, if

enforced and demanded, will naturally create a pull in the testing fraternity thereby improving

the overall number of samples being covered under the ambit of food testing.

43

Hence, in order to improve overall awareness levels, it is recommended to launch a national

level awareness programme in partnership with all stakeholders including the Central and

State Agencies, Street vendors, universities and colleges, NGOs, small and big food industry

players should be rolled out.

As a majority of the contamination/adulteration starts from the production level viz. farm

level, it is essential to detect and monitor the same. Hence, it is recommended that there

must be a nationwide campaign on Good Agricultural Practices across all food sectors as

well. FSSAI/ State Food Safety Authorities should conduct training and awareness program

about the Act and best agricultural practices for the primary producers. The focus of such

training should be to prevent food contamination at the primary level and evolve a proper

monitoring mechanism

5.2.8 Delegation of Power to state laboratories for procurement The state food testing laboratories face a number of challenges in terms of bureaucratic delays

and time consuming approval system. This hampers the day to day working of the laboratories,

as approvals need to be in place even for procurement of daily consumables. The delegation of

powers and authority to state laboratories would go a long way in in facilitation of smooth

processes, procurement of consumables, equipments and CRMs so that the daily operations are

negligibly hindered.

Since, food safety implementation and monitoring rests at the state level, a State Level

Advisory Committee should be constituted with the Food Safety Commissioner as the

Chairperson and all the stakeholders as its members. This should carry its own individual

guidelines, constitution and roles. The Director of the State Food Testing Lab, officers of the

Food Authority and representatives from the industry associations should also be included

as its members. As a result of this system, at State and District level, better handling of

licensing/registration regulations and facilitation of integration of local bodies with the

Food Safety Administration would be possible.

A separate agency or Department of Food Safety in each state should be established to

enforce the food safety mechanism more efficiently

5.2.9 Manpower Availability & Optimization

An action plan in coordination with State/UT Governments should be drawn for

overcoming the shortage of manpower of Food Regulatory Bodies. As a short-term measure,

professionally qualified persons should be engaged on short-term contract till adequate

manpower is made available. Due to the very sensitive nature of regulatory work, great care

needs to be ensured so that they do not indulge in corrupt and illegal practices.

It should be ensured that the Food Safety Commissioner (if holding additional charge from

Health Department) should be well versed with food science and technology and should be

a whole time officer. Part time arrangement for such important functions in many

States/UTs creates a hindrance and lacuna in implementation of the Act.

Each State/UT should frame its recruitment regulations according to its size and population

and regular exams should be conducted to recruit qualified & trained personnel for food

44

testing. A minimum number of technical staff required for proper functioning of food

testing laboratory should be earmarked.

Chalking out of an action plan for arranging and allocating the demand and expanding the

pool of food analysts as per requirement/need basis.

6 Initiatives by FSSAI

6.1 Food Safety on wheels Testing of food to instil confidence amongst consumers that food is safe to eat is important part

of the food safety ecosystem. However, number and spread of food testing laboratories in the

country is grossly inadequate. While, Food Safety and Standards Authority of India (FSSAI) is

working towards having more food testing laboratories both in the public as well as private

sector, it has also initiated a scheme to provide mobile units for food testing to reach out to

consumers through as many touch points as possible.

These mobile units are called “Food

Safety on Wheels”. Apart from

conducting simple tests for common

adulterants in milk, water, edible oil

and other items of food of daily

consumption, these mobile units

would also be used for awareness

building around food safety, hygiene

and promoting healthy eating habits in

citizens at large and for conducting

training and certification program for

food handlers and supervisors in food

businesses, particularly petty food

businesses. In addition, these mobile

units would help the field functionaries

in the States to enhance their outreach

and conduct surveillance activities

even in far-flung areas.

The concept has seen a good traction

and so far, 32 FSWs have been

sanctioned to 27 States/UTs (as on 23 July, 2018)

6.2 Setting up Laboratories on PPP Mode The authority has undertaken to upgrade its referral laboratory - FRSL, Ghaziabad –on a public-

private-partnership (PPP) mode. Under this, it is proposed that the private partner will provide

infrastructure, manpower, install and commission the testing equipments followed by operation

and maintenance of facilities including food testing as per FSSR 2011.

States where 1 FSW have been

sanctioned/ delivered/ MoU signed

States where 1 FSW have been

sanctioned/ delivered/ MoU Signed

Exhibit 41: Status of Food Safety on Wheels Initiative by FSSAI

Source: FSSAI

45

FSSAI is also modernizing and upgrading its own referral laboratory, the FRSL, Ghaziabad -

rechristened as National Food Laboratory (NFL) – under a public-private-partnership (PPP)

mode. In this PPP venture, FSSAI would cover the capital expenditures, especially in creating

the infrastructure including state of the art equipment; wherein the private partner will be

responsible for providing manpower, installing and commissioning the testing equipment apart

from operationalizing and maintain the complete facility. Upon implementation of the PPP

mode, the NFL is hoped to serve as a model food testing facility that can be replicated across the

country.

An Open Tender was floated for awarding the contract for the PPP mode. The Contract has

been awarded to M/s Arbro Pharmaceuticals Pvt. Ltd. after due procedure with the approval of

the Competent Authority, being the L1 bidder with the rates quoted as below:

Part A (Supply and installation of tendered equipment) Rs.17,54,32,003/-(Rupees Seventeen

Crore Fifty Four Lac Thirty Two Thousand And Three only)

Part B (5 year operating cost) Rs.14,94,00,000/ - (Rupees Fourteen Crore Ninety Four Lakhs

only) payable in 60 monthly payments for 498 minimum guaranteed samples@ the rate

prescribed by FSSAI. *The current FSSAI approved rate is Rs.5000/- per sample. These rates are

excluding of any duties/taxes.

