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FEBRUARY 18, 2019

METASTUDY ON FOOD TESTING


LABORATORIES IN INDIA

FOOD AND AGRIBUSINESS STARTEGIC ADVISORY & RESEARCH (FASAR)


YES BANK LIMITED
NEW DELHI
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:

172 19 88

FSSAI Notified Referral


State Laboratories
Laboratories Laboratories

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.

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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 Includes NABL accredited labs, FSSAI notified Labs,
in India ~ 915 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 - • ~462 Labs
NABL Accredited
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

9
Notified 265 Referral
Labs Labs

1
159 17
1
11
State Labs
76

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

FSSAI/
Referral*

41 37
16

MoFPI APEDA
Assisted 11 9 18 Recognized

11 9 18

EIC Recognized

Source: NABL, EIA, MoFPI, APEDA, FSSAI

1.3 NABL Accredited Laboratories


Exhibit 4: Institutional Breakup of NABL Accredited Labs

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There are around 462 NABL
accredited laboratories for food and NABL Labs: Institutional Breakup

food products in India (As of Sept 1,


3%
2018 NABL data). This universe 9%
Private Labs
consists of laboratories across all 11%
states in India, which are open to Institutional Labs

testing for others, partially open to Labs owned by FBOs


14%
others or are in house laboratories. 63%
Government Labs
These food testing laboratories are
State Labs
either owned by the private sector
(majorly as a food testing business
Source: NABL, YBL Analysis
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%.

Large Corporates 20%


Total Food
Processing
Industry
MSME 80%

10%
Exhibit 5: NABL Accredited Testing Facilities by FBOs
Interestingly few of these large corporates 38%
have established their own laboratories,
some of which are state of the art and
52%
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In house Open to Others Partially open to others


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

12
REGIONAL DISTRIBUTION OF ALL
FOOD TESTING LABS~600 Labs

North 30%

East 10%
West 27%

South 34%

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

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

Regional distribution of NABL food testing Regional distribution of FSSAI food testing
labs labs
East East
7% 5%
South South
West West 37%
36% 28%
29%

North North
28% 30%

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

13
South Zone
78%
9% 1%
Tamil Nadu

12% Kerala
36%
Karnataka
Telangana
21% Andhra Pradesh
Pondichery
21%

Source: NABL, YBL Analysis

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

North Zone
2% 3% 79%
New Delhi
4%
20% Uttar Pradesh
12%
Haryana
Rajasthan
19% 21% Punjab
Himachal Pradesh
19% Jammu & Kashmir

Source: NABL, YBL Analysis

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

14
West Zone

85%
3% 1%
12% Maharashtra
Gujarat
Madhya Pradesh
26% 58%
Goa
Daman

Source: NABL, YBL Analysis

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

East Zone
West Bengal
3% 2% Odisha 69%
2% 2% Assam
2% Chhattisgarh
3% Jharkhand
3%
4% Andaman & Nicobar
Bihar
5%
Manipur
5% 55% Meghalaya
7% Mizoram
Nagaland
7% Tripura
Sikkim

Source: NABL, YBL Analysis

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

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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

16
Region Wise Testing Abilities of Food Testing Labs in India (~462 labs)

150
Food and Agri products 117
30 122
~ 419 Labs
53
Pesicide Residue 42
46
7
~ 148 Labs
41
Marine/Aquaculture 8
13
4
~ 66 Labs
4
Nutraceticals & Functional Foods 5
7
~ 17 Labs 1
3
GM Products 2
4
~9 Labs 0

South North West East

Source: NABL, YBL Analysis

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
414

241 236

56
23 13 15 6 4

Food and Agri products Marine/Aquaculture Nutraceticals & Functional Foods

Chemical Biological Both

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

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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
300
250
200
150
100
50
0

Chemical Micro Biological

Source: NABL, YBL Analysis

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

Pesticides 104
Mycotoxin 44
Antibiotics 41
Polychlorinated Biphenyl 15
Polycyclic Aromatic Hydrocarbons 14
Halogenated ydrocarbons 12
Chlorinated Dioxins & Dibenzofurans 12
Polyhalogenated Biphenyls 8
Phenols 6
Source: NABL, YBL Analysis

18
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.

