Post Workshop - Reforms Proposals - PFA

R3: 2nd Interim Report The Assessment & Formulation of Reform Implementation Plan to Simplify and Automate Compliance
pliance with Business Regulations in Punjab
The Assessment & Formulation of Reform

Implementation Plan to Simplify and
Automate Compliance with Business
Regulations in Punjab
Program Implementation Unit, Planning &
Development Board, Government of the
Punjab
Reforms Recommendations
Punjab Food Authority
EY Ford Rhodes 1|Page

A Member Firm of Ernst & Young Global Limited
R3: 2nd Interim Report The Assessment & Formulation of Reform Implementation Plan to Simplify and Automate Compliance with Business Regulations in Punjab
1. About Organization
The Punjab food Authority has been working as a functional entity since 2nd July 2012. Enforcement of food hygiene and quality standards as described in
the Punjab Food Authority Act 2011 and the Pure Food Rules 2011 is carried out through a qualified team of Food Safety Officers (FSOs’) and Assistant Food
Safety Officers (AFSOs’). The functionality of field teams at the district level is being supervised by the Deputy Director (Operations). Some of the major
functions and responsibilities are:
► To regulate and monitor the food business in order to ensure compliance by farmers, manufacturers, distributors, importers and other stake holders
in orders to provide safe food.
► To formulate standards, procedures, processes and guidelines in relation to any aspect of food including food business, food labelling, food additive,
and specify appropriate enforcement systems.
► To Specify procedures and guidelines for setting up and up-gradation of food laboratories.
► To specify licensing, prohibition orders, recall procedures, improvement notices and prosecution in the court of law.
► To provide scientific advice and technical support to the Government in matters relating to food safety.
► To establish food laboratories.
► To organize training programmes in food safety and standards.
► To promote general awareness regarding food safety and standards.
► To certify food products/items for export.
► To forward and backward traceability of food items.

2. RLCOs’ Mapping
The following table provides information about the RLCOs issued by Industries, Commerce, Investment and Skills Development Department to the
businesses.
Relevant Law/ Ordinance/Act / Notification / SOPs Attached Dept. / Directorate / Division RLCOs RLCO ID Sr. No
 Punjab Food Authority Act, 2011  Punjab Food Authority License for Food Business Operation PFD-001 01
 Punjab Food Authority Act,2011

 Punjab Food Authority (Product Registration  Punjab Food Authority Certificate of Product Registration PFD-002 02
and Display of PFA logo) Regulations, 2017
 Punjab Food Authority Act, 2011

 Punjab Food Authority Label approval PFD-003 03
 Punjab Pure Food Regulations, 2018
 Punjab Food Authority Act, 2011.

 Punjab Food Authority License for FAT Rendering Unit PFD-004 04
 Punjab Pure Food Regulations 2018
 The Food Grains (Licensing Control) Order, Food Grain License

 Food Directorate PFD-005 05
1957
 The Flour Mill Control Order, 1959.  Food Directorate Flour Mill Registration/Wheat Quota Enlistment PFD-006 05
 Punjab Sugar Supply Chain order,2021  Cane Commissionerate License for Sugar Broker PFD-007 07
 The Sugar Factories Control Act,1950

 Cane Commissionerate License for Private Purchasing Agent PFD-008 08
 The Sugar Factories Control Rules, 1950
3. Reforms Recommendations