The facility will become a world class testing facility with broader scope. The firm will operate and

maintain the facilities for 5 years which may be extended for a further period of 2 years on satisfactory

performance at mutually agreed terms and conditions and rates

Scope of Work as per tender To equip FRSL Ghaziabad with the complete testing facilities as per the

requirements of FSSR along with the required manpower to fully operate and run the laboratory.

Management There is a 06 member Joint Management Committee (JMC) comprising of three

representatives each from the FSSAI and the Firm.

Obligation of FSSAI and M/s Arbro Pharmaceuticals Pvt. Ltd.

(i) FSSAI

a. Capital Expenditure: Rs.24,85,39,762/- (One time)

b. Operational Expenditure: Rs.3,58,80,000/- Annually (@24,90,000 p.m.)

(ii) M/s Arbro Pharmacueticals Pvt. Ltd.

The firm will undertake following work:

a. Infrastructure provision including civil work.

b. Provision of Manpower.

c. Providing, Installing and commissioning Testing equipment.

d. Operation and maintenance of facilities, including testing of food samples as per FSSR-

2011.

e. The Infrastructure works including technical & civil work, electrical work, and laboratory

furniture has to be carried out by the firm as per the detailed BoQ submitted by the

46

contractor. The BoQ was submitted by the firm which was vetted by the empaneled Civil and

Electrical Engineer. A cost assessing committee was also formed to assess the reasonability of

price of the items not on CPWD schedule.

f. The firm will make provision for the trained, experienced and qualified manpower to be

made available at FRSL Ghaziabad for Chemical, Biological, QA and Administration.

g. The firm will have to bear all the expenditure on staff, consumables and any other

expenditure related to functioning of the laboratory (electricity, housekeeping, maintenance,

gardening, security etc.)

h. Besides bearing all the operational expenses the firm is employing 24 persons at his

expenses to run the laboratory.

i. The firm shall be responsible for establishing and maintaining a quality management system

in compliance with the requirements of NABL as per ISO 17025.

j. All the safety parameters such as heavy metals, pesticide residues, and antibiotic residues,

Naturally Occurring Toxic Substances (NOTS), Microbiological testing as per Food Safety and

Standards Regulations, as amended from time to time shall be covered under NABL

accreditation within a period of one and a half year after the laboratory is handed over to the

contractor. NABL accreditation for all other parameters shall be achieved within 04 years

from the date of handing over the laboratory to the contractor.

k. The firm shall have complete responsibility for coordinating with NABL and the assessment

teams. The firm shall have to organize and bear all costs related to the NABL assessments of

the laboratory which may include and is not limited to assessment and accreditation fees,

travel arrangements, local transportation, food and lodging of the assessment team.

6.3 INFoLNET FSSAI has developed an IT solution for the Indian Food laboratory network called INFoLNET.

INFOLNET is an IT solution for Indian food laboratory network. This laboratory management

system (LMS) is a centralized system that connects and collates the network of laboratories. The

information on the INFOLNET would help categorize laboratories on a fit for purpose basis i.e.,

for regulatory requirements, routine testing, appellate testing etc. This LMS will also be a one

stop information portal for several information pertaining to a food testing laboratory, ranging

from ownership details, infrastructure availability, technical capacity, scope of testing through

to test results of different samples. Apart from being the back bone of the network, this LMS

will also be integrated to other FSSAI core IT systems, such as FLRS (Licensing and

Registration), FICS (Import Clearance), Quick access, FoSTAC (Training), etc. The centralized

information will also have profound applications in deciphering risk analysis, enriching

standards, capacity building and training. 5 training programs have been organized, one each at

Delhi, Mumbai, Chennai, Bengaluru & Kochi, to give demonstration of INFOLNET.

6.4 Strengthening of Food Testing System FSSAI is implementing a Central Sector Scheme for “Strengthening of Food Testing System in

the Country Including Provision of Mobile Food Testing Labs” (SOFTeL) with a total outlay of

47

Rs. 481.95 crores. The time frame for implementation of the Scheme is 2016-17 to 2018-19. The

scheme envisages strengthening of 45 State Food Testing Laboratories. At least one food testing

laboratory in each State and two in larger States would be assisted. For this, FSSAI is providing

a non-recurring grant of around Rs. 10 Crore each for upgradation of state food laboratories for

procurement of 3 major equipment namely ICP-MS, GC-MSMS and LC-MSMS, setting up of

Microbiology Lab, creation of Infrastructure for sophisticated equipment and setting up of

microbiological laboratory, besides recurring grant of Rs.35 lakh/year for Professional services,

Consumables and Contingencies as per the requirement of the respective state lab.

Further, for those North East States which do not have any Food Testing Laboratory, the

Scheme provides a grant of INR 3 crore each for setting up new food testing laboratory there.

So far 28 State Food Safety Laboratories of 25 States/UTs have been taken up for upgradation

including setting up 7 microbiology laboratories in 6 States/UTs. Proposals for setting up of 14

microbiology laboratories in 14 States/UTs are under consideration. A total Grant in aid of

Rs.111.95 crore has been sanctioned out of which 108.45 crore has been released for the

upgradation of these laboratories (as on 24.07.2018).