14
Exhibit 16: Testing Infrastructure Mapping against Production and Processing for Cereals
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%
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

15
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
Top 10 states as a %
India's total 84% 50% 70%
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
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
Top 10 states as a %
India's total 93% 78% 70%
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

16
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
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
Madhya Pradesh 850 0.1 1 850
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
Uttar Pradesh 301 1.42 3 100
Himachal Pradesh 283 0.47 1 283
India 7277 7.02 105 69
Top 10 states as a %
India's total 82% 70% 58%
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.
Evaluating the number of food processing units catered to by the food testing laboratories, it is
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

17
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
Top 10 states as a %
India's total 100% 80% 74%
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.
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 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
Oil Processing (No. of units) Production (Mn MT) Testing Infra for edible oil FBO/Lab
Tamil Nadu 2537 0.92 25 101
Uttar Pradesh 1372 0.86 9 152
Rajasthan 1241 5.71 15 83
Kerala 978 0.001 17 58
Maharashtra 874 2.4 33 26
Madhya Pradesh 766 6.2 12 64
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
Top 10 states as a %
India's total 86% 90% 79%
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

18
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
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
Top 10 states as a %
India's total 94% 97% 70%
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.

19
 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
Average
Total Number of
testing Surplus/Deficit Number of
Samples to NABL Labs
capacity per in testing labs required
Zone FBOs be tested in open to others
year for all capacity (in @ 100 %
a year (in for testing
labs (in Lakh) compliance
lakh)
Lakh)
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

20
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 Lab requirement Lab requirement Lab requirement @ Lab requirement
requirement @ @ 20% compliance @ 50% compliance 80% compliance @ 100%
5% compliance 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
Source: FSSAI, YBL analysis
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

312

221 210

Lab requirement 145


130
@ 50%
98 91
84
Lab requirement
Lab 51 47 49
@ 20%
requirement @ 4

-20 -13 Lab Lab


-51 -52 requirement requirement
-76
-99 @ 100%
-107
-121
East West South North

Source: FSSAI, YBL analysis

21
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:
Exhibit 27: Theoretical gap in demand and supply of food testing labs in India
Average Surplus/Deficit
Total Number of
testing in testing Number of
Samples to NABL Labs
capacity per capacity (in labs required
Zone FBOs be tested in open to others
year for all Lakh) @ 100 %
a year (in for testing
labs (in compliance
lakh)
Lakh)
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:
Exhibit 29: Theoretical gap in demand and supply of food testing labs in India
Lab Lab requirement
Lab requirement Lab requirement Lab requirement @
requirement @ @ 100%
@ 20% compliance @ 50% compliance 80% compliance
5% compliance compliance
East -20 4 51 98 130
West -99 -51 47 145 210
South -121 -52 84 221 312

22
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
350
300
250
200
150
100 Lab Lab requirement
50 requirement @ @ 20%
5% compliance compliance
0
-50 Lab
Lab requirement @ Lab
requirement @
-100 50% compliance requirement
80% compliance
-150 @ 100%
compliance
East West South North

Source: FSSAI, YBL analysis

23
4 Primary Survey – Key Findings
4.1 Stakeholder Coverage
 For the purview of this study, a detailed sampling Sr.
plan was formulated in consultation with FSSAI Type of Lab
No.
covering all kinds of food testing labs across
multiple states and UTs in India. 1 Private Lab - FSSAI Notified
 The major categories of labs considered during the FBO (with or without Food
2
field survey exercise is enlisted in the table beside Testing Lab)
 In addition to food testing labs, key qualitative 3 State Labs
insights were also sought from government officials
related to food testing was also sought 4 Non FSSAI Labs
 The sampling plan for this study covering 120
5 Institutional
stakeholders is tabulated below:
6 Referral Labs
Exhibit 31: Sampling plan for Primary Survey

Zone/ FSSAI State Referral Non FBO Institutional/ Govt Total


Categori Notified Lab* FSSAI (with or without Others Officials
es labs)
North 6 1 7 12 3 5 47
13
East 2 1 3 - 3 1 13
3
West 4 1 7 6 - 2 31
11
South 2 4 8 4 4 1 32
9
Sub
36 14 7 24 22 8 9 120
Total
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

7%
Private Lab - FSSAI Notified
8%
FBO with Food Testing Lab
38%
State Labs
25% Non FSSAI Labs
Institutional
7% Referral Labs
15%

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.