To provide reforms recommendations, we are reviewing the process map and assessing information gathered through data collection tool based on principles of
a good regulatory regime and on discussions with process owners to identify the areas where ease could be created by improving the environment in which a
particular RLCO process is being performed and streaming the existing process.
Additionally, we are also using benchmark information to identify any improvements in existing regulatory environment.
A) Improvement Opportunities Applicable to All RLCOs
To operate efficiently and effectively, process for each RLCO should have following enablers in place:
► Digitalize the end-to-end process to facilitate the applicant to apply online and introduce an e-pay mechanism for payment of fee. Following processes
should be digitalized:
• PFD-004: License for Fat Rendering Unit
• PFD-005: Food Grain License
• PFD-006: Flour Mill Registration/Wheat Quota Enlistment
• PFD-007: License for Sugar Broker
• PFD-008: License for Purchasing Agent
► The fundamental principle of good regulatory regime is that the business regulatory procedures and processes are clearly documented and understood
by the common users and the regulators who are expected to enforce them, and the information related to RLCOs is disseminated to the public.
Administrative processes and regulatory procedures for RLCOs being issued by Punjab Food Authority are not completely defined and documented in
relevant act, rules, notifications, or any other document which affects the principle of accessibility of information by the applicant and availability of
guidance to the applicant and process owners causing inconvenience to the applicants and investors.
Note: Please refer to the process maps to identify areas or steps which are not appearing in any act, rules, or any other documents.
It is suggested to formally define and document administrative application submission procedures in an easy, unambiguous, transparent, and
understandable manner in both English and Urdu language, and make these procedures available to public and applicants on department's website and
onsite at front-end offices dealing with the applicant. The documented procedures shall also be disseminated to relevant process owners so that they have
better understanding tasks to be performed by them.
► To have the efficient administrative process and to facilitate the applicant to track the progress of application, the timelines for the overall administrative
process and key steps is defined and communicated. Currently, timelines for RLCOs being issued by the Punjab Food Authority are not formally defined
which might be causing undue delays in the application processing.
Current timelines have been provided in the Annexure A.

Punjab Food Authority shall define the timelines for overall processes and major steps in consultation with the business investors or applicants. Monitoring
and compliance mechanism shall be developed to ensure timelines are complied with and any delays beyond defined timelines are investigated.

Review of Laws, Rules and Regulations with Respect to Digitization

We have reviewed the primary and secondary legislation provided to us and identified provisions which needs to be amended for purposes of
digitization, including to enable online payment compliance and allow businesses and citizens to apply for concerned permits and approvals
online.
Provided below are the lists of provisions which may have to be amended for the digitalization of the registration process for the following
departments:
No Law, Rules or Section(s) Relevant Clause

Regulations

B) Improvement Opportunities at RLCO Level
Reforms
## Current State Benchmark Practices (Where available) Recommendations/ Key Takeaways Legal Changes Required Impact
PFA-001: License for Food Business Operation
The grant of a food business Singapore Comments on overall Regulatory  Regulatory

operating license is governed Framework system will
Singapore has a comprehensive regulatory
by Punjab Food Authority Act, be more
framework. Food sector value chain is segmented In Pakistan, food sector is one the major
2011 and Punjab Pure Food effective and
and for each segment, laws and regulations, sectors and as it directly relates to public
Regulations, 2018. efficient
01 conditions of licensing and guidance according to health, therefore, food sector is classified
Under the provisions of business nature have been formally defined and among riskiest sectors. These risks are
section 15 of the Punjab Food disseminated: managed through strict and effective
Authority Act, 2011 every regulations over the sector.
- Food Farming (https://www.sfa.gov.sg/food-
food operator is required to
farming) As part of this project, we studied the
obtain a license to run a food
- Food Manufacturers Singapore model to identify any
business.
(https://www.sfa.gov.sg/food-manufacturers) improvement areas in Punjab’s existing
The Applicant applies for - Wholesale Food Markets regulatory framework.
license either on mobile or (https://www.sfa.gov.sg/wholesale-markets)
Key lessons from benchmarking exercise
web application, by visiting - Food Import & Export
were:
the PFA office or by (https://www.sfa.gov.sg/food-import-export)
Operations team on visit to the - Food Retailer (https://www.sfa.gov.sg/food- - Businesses Categorization: Complete
applicants’ premises. retail ) food industry has been initially segmented
- Food Information such as guidelines related to based on the value chain of food sector to
FSO carries out inspection and
labelling, food safety education, food alerts and ensure all the segments are covered and to
uploads inspection report and
recalls, etc (https://www.sfa.gov.sg/food- better manage risks of each segment
assigns the License Category
information ) separately. Segmentation has been
in the system.
provided for reference purpose in the
If inspection results are not License renewal requirements are based on the benchmarking column.
satisfied, applicant is asked to nature of the business. Additionally, business segments have
address the deficiencies. There are different award tier and licence with been formally defined to identify what
different validity https://www.sfa.gov.sg/food- type of trading activities will be covered
If inspection results are
retail/SAFE-framework). These tiers are defined in a particular segment. For example,
satisfied, license is issued to
based on food safety risk and the extent of food food manufacturers segment includes
the applicant.
handling practices involved.