6.5 Training Programs FSSAI has also been very actively taking up training programs for the human resource involved

in Food Testing. The various training modules include- training the trainer, awareness program

on accreditation of laboratories by NABL, Good Food laboratory Practices. The training

programs have seen good traction and around 753 personnel have been trained under different

programs (as on 30th June, 2018)

Exhibit 42: Personnel Trained under various training programs

Upgradation

28 State Food Safety

Laboratories of 25 States/UTs

MicroBio Labs

Setting up 7 microbiology

laboratories in 6 States/UTs

MicroBio Labs

Proposals for setting up of 14 microbiology

laboratories in 14 States/UTs are

under consideration

Grant in Aid

Rs.111.95 crore has been

sanctioned out of which 108.45

crore has been released

48

Source: FSSAI

6.6 National Milk Quality Survey A National Milk Quality Survey is being steered by FSSAI to assess the quality of milk with

focus on unsafe/adulterated milk. The survey is being carried out in more than 130 cities across

India. Over 2800 samples will be picked up and tested for Fat and SNF content and 13 common

adulterants. Common sampling SOPs are being followed all over the country for picking up

samples, sample transportation and delivery. Moreover, the testing laboratories are following

common testing protocols provided by FSSAI for testing of the samples.

6.7 Reference Laboratories

6.7.1 Introduction The Food Safety & Standards Authority of India (FSSAI) is established under the provisions of

Food Safety & Standards (FSS) act 2006 as a statutory body for laying down science based

standards for articles of food and to regulate manufacture, storage, distribution, sale and import

of food so as to ensure availability of safe and wholesome food for human consumption.

FSS Act, under Section 16(2)(e), prescribes that the Food Authority may by regulations specify

the procedure and guidelines for accreditation of laboratories and notification of the accredited

laboratories; and, section 16(2)(f) prescribes that the Food Authority may by regulations specify

the method of sampling, analysis and exchange of information among enforcement authorities.

16

143 143

451

Master TrainingProgram

Training ofTrainers

Awarenessprogram for

Accreditation oflaboratories by

NABL

Good Food LabPractices

Total Samples to be Collected

2800

Coverage

130 Cities

Survey Components

Fat, SNF, 13 Adulterants

Collected Samples

513

Tested Samples

409

49

Also, the act under section 16(3) (e) prescribes that the Food Authority may by regulations

specify establishment of a system of network of organisations with the aim to facilitate a

scientific co-operation framework by the co-ordination of activities, the exchange of

information, the development and implementation of joint projects, the exchange of expertise

and best practices in the fields within the Food Authority’s responsibility.

FSSAI has laid down procedures and regulations for recognition and notification of accredited

laboratories. In order to further fulfil the above mandates, FSSAI initiated the process of

establishing the Network of National Reference Laboratory (NNRL).

Objective of setting up NNRL

6.7.2 Network of National Reference Laboratory – The Regulatory Status As per the regulations governing the recognition and notification of food testing laboratories

approved by the Food Authority, the authority may recognize any primary food laboratory

or referral food laboratory notified under Section 43 of FSS Act as National Reference

Laboratory for the purpose of developing methods of testing, validation, proficiency testing

(PT) and training. The network of such laboratories is named as the Network of National

Reference Laboratory or NNRL.

Functions of NNRL

Enhance reliability of results & continuous adherence to international laboratory practices

Result in greater availability of competent laboratories and proficient personnel

Allow uniformity in protocols and procedures across the laboratory network

Reduce litigations among the stakeholders / trade partners

Allow effective utilization of existing laboratory infrastructures

50

For being recognized and notified, every food laboratory shall have-

(a) Accreditation against ISO/IEC 17025 by the National Accreditation Board for

Testing and Calibration Laboratories (NABL) or such other equivalent accreditation

agency as may be approved by the Food Authority

(b) Adequate capability and competence for testing of food safety and quality

parameters as per the requirements of the Act

(c) Person possessing qualification and experience required for being appointed as

Food Analyst under rule 2.1.4 (1) of the Food Safety and Standards Rule, 2011:

Provided that a food laboratory accredited by an accreditation body having

authorized signatory designated by such accreditation body, shall also be

considered for being notified subject to the condition that such authorized signatory

shall, within one year from the date of such notification, acquire the qualification

and experience required for being appointed as Food Analyst under the said rule;

and,

(d) The infrastructure and facilities including equipment required for carrying out the

analysis as per the scope applied for.

Develop standards for routine testing procedures and reliable testing methods

Be a resource center for provision of information for certified reference materials and reference materials

Validate any method that is fit-for-purpose for food testing

Provide technical support in the area of competence

Evaluate the performance of other notified laboratories

Coordinate exchange of information amongst notified food laboratories

Collaborate for data generation among the network of notified and referral food laboratories and collate the data related to their specific domain

Other functions as may be specified by the Food Authority

51

6.7.3 Vision and Mission of NNRL

6.7.4 Conceptualization of NNRL The concept of setting of NNRL was placed before the Food Authority in its 23rd meeting held

on 25.05.2017. The Authority approved the proposal and accordingly, about 14 National

Reference Laboratories will be set up either on product basis (Milk & Milk Products, Fish & Fish

Products, Meat & Meat Products, Cereal & Cereals Products, Fruit & Vegetables Etc.) or analyte

basis (Pesticide Residue, Mycotoxins, Veterinary Drug Residues including Antibiotics, Heavy

Metals etc.) or combination of both, product and analyte (Veterinary drug residues in fish

products, pesticides in a specific agricultural commodity, food contact surfaces, GMO etc.).

Subsequently, FSSAI invited Expression of Interest (EOI) during November, 2017 from eligible

laboratories to be designated as a National Reference Laboratory. Simultaneously, a Core

Committee comprising of domain experts was constituted. Based on screening of the

applications and presentations made by the shortlisted laboratories before the Core Committee,

15 laboratories were declared as provisional NRLs. Of the 15 provisional NRLs, 13 have been

declared as NRLs after physical assessment of the facilities of provisional NRLs by the Core

Committee during June-July, 2018. Remaining two laboratories viz. Export Inspection Agency,

Kolkata and Export Inspection Agency, Chennai will only act as a support facility but not as an

independent NRL.