24
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. Type Of Particulars


No. Accreditation
1 National  The National Accreditation Board for Testing and Calibration
Accreditation Laboratories (NABL) undertakes the assessment and accreditation of
Board for Testing and Calibration Laboratories, in accordance with the
Testing and international standard ISO / IEC 17025 and ISO 15189.
Calibration  Accreditation areas include: Testing & Calibration
Laboratories - Testing: Biological, Chemical, Electrical, Electronics, Fluid-Flow,
(NABL) 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  FSSAI Notified NABL Accredited Food Testing Laboratories valid for
Notified the purposes of carrying out Analysis of Samples Taken under Section
47of the Food Safety and Standard Act, 2006.
3 EIC  The Export Inspection Council (EIC) is the official export inspection
Approved 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

25
Sr. Type Of Particulars
No. Accreditation
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  Authorized labs for sampling and analysis of agro products being
Recognized 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 FSSAI EIC APEDA MoFPI
Accredited Notified approved recognized 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

26
 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.

Exhibit 34: Accreditations of labs covered under primary survey

78%

57%

11% 13% 14%

NABL FSSAI Notified EIC Approved APEDA recognised MOFPI assisted

Source: Primary Survey & Yes Bank Analysis

27
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  Trace chemicals, especially pesticides, easily find their way into
e the food cycle, affecting the health of consumers and disturbing
the ecosystem in general

28
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.
Exhibit 35: Accreditations of labs covered under primary survey
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

100% 100%
94% 100% 100% 100%
94% 93%
86% 86%
69%
71%
57% 50%
58% 57% 54%
50%
43%

29% 25%
17%
14% 17%

Private Lab - FBO with Food State Labs Non FSSAI Labs Institutional Referral Labs
FSSAI Notified Testing Lab

Chemical Biological Mechanical Pesticide/Residue

Source: Primary Survey & Yes Bank Analysis

29
 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.

30
 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
50% 50%
moved to food testing owing to
business opportunities and similarity in
testing methods and equipment.
 The major sectors in which labs
Labs doing testing in other sectors
were found to be involved in testing
are: Labs doing only food testing

o Pharmaceutical & environmental testing


o Petroleum & Chemical products Source: Primary Survey & Yes Bank Analysis

o Cosmetics & AYUSH


o Packaged Drinking Water

31
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

Equipment Availability
86% 86%

71% 75%
71% 71%

58% 58% 58%


56%
50% 29% 50%
47%
43%
38% 38%
29%
25%
29% 29% 29% 29% 29%
17%
19%
17%
14% 14% 14% 14%

4% 4% 4%
0% 0%

GCMS GCMSMS LCMS LCMSMS ICPMS IRMS

Private Lab - FSSAI Notified FBO with Food Testing Lab State Labs
Non FSSAI Labs Institutional Referral Labs

Source: Primary Survey & Yes Bank Analysis


 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

32
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
14

10
8 8
6
4

Non FSSAI Labs FBO with Food Referral Labs Private Lab - State Labs Institutional
Testing Lab FSSAI notified

TAT (in days)

Source: Primary Survey & Yes Bank Analysis

33
 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

Referral Labs 52%


Institutional 57%
Non FSSAI Labs 56%
State Labs 84%
FBO with Food Testing Lab 72%
Private Lab - FSSAI Notified 46%
51%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Capacity Utilisation (%)

Source: Primary Survey & Yes Bank Analysis

34
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

30
23
15 13
11 10
9 7
6 6 4
4 3 3 2 0
1 0 0 1 1 1 1 0

Private Lab - FBO with Food State Labs Non FSSAI Labs Institutional Referral Labs
FSSAI Notified Testing Lab

Chemist Microbiologist Food Analyst Non Technical Staff

Source: Primary Survey & Yes Bank Analysis

 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.

35
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.

36
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

37
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.

38
• 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

39
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

40
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

41
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.

42
 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

43
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 Exhibit 41: Status of Food Safety on Wheels Initiative by FSSAI
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
States where 1 FSW have been

businesses, particularly petty food sanctioned/ delivered/ MoU signed

States where 1 FSW have been


businesses. In addition, these mobile sanctioned/ delivered/ MoU Signed

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 Source: FSSAI
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.

44
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

45
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

46
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).

Upgradation MicroBio Labs MicroBio Labs Grant in Aid

Proposals for
Rs.111.95 crore
setting up of 14
28 State Food Setting up 7 has been
microbiology
Safety microbiology sanctioned out of
laboratories in 14
Laboratories of laboratories in 6 which 108.45
States/UTs are
25 States/UTs States/UTs crore has been
under
released
consideration

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

47
451

143 143

16

Master Training Training of Awareness Good Food Lab


Program Trainers program for Practices
Accreditation of
laboratories by
NABL

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.

