FSSAI should be fair and unaffected by the same food industry it has to control and regulate
FSSAI should be fair and unaffected by the same food industry it has to control and regulate
In science and academia, the search for truth is the main driving force for progress. Arrogance and stubbornness are stumbling blocks. When it comes to policy making regarding the health and safety of millions of people in India, it must be guided by the hard evidence generated from science and systematic research.
Interview, “Expert panel to study star rating: FSSAI CEO” ( Hindu, Inside Page, May 6, 2022), with Arun Singhal, CEO, Food Safety and Standards Authority of India (FSSAI), shows a different story. FSSAI is a regulator on healthy and safe food items produced in the country, constituted by the government for the people and funded with taxpayers money. It should be fair and unaffected by the same food industry that it has to control and regulate.
“Six rounds of stakeholder consultations have already been conducted” – a line in the interview – if pending issues are still to be resolved, do not exempt FSSAI from any further consultations. Unresolved issues may require more consultation with new evidence generated. If consulting dominates the industry, how can consumer interests be adequately protected? Classification of foods as healthy or unhealthy is a technical or professional step. It should be decided by a governing body like FSSAI or food and nutrition experts or professionals. Not by the food industry or manufacturers.
have health concerns
What is our concern? Consumption of junk foods high in calories, sugar, fat and salt leads to early onset of obesity in adolescents, insulin deficiency, and results in diabetes, high blood pressure, heart and kidney diseases in adulthood. We need to reduce the production, marketing and availability of such unhealthy foods and if available, change consumer behavior in buying such processed food by giving proper warning of their contents using labels on packets. We appeal to their reasoned and responsible decision making to prevent them from buying dangerous food items.
The World Health Organization (WHO) has issued a limit for sugar, salt, fat and calories per 100 grams of packaged processed foods or bottled liquid beverages. Until we generate competitive technical data for the Indian population, we have to follow WHO norms. A technical group set up by FSSAI has evaluated processed food items on racks of Indian supermarkets and found that 96% of products for one ingredient and 62.8% of products for three components are above WHO limits. We cannot relax the thresholds as per the industry but the industry should change its structure to a healthy extent. FSSAI should ensure this.
Any order or direction issued in public interest should be mandatory from day one. As Mr. Singhal suggested, we may not have the flexibility of voluntary adoption and staggered implementation. The regulator cannot give various untenable excuses on the part of food producers for not enforcing its own terms. It is a complete abandonment of his power and purpose. There is no point in allowing voluntarily adopting the rules, and if a person does not subsequently adopt the regulation, relaxing the norms. Will one allow voluntarily adopting to wear a helmet while driving a two wheeler or locking a seat belt while driving a four wheeler over a long period of time and then agree to relaxation of norms if compliance is poor? Is this the way the regulator works?
No one denies that the Indian Institute of Management Ahmedabad – mentioned in interviews to conduct a consumer survey involving 20,500 people – is a reputed institution. Similarly there are other IIMs of the country, Indian Council of Medical Research, International Institute of Population Sciences, All India Institute of Medical Sciences, National Institute of Nutrition Hyderabad. Was he invited and given a chance to bid for such a huge costly study? A minimum of three bids are required to be requested in the Financial Regulations.
on package labeling
So how to do Front Package Labeling (FOPL)? Is it in the ways of Multiple Traffic Lights (MTL), Monochrome GDA, Nutri-Score, Warning Labels and Health Star Rating (HSR)? If the purpose of the study is to find out “what type of FOPL is most perceptible, acceptable and yet effective in influencing purchase intentions”, then the methodology should serve that objective, providing crystallized information in the best acceptable manner. It would be ideal to do for consumption and leave it open for the consumer to decide. We’ve done it with tobacco packs and wine bottles.
Study participants should have the ability to objectively evaluate different forms of FOPL based on the information content. They should have the ability to compare and identify the least harmful, or more material than recommended. Why do we take the opinion of the consumer who is not knowledgeable or illiterate? it is pointless.
The methodology states that the respondent’s profile is captured after the respondent makes a choice rating of the FOPL. There should be some tools to assess the basic level of understanding and then decide whether to include or exclude the participant from the study. There is no exclusion and inclusion criteria based on the profile of the respondent prior to conducting an opinion poll.
The authors acknowledge in this study that 13.8% of respondents have no schooling at all or are illiterate, while 28%-35% of respondents are those who never read food labels. Therefore, they should have been excluded from making relative comparisons between labels in this study. Can anyone ever ask a teetotaler their opinion about the relative merits of three comparable brands of whiskey?
children have been abandoned
Also, excluding young adolescent children aged 10-18 years – who are major consumers of packaged biscuit chips and bottled soft drinks – from the study is a major methodological error. This is a case of critical missing data.
The “priming of the defendant” methodology is an unnecessary step with questionable benefit. This complicates study design with multiple levels of stratification and leads to no conclusive conclusions. Unfortunately, no solid policy guideline tips can be drawn from the findings of this detailed costly study because it contains many avoidable methodological errors.
The FSSAI cannot proceed with a draft regulation based on a highly controversial study design and whose findings have not yet been reviewed. As a front of pack labeling, the decision to stick to Health Star ratings based only on algorithms known to the food industry is without sound reasoning or evidence.
Dr KR Antony is a Pediatrician in Kochi, an independent Monitor, former Director of National Health Mission and State Health Resource Centre, Chhattisgarh.