VISION

• Ensure that our laboratory system meets the national and international regulatory requirements and obligations;

• Ensure that the laboratory results on which the regulator(s) make decisions are valid and reliable;

• Ensure greater availability of competent laboratories with best practices in line with the global trends; and

• Provide guidance and flexible but consistent solutions for the different stakeholders.

MISSION

• The mission of NNRL will be to set up a country wide standard for routine procedures, reliable testing methods & validation of such standard procedure/testing methods, development of new methods and ensuring proficiency in testing across the food laboratories with special reference to the risks or food categories.

52

The final list of laboratories declared as NRLs for specific area is as follows:

Exhibit 43: Final list of laboratories declared as NRLs for specific area

S.

No.

Name of the Laboratory/

Institution/Organization

Address Specific area for which

declared as NRL

Government Laboratories

1. Central Food

Technological Research

Institute

FS & AQCL Department, CFTRI,

Mysore - 570020

Nutritional information

and labelling

2. Export Inspection Agency 27/1767 A, Shipyard Quarters

Road, Panampilly Nagar (South),

Kochi, Kerala 682036

GMO testing

3. Punjab Biotechnology

Incubator

SCO 7-8, Phase-V, SAS Nagar,

Mohali – 160059, Punjab

Sweets & Confectionary

including Honey

4. ICAR-National Research

Centre For Grapes

P.O. Manjiri Farm, Solapur Road,

Pune - 412307

Pesticides Residues and

Mycotoxins

5. Central Institute of

Fisheries Technology

CIFT Junction, Willingdon Island

Matsyapuri P.O., Kochi - 682029

Fish & Fish Products

6. Centre for Analysis and

Learning in Livestock and

Food - National Dairy

Development Board

Opposite IRMA Main Gate, Near

Anandalaya School, Anand -

388001

Milk & Milk Products

7. CSIR-Indian Institute of

Toxicology Research

Vishvigyan Bhawan, 31,

Mahatama Gandhi Marg,

Lucknow – 226001, Uttar Pradesh

Toxicological evaluation

of nutraceuticals,

functional foods and

novel/emerging foods /

food ingredients

8. NIPHM

Pesticide Management Division,

Rajendranagar, Hyderabad –

500030

Pesticide residue

analysis in fruits &

vegetables, cereals &

pulses, spices and PTP

for the same

Private Laboratories

9. Trilogy Analytical

Laboratory Pvt. Ltd.

Plot No. 7, C.F. Area, Phase-II,

IDA Cherlapally, Hyderabad -

500051

Mycotoxins in cereals &

pulses, spices &

condiments and related

PT activities.

10. Edward Food Research & Subhas Nagar, Barasat P.O., Veterinary drug

53

Analysis Centre Limited

Nikunj Bazar, Kolkata - 700121 residues, antibiotics &

hormones

11. Vimta Labs Limited Life Sciences Campus, 5, MN

Park, Genome Valley,

Shameerpet, Hyderabad - 500101

Water, Alcoholic and

Non-Alcoholic

Beverages

12. Fare Labs Pvt. Ltd.

L-17/3, DLF, Ph – II, IFFCO

Chowk, M.G. Road, Gurugram –

122002

Oils and Fats

13. Neogen Food & Animal

Security (India) Private

Limited

Uchikkal Lane, Poonithura P.O.,

Cochin - 682038

Food Allergens

Source: FSSAI

Following tasks have been assigned to an individual NRL

Ensure availability of adequate analytical methods (confirmatory/arbitration)

Support notified laboratories (PT and Standard Reference Material/Reference Material)

Create quality assurance system for the laboratories in the NRL network

Act as a Centre(s) of excellence in the chosen area

Collaborate with national/international bodies

Offer expert opinion to FSSAI on critical issues

Ensure availability of adequate technical infrastructure and competent staff, especially in case of food safety incidents

54

6.7.5 Obligations of NRL

6.8 Incentivizing States to utilize the facilities available in FSSAI Notified Labs FSSAI has already notified 125 NABL accredited labs under FSS Act, 2006. Utilization of

these labs in the enforcement activities would cut down delays and bring in transparency.

This will also help in reducing burden on Government infrastructure and also bring down

costs. For this purpose, States/UT would be incentivized to meet the cost towards the

testing charges of testing labs as notified by FSSAI. Under this component, a sum of Rs. 10

crore has been earmarked for 3 years.

6.9 School Food & Hygiene Programme FSSAI has already notified 125 NABL accredited labs under FSS Act, 2006. Utilization of

these labs in the enforcement activities would cut down delays and bring in transparency.

Organize annual event/conference for all the NRLs, primary and referral testing laboratories in the area of chosen expertise

Develop standards for routine testing procedures and reliable testing methods

Provide technical support in the area of competence

Acknowledge FSSAI Manuals of Methods of Analysis and publish methods in association with AOAC

Support FSSAI in surveillance activities and risk assessment in the specific areas of expertise of NRL

Hand hold State Food Testing Laboratories including capacity building

Coordinate exchange of information

Collaborate for data generation among the network of notified & referral food laboratories and collate the data related to their specific domain

Be a resource center for provision of information for certified reference materials and reference materials

Undertake any such scientific activity as assigned by the food authority from time to time

55

This will also help in reducing burden on Government infrastructure and also bring down

costs. For this purpose, States/UT would be incentivized to meet the cost towards the

testing charges of testing labs as notified by FSSAI. Under this component, a sum of Rs. 10

crore has been earmarked for 3 years.