Total Samples to Survey Collected


Coverage Tested Samples
be Collected Components Samples

Fat, SNF, 13
2800 130 Cities 513 409
Adulterants

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.

48
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

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

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

49
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

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.

50
6.7.3 Vision and Mission of NNRL
VISION MISSION
• Ensure that our laboratory system • The mission of NNRL will be to set up
meets the national and international a country wide standard for routine
regulatory requirements and procedures, reliable testing methods &
obligations; validation of such standard
• Ensure that the laboratory results on procedure/testing methods,
which the regulator(s) make decisions development of new methods and
are valid and reliable; ensuring proficiency in testing across
• Ensure greater availability of the food laboratories with special
competent laboratories with best reference to the risks or food
practices in line with the global trends; categories.
and
• Provide guidance and flexible but
consistent solutions for the different
stakeholders.

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.

51
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. Name of the Laboratory/ Address Specific area for which


No. Institution/Organization declared as NRL
Government Laboratories
1. Central Food FS & AQCL Department, CFTRI, Nutritional information
Technological Research Mysore - 570020 and labelling
Institute
2. Export Inspection Agency 27/1767 A, Shipyard Quarters GMO testing
Road, Panampilly Nagar (South),
Kochi, Kerala 682036
3. Punjab Biotechnology SCO 7-8, Phase-V, SAS Nagar, Sweets & Confectionary
Incubator Mohali – 160059, Punjab including Honey
4. ICAR-National Research P.O. Manjiri Farm, Solapur Road, Pesticides Residues and
Centre For Grapes Pune - 412307 Mycotoxins

5. Central Institute of CIFT Junction, Willingdon Island Fish & Fish Products
Fisheries Technology Matsyapuri P.O., Kochi - 682029
6. Centre for Analysis and Opposite IRMA Main Gate, Near Milk & Milk Products
Learning in Livestock and Anandalaya School, Anand -
Food - National Dairy 388001
Development Board
7. CSIR-Indian Institute of Vishvigyan Bhawan, 31, Toxicological evaluation
Toxicology Research Mahatama Gandhi Marg, of nutraceuticals,
Lucknow – 226001, Uttar Pradesh functional foods and
novel/emerging foods /
food ingredients
8. NIPHM Pesticide Management Division, Pesticide residue
Rajendranagar, Hyderabad – analysis in fruits &
500030 vegetables, cereals &
pulses, spices and PTP
for the same
Private Laboratories
9. Trilogy Analytical Plot No. 7, C.F. Area, Phase-II, Mycotoxins in cereals &
Laboratory Pvt. Ltd. IDA Cherlapally, Hyderabad - pulses, spices &
500051 condiments and related
PT activities.
10. Edward Food Research & Subhas Nagar, Barasat P.O., Veterinary drug

52
Analysis Centre Limited Nikunj Bazar, Kolkata - 700121 residues, antibiotics &
hormones
11. Vimta Labs Limited Life Sciences Campus, 5, MN Water, Alcoholic and
Park, Genome Valley, Non-Alcoholic
Shameerpet, Hyderabad - 500101 Beverages
12. Fare Labs Pvt. Ltd. L-17/3, DLF, Ph – II, IFFCO Oils and Fats
Chowk, M.G. Road, Gurugram –
122002

13. Neogen Food & Animal Uchikkal Lane, Poonithura P.O., Food Allergens
Security (India) Private Cochin - 682038
Limited
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

53
6.7.5 Obligations of NRL
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

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.

54
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.

55
(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.

56
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.N Main Head Sub heads Marks Remarks (if any)


o
1 Accreditatio 7 NABL accreditation is
ns and compulsory/prerequisite
Certification
s
This will increase the interest of NABL
FSSAI Notified 3 accredited labs in getting notified by
FSSAI
Stringent compliance required, and
APEDA/EIC/Both 4
hence higher marks
2 Scope of 15
Testing
Chemical 2
Microbiology 3
Residue in food 5
Phenols 0.5
Polyhalogenated Biphenyls 0.5
Halogenated hydrocarbons 0.5
Chlorinated Dioxins &
0.5
Dibenzofurans
Polycyclic Aromatic
0.5
Hydrocarbons
Polychlorinated Biphenyl 0.5
Antibiotics 0.5
Mycotoxin 0.5
Trace metal elements 0.5
Pesticides 0.5
GMO 3
Drinking Water/Water for
2
food processing
3 Product 10 An alternative option for this