Reforms
https://www.sfa.gov.sg/docs/default-source/tools-
following types of businesses:
and-resources/resources-for-businesses/licensing-
1. Food processing establishment
condition---food-processing-establishment
o Meat and/or fish processing
Application processing – food manufacturers establishment
o Other processed food
Before applicant applies to Singapore Food Agency
(SFA) to operate in above businesses, applicant is establishment: For other
required to hold a valid business registration with manufacturing activities, including
Accounting and Corporate Regulatory Authority central kitchens and repacking of
(regulator of business registration). food products
2. Cold store: For storage of meat and
The following steps are performed to get license fish products without any processing
from SFA: activities
1 Check suitability of premises location. 3. Slaughterhouse
Applicants are required to operate in approved Such categorization helps to implement a
food processing or compatible industrial place risk based regulatory framework. For
2 Apply for a SFA licence at the GoBusiness example, high risk businesses will be
Licensing website. Applicant applies via online subject to frequent inspections and license
portal for SFA’s preliminary evaluation along may be issued for duration of one year.
with following documents: Layout plan, Process In Pakistan, businesses are categorized
flow chart and Particulars of Products. into retail and manufacturing category
Application processing fee includes inspection ranging from very small to very large.
fee for evaluation of floor plans and process flow Categorization can be seen on
chart and a joint site inspection of the completed department’s website
premises with a licensing officer to ensure it (http://www.pfa.gop.pk/food-licensing-
complies with SFA's requirements. categories/) and in Note-2 of relevant
Upon receiving the application with the necessary process maps. Furthermore, we were
documents, SFA will assess the proposed plans unable to find any proper definition in any
to ensure they are designed in compliance with SOPs, law, rules formally defining these
SFA’s food safety requirements. Once SFA has categories which could create ambiguity
evaluated the submitted proposal, an in- regarding definition among applicants.
principle approval notification will be sent to - Proactive Governance Mechanism:
the applicant to start renovation works.

Reforms
3 Final Inspection – Once the renovation work is

Singapore has deployed a proactive
complete, applicant contact the same SFA
model for licensing. Applicants are
inspection officer and submit a list of required
required to submit factory or premises
documents for inspection.
layout before construction or
Inspector carries out final inspection and upon renovation to the relevant authority.
satisfactory inspection outcomes, case will be Layout is evaluated by the department to
approved. ensure compliance with operational
conditions for example, the premises must
4 License Approval – The licence application is
be designed in a way that allows one
approved via the GoBusiness Licensing system
directional flow to prevent cross-
and that license will be able to print upon
contamination between raw and finished
payment of the licence fee. License fee varies
products.
and depends on nature of trade. Details of
approved activities are indicated on the license. If Once the renovation/ construction work
applicant intends to carry out additional trades in is complete, license is issued to the
the future, applicant is required to get prior applicant after final inspection.
approval of department.
In Pakistan, application for licensing is
https://www.sfa.gov.sg/food-manufacturers/setting- made after construction but before
up-food-establishments becoming operational model.
- Well-defined Compliance Conditions:
Service analysed: Application for registration of a Compliance conditions are well defined
trade, public catering, primary production and / or and disseminated which businesses are
other food handling entity required to must comply.
The service is initiated via ‘Lithuanian Integrated In case of non-compliance, businesses are
food and veterinary information system (IMVIS)” subject to strict penalties.
and is provided by State Food and Veterinary In Pakistan, SOPs based on the business
Service. IMVIS also can be accessed via central nature have been defined and
eGovernment gateway. disseminated but these SOPs cover few
The applicant authenticates via E-Government areas.
Gateway by confirming his / her identity with It is suggested to review compliance
eSignature, ID card or SmartID. After conditions of Singapore and update
authentication, the applicant is returned to the SOPs accordingly for Punjab to ensure