6.10 Support for Mobile Food Labs 60 Food Safety on Wheels (FSWs) are also proposed to be provided to the States/UTs.

Mobile food testing laboratories are expected to give consumers in the remote and interior

areas easy access to the facilities for checking the common adulterants in the food items.

Since the food testing laboratories are established only in major cities, there is a difficulty in

testing samples of perishable items from the small towns and villages. Testing for common

adulterants can instil confidence in the local population while strengthening the hands of

enforcement machinery by screening large number of samples for common adulterants. The

available data can then be used to carry out enforcement activity in a targeted manner. The

mobile labs can also be used to transport samples picked from remotes areas to the nearest

food testing laboratory. Education of the consumers in various aspects of food safety laws

and common hygiene practices through the utilization of mobile food testing labs can help

in overall goal of supply of safe and wholesome food to the country. This would not only

address the issue of lack of food testing infrastructure in the remote areas but also cater to

the basic analytical needs of consumers. Apart from testing and training, the FSWs would

also help the regulatory staff or the field functionaries in the States/UTs to enhance their

outreach; and, also help in conducting surveillance activities even in far-flung areas.

FSWs would be utilized for executing the functions of

(i) Surveillance and creating awareness regarding the food safety in remote areas in the

State, large public congregations, schools and consumer organisations;

(ii) Transporting samples picked from remotes areas to the nearest food testing

laboratory;

(iii) Education of the consumers in various aspects of food safety laws and common

hygiene practices;

(iv) On the spot test facilities for qualitative adulteration of common food items like

ghee, milk, khoya, sweets, edible oil, non-permitted food colours in various foods

like namkeens, spices, prepared foods etc.

Under this component, a fully fabricated vehicle (along with equipment) costing around

INR 30 lakh (approx.), excluding GST, are being provided besides a recurring grant of Rs. 5

lakh/year for POL and Consumables for Mobile Lab. So far, 40 FSWs have been sanctioned

to 29 States/UTs out of which 33 FSWs has been delivered to 27 States/UTs. The FSW is

being provided to States/UTs on first-cum-first serve basis, depending upon their readiness.

The State /UT’s are required to provide the following details for having FSW from FSSAI:

(i) Location where FSW is to be sent by FSSAI.

56

(ii) (a) If run by the State, contact details of Nodal person in–charge of FSW.

(b) If run by other than the state/UT governments provide address and contact

details of the organization/ association, contact person and person in-charge of FSW.

(iii) A/c details for transfer of funds towards POL and consumables.

(iv) Confirmation that dedicated manpower is available to operate MFTL, efficiently and

effectively.

6.11 International Training Centre For Food Safety And Applied Nutrition (ITC-

FSAN) FSSAI is creating international level facilities to impart classroom training and hands on

Training on analytical technique. The first one is being created in association with Export

Inspection Council (EIC) and World Bank led Global Food Safety Partnership (GFSP) at EIC’s

pilot test house facility in Mumbai. It is named as the International Training Centre for Food

Safety and Applied Nutrition (ITC-FSAN). The second facility is being created at the FRSL-

Ghaziabad in association with M/s Thermo-Fisher Scientific India Private limited. Both these

world class facilities will not only be critical for scaling the current capacity building activities,

but would also provide a valuable and sustainable resource for development of laboratory

capacity in the region and beyond. This dedicated facility will provide hands-on training to

Indian and International scientists on the best scientific practices and testing methodologies.

Also, these centers would help in creation of a mechanism to share information and best

practices amongst the network of scientific peers on continuous basis.

57

7 Proposed Ranking Matrix for Food Labs In order to motivate the good and earnest labs to keep up the worthy practices followed in food

testing and also to encourage the lesser competent labs to strive towards better business

practices, FSSAI envisages to rank the food testing laboratories operating in India in accordance

to their performance. This ranking matrix, will also help in generating more business through

the FBOs for the more competent and proficient labs. With this objective, a ranking matrix has

been developed in consultation with experts from the food testing domain. The key parameters

of the ranking matrix are as below:

Universe for ranking:: All NABL accredited food labs

The ranking shall be done for each individual lab and not a group/network of labs

S.No

Main Head Sub heads Marks Remarks (if any)

1 Accreditations and Certifications

7 NABL accreditation is compulsory/prerequisite

FSSAI Notified 3

This will increase the interest of NABL accredited labs in getting notified by FSSAI

APEDA/EIC/Both 4

Stringent compliance required, and

hence higher marks 2 Scope of

Testing 15

Chemical 2

Microbiology 3

Residue in food 5

Phenols 0.5

Polyhalogenated Biphenyls 0.5

Halogenated hydrocarbons 0.5

Chlorinated Dioxins & Dibenzofurans

0.5

Polycyclic Aromatic Hydrocarbons

0.5

Polychlorinated Biphenyl 0.5

Antibiotics 0.5

Mycotoxin 0.5

Trace metal elements 0.5

Pesticides 0.5

GMO 3

Drinking Water/Water for food processing

2

3 Product 10 An alternative option for this

58

Testing Capability

segment is appended on page 5 of the document.