57
Testing segment is appended on page 5 of
Capability the document.
Cereals, pulses and 0.5
products
Herbs, spices, condiments 0.5
Milk & products 0.5
Edible oils & fats 0.5
Bakery & Confectionery 0.5
Fruit / vegetables and 0.5
products
Tea/ coffee/ cocoa 0.5
products
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 & 0.5
preservatives
Infant food 0.5
Jams juices sauces 0.5
Starch and starch products 0.5
Poultry and poultry 0.5
products
Egg & egg product 0.5
Edible colors and flavors 0.5
4 Proficiency 18
testing
Number of PT 4 PT number to be considered only by
participation in the FY ISO approved PT providers
(National)
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 2 PT number to be considered only for
participation in the FY ISO approved PT providers
(International)
Score 2 Range for scoring to be created
Scope of PT 2 Number of parameters considered for
PT

58
5 Equipment 10
availability
HPLC 1 Option 2- Can add basic equipment as
well with 0.5 marks to each equipment
GC MS 1 (including spectrophotometer,
GC MSMS 2 polarimeter, Colel incubator etc.)
LC MS 1
LC MSMS 2
ICPMS 1
IRMS 1
HPTLC 1
6 Manpower 10 Detailed matrix submitted separately
Availability to mark this parameter- considering
the number, qualification as well as
experience of manpower
8 Rejections/ 5 Data availability for the same is a
Irregularity question
notifications
9 Number of 7 Range for scoring based on number
food tests
conducted
annually
10 Lab on 8 Range for scoring based on fully or
INFOLNET partially filled application

11 Lab's 5 Suspended/Not suspended in the


performance past. Suspended-0 marks; not
history suspended/penal action by any
regulatory authority -5 marks
12 Participatio 5 Range for scoring based on number
n in
Workshops,
Trainings
and Skill
Developme
nt Programs
in FY
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 & Cap on Weight Certified Food Microbiologist Chemist


Experience Weightage age Analysts (No.) (No) (No)
50% 30% 20%
PhD (10 and above 100% 20% 0 0 1
Years)
PhD (5 -10 Years) 12% 1 2 2
PhD (1-5 Years) 10% 0 1 0

59
PhD (0-1 Years) 8% 0 0 0

wt avg
M.Sc (10 and above 50% 8% 3 2 0
Years)
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 20% 5% 1 1 0
Years)
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. 20% 18% 8%


Candidates
Score for B. Sc + M. Sc 50% 50% 50%
Section
Total Score 62% 84% 94%

Final Weighted Score 75%

Alternative option for calculation of score on product testing capabilities

OPTION 2 Chem Bio Total

60
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

61
Annexures
List of Stakeholders Consulted
S. Name of Stakeholder Category of Name of Person Designation
No. Stakeholder
1 Edward Food Research & Analysis FSSAI Notified Satish Poddar CFO
Centre Limited
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 FSSAI Notified Saurabh Arora Executive Director
Limited (Analytical Division)
7 CEG Test House and Research FSSAI Notified Ravindra Jain Executive Director &
Centre Pvt. Ltd. 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 FSSAI Notified Amit Saxena Director
Limited (Analytical Division)
11 FAIR Quality Institute (Food FSSAI Notified D.K. Mishra CEO
Analysis & Industrial Research
Quality Institute)
12 FICCI Research and Analysis FSSAI Notified Vivek Parashar Manager- Technical
Centre
13 Interstellar Testing Centre Private FSSAI Notified Ankush Bera Head-Pharma &
Limited Drug
14 Intertek India Private Limited FSSAI Notified Deepak Food Service
(Food Services) Chaudhary Quality Manager
15 National Collateral Management FSSAI Notified Ganesh COO
Services Limited-Commgrade- Ramamurthy
Testing Services Regional
Laboratory, (North)
16 Shriram Institute for Industrial FSSAI Notified Laxmi Rawat Senior Asst Director
Research & Chief
17 Accurate Analytic (General FSSAI Notified A. Navaneetha Laboratory Manager
Purpose Laboratory) Krishnan
18 Eurofins Analytical Services India FSSAI Notified Gouri Satpathy Senior Manager
Pvt. Ltd.
19 First Source Laboratory Solutions FSSAI Notified Sudhakar Vice President
LLP. (Analytical Services) Yadlapalli
20 FQLab & Research Centre Private FSSAI Notified B. Jacob CEO
Limited
21 Hubert Enviro Care Systems (P) FSSAI Notified Rajkumar Samuel Director - Technical
Ltd
22 Interfield Laboratories FSSAI Notified Joseph Paul Managing Partner
23 Neogen Food and Animal Security FSSAI Notified Unnikrishan Director
(India) Pvt. Ltd.