Reforms
IMVIS where he / she must enter full personal
all the risky areas have been regulated.
contact details and also company details when
References have been provided:
entering for the first time. After, the applicant
selects the service for “Application for
Conditions of Licensing for Poultry
registration of a trade, public catering, primary
Slaughterhouses - Singapore
production and / or other food handling entity “.
https://www.sfa.gov.sg/docs/default-
The application form is pre-generated and includes
source/tools-and-resources/resources-for-
pre-filled personal data. The applicant:
businesses/
1. Selects which regional department of State
slaughterhouselicencecon_jun09.pdf
Food and Veterinary Service will review the
application;
SOPs for Food Businesses - Punjab
2. Indicates how he/she would like to receive the
https://www.pfa.gop.pk/sops-for-food-
permit;
businesses/
3. Confirms that they are aware and of food
handling regulations and rules; Procedural Reforms in Existing
4. Uploads documents which provide information Procedures
about the hygiene procedures in place in the
 Currently, different categories have been
facility;
identified for fee submission as provided
5. Answers additional questions about the
in note-2 of relevant process map. As
company and it’s food handling procedures.
these categories are not defined in any
The State Food and Veterinary Service officers
law, rules or SOPs and basis are not
evaluates the submitted documentation and
communicated to the applicant, it is likely
determines
to create ambiguity among the applicants
if the applicant has sufficient hygiene standards to
and process owners.
receive the permit.
The applicant is informed through email or via the It is suggested to formally define these
system on the status of the license issuance categories and communicate the basis of
(approved / denied). If successful, the applicant categorization to the public.
collects the license as selected in the application
form.
PFA-002: Certificate of Product Registration
EY Ford Rhodes 10 | P a g e
Reforms
USA Comments on regulatory framework
The Applicant applies through   Increase
the prescribed application FDA regulates foods and food ingredients sold in  Health and Food is a provincial subject in efficiency in
form available online, along the USA, except for meat, poultry, and certain Pakistan’s regulatory framework. the process
with the required documents. processed egg products regulated by the U.S. Currently, certificate of registration issued  Effective
Department of Agriculture (USDA). in one province remains valid in that Regulation
The applicant pays the fee by
province only because each province has
logging into in the PFA Food facility registration is one of the FDA
its own product registration criteria.
software application which requirements for food products. If applicant is a
It is suggested to develop a standardized
generates fee challan by domestic food manufacturing, processing, packing
criterion for product registration at national
entering the product name and or warehouse facility, applicants are required to
level and introduce a mechanism where
category. register with FDA.
product registration in one province should
The fee can be submitted at https://www.fdabasics.com/our-faq/fda- be considered valid across Pakistan.
any Allied Bank branch and requirements-for-food/
02
also online through Easypaisa
EU:
app.
The only general requirement for every food
manufacturer is to be a registered food processing
entity.
The registration process in Lithuania is presented
under Benchmarking Practice of RLCO 1.3 Food
Business Operating Licensing & Renewal under
Punjab Food Authority.
LINK /
LINK
PFA-003: Label Approval