Cereals, pulses and products

0.5

Herbs, spices, condiments 0.5

Milk & products 0.5

Edible oils & fats 0.5

Bakery & Confectionery 0.5

Fruit / vegetables and products

0.5

Tea/ coffee/ cocoa products

0.5

Sugar and products 0.5

Beverages (alc/non alc) 0.5

Honey and honey products 0.5

Meat & meat products 0.5

Canned & processed food 0.5

Nuts 0.5

Food additives & preservatives

0.5

Infant food 0.5

Jams juices sauces 0.5

Starch and starch products 0.5

Poultry and poultry products

0.5

Egg & egg product 0.5

Edible colors and flavors 0.5

4 Proficiency testing

18

Number of PT participation in the FY (National)

4 PT number to be considered only by ISO approved PT providers

Score 4 Range for scoring to be created -for eg. (z=<2 score is 5; 2< z < 3 score is 3; for others 0

Scope of PT 4 Number of parameters considered for

PT

Number of PT participation in the FY (International)

2 PT number to be considered only for ISO approved PT providers

Score 2 Range for scoring to be created

Scope of PT 2 Number of parameters considered for

PT

59

5 Equipment availability

10

HPLC 1 Option 2- Can add basic equipment as well with 0.5 marks to each equipment (including spectrophotometer, polarimeter, Colel incubator etc.)

GC MS 1

GC MSMS 2

LC MS 1

LC MSMS 2

ICPMS 1

IRMS 1

HPTLC 1

6 Manpower Availability

10 Detailed matrix submitted separately

to mark this parameter- considering the number, qualification as well as experience of manpower

8 Rejections/ Irregularity notifications

5 Data availability for the same is a question

9 Number of food tests conducted annually

7 Range for scoring based on number

10 Lab on INFOLNET

8 Range for scoring based on fully or partially filled application

11 Lab's performance history

5 Suspended/Not suspended in the past. Suspended-0 marks; not suspended/penal action by any regulatory authority -5 marks

12 Participation in Workshops, Trainings and Skill Development Programs in FY

5 Range for scoring based on number

Total 100

For the calculation of scoring for manpower the following matrix has been prepared- (sample

below). The same has be submitted to FSSAI in excel format

Qualification & Experience

Cap on Weightage

Weightage

Certified Food Analysts (No.)

Microbiologist (No)

Chemist (No)

50% 30% 20%

PhD (10 and above Years)

100% 20% 0 0 1

PhD (5 -10 Years) 12% 1 2 2

PhD (1-5 Years) 10% 0 1 0

60

PhD (0-1 Years) 8% 0 0 0

wt avg

M.Sc (10 and above Years)

50% 8% 3 2 0

M.Sc (5 -10 Years) 6% 3 3 2

M.Sc (1-5 Years) 5% 4 6 4

M.Sc (0-1 Years) 4% 3 5 3

wt avg

B.Sc (10 and above Years)

20% 5% 1 1 0

B.Sc (5 -10 Years) 4% 4 2 2

B.Sc (1-5 Years) 2% 3 2 0

B.Sc (0-1 Years) 1% 0 1 0

Score for B. Sc. Candidates

20% 18% 8%

Score for B. Sc + M. Sc Section

50% 50% 50%

Total Score 62% 84% 94%

Final Weighted Score 75%

Alternative option for calculation of score on product testing capabilities

OPTION 2 Chem Bio Total

61

Cereals, pulses and products 0.25 0.25 0.5

Herbs, spices, condiments 0.25 0.25 0.5

Milk & products 0.25 0.25 0.5

Edible oils & fats 0.25 0.25 0.5

Bakery & Confectionery 0.25 0.25 0.5

Fruit / vegetables and products 0.25 0.25 0.5

Tea/ coffee/ cocoa products 0.25 0.25 0.5

Sugar and products 0.25 0.25 0.5

Beverages (alc/non alc) 0.25 0.25 0.5

Honey and honey products 0.25 0.25 0.5

Meat & meat products 0.25 0.25 0.5

Canned & processed food 0.25 0.25 0.5

Nuts 0.25 0.25 0.5

Food additives & preservatives 0.25 0.25 0.5

Infant food 0.25 0.25 0.5

Jams juices sauces 0.25 0.25 0.5

Starch and starch products 0.25 0.25 0.5

Poultry and poultry products 0.25 0.25 0.5

Egg & egg product 0.25 0.25 0.5

Edible colors and flavors 0.25 0.25 0.5

62

Annexures

List of Stakeholders Consulted S. No.