62
S. Name of Stakeholder Category of Name of Person Designation
No. Stakeholder
24 Robust Materials Technology FSSAI Notified K.R. Ravikumar Director & CEO
Pvt.Ltd.
25 Shiva Analyticals (India) Private FSSAI Notified Vivekanand Bhat Quality Manager
Limited
26 Accurate Laboratory FSSAI Notified Priyesh Amin Technical Manager
27 Analytical & Environmental FSSAI Notified V R Narendra CEO
Services
28 Doctor’s Analytical Laboratories FSSAI Notified Anand D. Sathe Director - Technical
Private Limited,
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 FSSAI Notified Pavitra Singh Laboratory Manager
Research Centre, Ahmedabad
33 MAARC Labs Pvt. Ltd. FSSAI Notified V.S. Keskar -
34 Shreeji Analytical & Research FSSAI Notified Mukesh Naroliya Quality Head
Laboratories Pvt. Ltd.
35 Testtex India Laboratories Pvt. Ltd. FSSAI Notified Meeta Shinghala Managing Director
H.O. & Central Laboratory
36 Vimta Labs Limited FSSAI Notified Anuradha V -
37 Central Food Laboratory, Kolkata, State Lab Sarmishta Food Analyst
West Bengal Mukhopadhyay
38 Public Health Laboratory, Kolkata, State Lab Arup Dutta Food Analyst
West Bengal Gupta
39 State Food, Drugs and Excise State Lab Ashok Kumar Public Analyst
Laboratory,
40 Combined Food & Drugs State Lab S.M Bhardwaj Food Analyst
Laboratory, New Delhi
41 District Food Laboratory, Haryana State Lab Poonam Mudgil Deputy Public
analyst
42 State Food, Water and Excise State Lab Manisha Bora Public Analyst
Laboratory,
43 State Public Health Laboratory, State Lab Pankaj Kumar Chief Food Analyst
Rajasthan
44 Divisional Food Laboratory, State Lab Seshagiri Senior Food Analyst
Mysore, Karnataka
45 Food and Drugs Laboratory, State Lab Vaishali N Patel Joint Director
Vadodara, Gujarat
46 Municipal Laboratory, Mumbai State Lab - -
Maharashtra
47 Public Health Laboratory, State Lab Atul S Soni Quality Manager
Ahmedabad, Gujarat
48 Public Health Laboratory, State Lab G R Gohil Food Analyst
Vadodara, Gujarat
49 State Food Laboratory, Hyderabad, State Lab Lakshmi Narayan Incharge

63
S. Name of Stakeholder Category of Name of Person Designation
No. Stakeholder
Telangana Reddy
50 Regional Food Research & State Lab Jyoti P Sr. Analyst/Head
Analysis Centre (RFRAC) Mishra/Jamal Administration
Siddiqui
51 Central Food Laboratory Referral A. K. Adhikari Director
52 Food Research and Referral Abhay Ekbote Representative
Standardization Laboratory, (Arbro
Ghaziabad Pharmaceuticals)
53 Central Institute of Fisheries Referral Ravishankar Director
Technology (CIFT)
54 Indian Institute of Horticulture Referral Debi Sharma Director
Research (IIHR)
55 Centre for Analysis and Learning Referral Rajesh Nair Director
in Livestock and Food (CALF)
56 QEL, Spices Board, Kochi Referral Ramesh BN Scientist
57 Central Food Training & Research Referral Asha Martin Director
Institute
58 Export Inspection Agency – Institutional/ Others D Peer Mohamed Asst Director -
Kolkata Laboratory Technical
59 Export Testing Laboratory (ETL), Institutional/ Others Sankhajit Roy Asst Professor
Bidhan Chandra Krishi
Viswavidyalaya
60 Oil Laboratory, Department of Institutional/ Others Mahua Ghosh Asst Professor
Chemical Technology, University
of Calcutta
61 National Referral Centre for Milk Institutional/ Others Naresh Kumar Principal Scientist -
Quality and Safety NBFS &QA
62 Project Coordinating Cell, Institutional/ Others K.K. Sharma Principal Scientist &
Pesticide Residue Laboratory, All Network
India Network Project on Pesticide Coordinator
Residues
63 Export Inspection Agency – Kochi, Institutional/ Others Jayapalan.G Director
Laboratory
64 The Marine Products Export Institutional/ Others Suma A Asst Director -
Development Authority, Quality Laboratory
Control Laboratory
65 Indian Institute of Packaging Institutional/ Others Naresh B. Lalwani Deputy Director &
Regional Head
66 Central Lab, Innovation Center, FBO Atanu Haldar Chief R&D officer
Mother Dairy Fruit & Vegetable
Pvt. Ltd.
67 Dabur Research & Development FBO Ranjan Mitra Head- Analytical
Centre (Analytical Division) Development
68 AMUL- Dudhmotisagar FBO Modi Quality Head
69 Bikanervala Food Pvt Limited FBO Rakesh Gupta DGM-QA