Name of Stakeholder Category of Stakeholder

Name of Person Designation

1 Edward Food Research & Analysis Centre Limited

FSSAI Notified Satish Poddar CFO

2 Mitra S. K. Private Limited FSSAI Notified Nandita Das Head- Technical

3 SGS India Private Limited FSSAI Notified Sudeb Mandal Head- Labs

4 National Test House (N.W.R.) FSSAI Notified Rakesh Saini Scientist

5 AES Laboratories Pvt. Ltd. FSSAI Notified Vishal Arora Managing Director

6 Arbro Pharmaceuticals Private Limited (Analytical Division)

FSSAI Notified Saurabh Arora Executive Director

7 CEG Test House and Research Centre Pvt. Ltd.

FSSAI Notified Ravindra Jain Executive Director & CEO

8 Choksi Laboratories Limited FSSAI Notified Satish Joshi Director

9 Dove Research & Analytics FSSAI Notified Anil Arya Executive Director

10 EKO PRO Engineers Private Limited (Analytical Division)

FSSAI Notified Amit Saxena Director

11 FAIR Quality Institute (Food Analysis & Industrial Research Quality Institute)

FSSAI Notified D.K. Mishra CEO

12 FICCI Research and Analysis Centre

FSSAI Notified Vivek Parashar Manager- Technical

13 Interstellar Testing Centre Private Limited

FSSAI Notified Ankush Bera Head-Pharma & Drug

14 Intertek India Private Limited (Food Services)

FSSAI Notified Deepak Chaudhary

Food Service Quality Manager

15 National Collateral Management Services Limited-Commgrade- Testing Services Regional Laboratory, (North)

FSSAI Notified Ganesh Ramamurthy

COO

16 Shriram Institute for Industrial Research

FSSAI Notified Laxmi Rawat Senior Asst Director & Chief

17 Accurate Analytic (General Purpose Laboratory)

FSSAI Notified A. Navaneetha Krishnan

Laboratory Manager

18 Eurofins Analytical Services India Pvt. Ltd.

FSSAI Notified Gouri Satpathy Senior Manager

19 First Source Laboratory Solutions LLP. (Analytical Services)

FSSAI Notified Sudhakar Yadlapalli

Vice President

20 FQLab & Research Centre Private Limited

FSSAI Notified B. Jacob CEO

21 Hubert Enviro Care Systems (P) Ltd

FSSAI Notified Rajkumar Samuel Director - Technical

22 Interfield Laboratories FSSAI Notified Joseph Paul Managing Partner

23 Neogen Food and Animal Security (India) Pvt. Ltd.

FSSAI Notified Unnikrishan Director

63

S. No.



24 Robust Materials Technology Pvt.Ltd.

FSSAI Notified K.R. Ravikumar Director & CEO

25 Shiva Analyticals (India) Private Limited

FSSAI Notified Vivekanand Bhat Quality Manager

26 Accurate Laboratory FSSAI Notified Priyesh Amin Technical Manager

27 Analytical & Environmental Services

FSSAI Notified V R Narendra CEO

28 Doctor’s Analytical Laboratories Private Limited,

FSSAI Notified Anand D. Sathe Director - Technical

29 Envirocare Labs Pvt. Ltd. FSSAI Notified Prajakta Kulkarni Manager

30 Equinox Labs Private Limited FSSAI Notified Ashwin Bhadri CEO

31 Gujarat Laboratory FSSAI Notified Hasmukh J Amin CEO

32 Hitech Healthcare Laboratory and Research Centre, Ahmedabad

FSSAI Notified Pavitra Singh Laboratory Manager

33 MAARC Labs Pvt. Ltd. FSSAI Notified V.S. Keskar -

34 Shreeji Analytical & Research Laboratories Pvt. Ltd.

FSSAI Notified Mukesh Naroliya Quality Head

35 Testtex India Laboratories Pvt. Ltd. H.O. & Central Laboratory

FSSAI Notified Meeta Shinghala Managing Director

36 Vimta Labs Limited FSSAI Notified Anuradha V -

37 Central Food Laboratory, Kolkata, West Bengal

State Lab Sarmishta Mukhopadhyay

Food Analyst

38 Public Health Laboratory, Kolkata, West Bengal

State Lab Arup Dutta Gupta

Food Analyst

39 State Food, Drugs and Excise Laboratory,

State Lab Ashok Kumar Public Analyst

40 Combined Food & Drugs Laboratory, New Delhi

State Lab S.M Bhardwaj Food Analyst

41 District Food Laboratory, Haryana State Lab Poonam Mudgil Deputy Public analyst

42 State Food, Water and Excise Laboratory,

State Lab Manisha Bora Public Analyst

43 State Public Health Laboratory, Rajasthan

State Lab Pankaj Kumar Chief Food Analyst

44 Divisional Food Laboratory, Mysore, Karnataka

State Lab Seshagiri Senior Food Analyst

45 Food and Drugs Laboratory, Vadodara, Gujarat

State Lab Vaishali N Patel Joint Director

46 Municipal Laboratory, Mumbai Maharashtra

State Lab - -

47 Public Health Laboratory, Ahmedabad, Gujarat

State Lab Atul S Soni Quality Manager

48 Public Health Laboratory, Vadodara, Gujarat

State Lab G R Gohil Food Analyst

49 State Food Laboratory, Hyderabad, State Lab Lakshmi Narayan Incharge

64

S. No.



Telangana Reddy

50 Regional Food Research & Analysis Centre (RFRAC)

State Lab Jyoti P Mishra/Jamal Siddiqui

Sr. Analyst/Head Administration

51 Central Food Laboratory Referral A. K. Adhikari Director

52 Food Research and Standardization Laboratory, Ghaziabad

Referral Abhay Ekbote Representative (Arbro Pharmaceuticals)

53 Central Institute of Fisheries Technology (CIFT)

Referral Ravishankar Director

54 Indian Institute of Horticulture Research (IIHR)

Referral Debi Sharma Director

55 Centre for Analysis and Learning in Livestock and Food (CALF)

Referral Rajesh Nair Director

56 QEL, Spices Board, Kochi Referral Ramesh BN Scientist

57 Central Food Training & Research Institute

Referral Asha Martin Director

58 Export Inspection Agency – Kolkata Laboratory

Institutional/ Others D Peer Mohamed Asst Director - Technical

59 Export Testing Laboratory (ETL), Bidhan Chandra Krishi Viswavidyalaya

Institutional/ Others Sankhajit Roy Asst Professor

60 Oil Laboratory, Department of Chemical Technology, University of Calcutta

Institutional/ Others Mahua Ghosh Asst Professor

61 National Referral Centre for Milk Quality and Safety

Institutional/ Others Naresh Kumar Principal Scientist - NBFS &QA

62 Project Coordinating Cell, Pesticide Residue Laboratory, All India Network Project on Pesticide Residues

Institutional/ Others K.K. Sharma Principal Scientist & Network Coordinator

63 Export Inspection Agency – Kochi, Laboratory

Institutional/ Others Jayapalan.G Director

64 The Marine Products Export Development Authority, Quality Control Laboratory

Institutional/ Others Suma A Asst Director - Laboratory

65 Indian Institute of Packaging Institutional/ Others Naresh B. Lalwani Deputy Director & Regional Head

66 Central Lab, Innovation Center, Mother Dairy Fruit & Vegetable Pvt. Ltd.

FBO Atanu Haldar Chief R&D officer

67 Dabur Research & Development Centre (Analytical Division)

FBO Ranjan Mitra Head- Analytical Development

68 AMUL- Dudhmotisagar FBO Modi Quality Head

69 Bikanervala Food Pvt Limited FBO Rakesh Gupta DGM-QA

65

S. No.



(Bikano)

70 Perfetti van Melle India Pvt Ltd FBO Upkar Garg Senior Executive, Quality Assurance

71 All India Food Processors Association

FBO DV Malhan -

72 Soyabean Processors Association of India

FBO DN Pathak Executive Director

73 DuPont FBO - -

74 Indian Sugar Mills Association FBO GK Thakur -

75 VKL Seasonings & Flavours FBO Ms. Angeline Laboratory Manager

76 Saraf Foods FBO Suresh Saraf Managing Director

77 Shree Additives (Pharma) & Foods Limited

FBO Shreedhar Poddar Director

78 Schreiber Dynamix Dairies Private Limited

FBO Vijay Jaikhani Team Leader - Quality Assurance

79 S R Thorat Milk Products Pvt Ltd FBO SM Sharma GM - Production

80 SP Chips Private Limited FBO Vishal Patel Director

81 ABS Foods Limited FBO Avadhnaresh Sharma

Managing Director

82 LT Foods FBO Nidhi Arora Sr. Manager

83 Healthkart: Bright Lifecare Pvt Ltd FBO Manoj K Verma Sr. Manager

84 Hector Beverages Pvt Ltd FBO Dipasha Mahendru

General Manager

85 Lazza Foods FBO Simon John Promoter

86 Sam Agritech Ltd FBO Priyatham V CEO

87 Nekkanti Seafoods FBO M. Nagesh CFO

88 Agricultural & Processed Food Products Export Development Authority (APEDA), Delhi

Govt Officials Tarun Bajaj General Manager

89 National Accreditation Board for Testing and Calibration Laboratories (NABL) Delhi

Govt Officials Venkateswaran N Director

90 Food Safety and Standards Authority of India, Delhi

Govt Officials Bhaskar N. Advisor QA

91 Exports Inspection Council, Delhi Govt Officials SK Saxena Director

92 Agricultural & Processed Food Products Export Development Authority (APEDA), Hyderabad

Govt Officials RP Naidu Regional I/c

93 Agricultural & Processed Food Products Export Development Authority (APEDA), Mumbai

Govt Officials Prashant Waghmare

AGM

94 Marine Products Exports Development Authority (MPEDA),

Govt Officials Dr. Naik Director

66

S. No.



Mumbai

95 Waters (India) Govt Officials Shrinivas Joshi AGM Env and Food Market

96 West Bengal Agriculture Marketing Board

Govt Officials Atamika Bharti Director, Agri Marketing

97 Regional Agmark Laboratory Non FSSAI MP Usankar -

98 Analytics India Non FSSAI S.K. Choudhuri CEO

99 N.D. International Non FSSAI K P De / Devashish De

Head- Operations/ Managing Partner

100 Pesticide Residues Laboratory (All India Network Project on Pesticide Residues) Division of Entomology, Rajasthan Agricultural Research Institute (RARI)

Non FSSAI A.R.K. Pathan Professor

101 CATTS Labs & Research Private Limited

Non FSSAI J.S. Chadha Group Chairman

102 LTC Lab - Testing Services, LTC Commercial Company (P) Ltd.

Non FSSAI Manoj Kumar Poonia

Chief Chemist

103 Oasis Test House Limited Non FSSAI Subhash Gupta Director

104 Bangalore Analytical Research Center Private Limited

Non FSSAI Verghese Chacko CEO

105 FSA Laboratories Private Limited Non FSSAI R. Janarthanan Managing Director

106 Gesra Labs India Private Limited Non FSSAI N Gayatri Devi -

107 Hi-Rise Food Tech Lab Non FSSAI Ramya K. CEO

108 Mangalore Biotech Laboratory Non FSSAI R Anand Promoter

109 Parikshan Laboratory Non FSSAI Praveen Andrews Technical Manager

110 Arham Quality Control Laboratory (AQC Labs)

Non FSSAI Ansul Jain Proprietor

111 Parishil Laboratories Private Limited

Non FSSAI Aanal Trivedi -

112 Pious Laboratories Private Limited Non FSSAI Amay Mahajan Quality Manager

113 Quality Services & Solutions (QSS) Non FSSAI Ashish Acharya Manager

114 Vision Labs Non FSSAI T. Lakshmikanth Reddy

CEO

115 Navjyoti Analytics & Research Laboratory

Non FSSAI Harendra Solanki Chief Laboratory Officer

116 Shri Om Testing & Research Laboratory

Non FSSAI RK Sharma Manager

117 Ana Laboratories Non FSSAI Ajay Potdar Quality Manager

118 Pesticide Residue Laboratory, AINP on Pesticide Residues, MPKV, Rahuri

Non FSSAI C. S. Patil Residue Analyst

119 Bangalore Testing Laboratories Pvt. Ltd., Bengaluru now named as

Non FSSAI - -

67

S. No.



Merieux Nutrisciences Pvt Ltd (French)

120 Apex Assessment Labs Private Limited

Non FSSAI Avnish Kumar -

Documents

Metastudy on food testing laboratories in india