64
S. Name of Stakeholder Category of Name of Person Designation
No. Stakeholder
(Bikano)
70 Perfetti van Melle India Pvt Ltd FBO Upkar Garg Senior Executive,
Quality Assurance
71 All India Food Processors FBO DV Malhan -
Association
72 Soyabean Processors Association FBO DN Pathak Executive Director
of India
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 FBO Shreedhar Poddar Director
Limited
78 Schreiber Dynamix Dairies Private FBO Vijay Jaikhani Team Leader -
Limited 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 Managing Director
Sharma
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 General Manager
Mahendru
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 Govt Officials Tarun Bajaj General Manager
Products Export Development
Authority (APEDA), Delhi
89 National Accreditation Board for Govt Officials Venkateswaran N Director
Testing and Calibration
Laboratories (NABL) Delhi
90 Food Safety and Standards Govt Officials Bhaskar N. Advisor QA
Authority of India, Delhi
91 Exports Inspection Council, Delhi Govt Officials SK Saxena Director
92 Agricultural & Processed Food Govt Officials RP Naidu Regional I/c
Products Export Development
Authority (APEDA), Hyderabad
93 Agricultural & Processed Food Govt Officials Prashant AGM
Products Export Development Waghmare
Authority (APEDA), Mumbai
94 Marine Products Exports Govt Officials Dr. Naik Director
Development Authority (MPEDA),

65
S. Name of Stakeholder Category of Name of Person Designation
No. Stakeholder
Mumbai
95 Waters (India) Govt Officials Shrinivas Joshi AGM Env and Food
Market
96 West Bengal Agriculture Govt Officials Atamika Bharti Director, Agri
Marketing Board 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 / Head- Operations/
Devashish De Managing Partner
100 Pesticide Residues Laboratory (All Non FSSAI A.R.K. Pathan Professor
India Network Project on Pesticide
Residues) Division of Entomology,
Rajasthan Agricultural Research
Institute (RARI)
101 CATTS Labs & Research Private Non FSSAI J.S. Chadha Group Chairman
Limited
102 LTC Lab - Testing Services, LTC Non FSSAI Manoj Kumar Chief Chemist
Commercial Company (P) Ltd. Poonia
103 Oasis Test House Limited Non FSSAI Subhash Gupta Director
104 Bangalore Analytical Research Non FSSAI Verghese Chacko CEO
Center Private Limited
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 Non FSSAI Ansul Jain Proprietor
(AQC Labs)
111 Parishil Laboratories Private Non FSSAI Aanal Trivedi -
Limited
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 CEO
Reddy
115 Navjyoti Analytics & Research Non FSSAI Harendra Solanki Chief Laboratory
Laboratory Officer
116 Shri Om Testing & Research Non FSSAI RK Sharma Manager
Laboratory
117 Ana Laboratories Non FSSAI Ajay Potdar Quality Manager
118 Pesticide Residue Laboratory, Non FSSAI C. S. Patil Residue Analyst
AINP on Pesticide Residues,
MPKV, Rahuri
119 Bangalore Testing Laboratories Non FSSAI - -
Pvt. Ltd., Bengaluru now named as

66
S. Name of Stakeholder Category of Name of Person Designation
No. Stakeholder
Merieux Nutrisciences Pvt Ltd
(French)
120 Apex Assessment Labs Private Non FSSAI Avnish Kumar -
Limited

67

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