03 US Comments on regulatory framework   To enhance
The applicant pays the fee by
Label Designing Services process
either visiting the PFA office  Currently, trademarks are registered with
Labeling is one of the important regulatory efficiency
or by logging into in the PFA Intellectual Property Organization and
requirements for food products marketed in the
software application which business names are registered with other
United States. In case, food product label fails to
generates fee challan by regulatory agencies (Industries
Reforms
meet FDA requirements, FDA may take strict
entering the product name and departments and SECP).
regulatory action. FDA offers complete assistance
category.
for to meet FDA food labeling requirements. As per our discussions with process
Applicant submits Additionally, FDA provides food product label owners, some food businesses use words
application on letterhead designing services at competitive fees. Review such as organic, pure food in their
along with paid fee challan services includes health claim review, verification trademarks or names. Registration of
and copy of draft label and of mandatory statements, nutrition/ facts review, trademarks or business names with such
content and formatting review. words may be misleading as internationally
The fee can be submitted at
Label Review Approval such names are allowed unless such
any Allied Bank branch and
There is an online system for label approval product is certified as organic by an
online through Easypaisa app.
named as Label Submission and Approval System accredited organization.
(LSAS). To use the system, users are required to
To cater the above issue, it is suggested to
have USDA “Level 2” e-Authentication (eAuth).
either include an approval of food
https://www.fsis.usda.gov/inspection/compliance-
department for business naming and
guidance/labeling/label-submission-and-approval-
trademark registration service or to add
system-lsas
such words in the list of names requiring
special approval from food department.
EU
Typically, this service in EU is not provided. The
compliance is ensured during State food authority
checks on company products.
It is the food business owner’s responsibility to
make sure labelling is done correctly in the product
nutrition declaration.
The requirements for food product nutrition
declaration (the label) is provided in the State Food
and Veterinary Service website LINK.
PFA-008: License for Sugar Broker/ PFA-009: License for Private Purchasing Agent
PFA-008: License for Sugar N/A Procedural Reforms  
05 Broker
 Review current approval mechanism to
The Punjab Sugar Supply limit the number of reviews to a level
Reforms
chain Management order,
where the compliance burden in terms of
2021 requires the Brokers of
time is appropriately balanced with the
sugar (who sells sugar to a
problem or risk being addressed.
dealer or a wholesaler or a
bulk consumer on behalf of
occupier of a sugar factory) to
get registered with the Cane
Commissioner.
The applicant submits the
application on plain paper to
the Cane Commissioner along
with the following documents:
 NTN
 Copy of CNIC
 1 Photograph
Superintendent scrutinizes the
application to check
completeness of the
documents / particulars. The
Superintendent also confirms
the NTN on FBR portal.
Cane Commissioner, if
satisfied that all the
requirements have been
fulfilled, grants approval for
issuance of License. The
License is issued on the
prescribed Form-6.
PFA-009: License for

Private Purchasing Agent
The licensing of Purchasing
Agents for the purchase of
Reforms
sugarcane is carried out under

the Sugar Factories Control
Act, 1950 (section 17) and
Sugar factories Control Rules,
1950 (rule 12).
The application for grant of
license to Purchasing Agent is
submitted by the Occupier of
the Sugar Factory, by way of
nomination, to the Cane
Commissioner Punjab. After
detailed scrutiny of
application, license is issued to
the applicant.
Annexure A
Defined Timelines Attached Dept. / Directorate / Division RLCOs RLCO ID Sr. No
License for Food Business

 Not Defined  Resource and Licensing Wing PFA-001 01
Operation
 Defined in the Food Authority

Certificate of Product
(Product Registration & Display of  Technical Wing PFA-002 02
Registration
PFA logo) Regulations, 2017
 Defined in Punjab Pure Food

 Technical Wing Label Approval PFA-003 03
Regulations, 2018
 Not Defined  Resource and Licensing Wing License for FAT Rendering Unit PFA-004 04
 The Food Grains (Licensing Control) Order, Food Grain License

 Not Defined PFA-005 05
1957
Flour Mill Registration/Wheat

 Not Defined  The Flour Mill Control Order, 1959. PFA-006 06
Quota Enlistment
 Not Defined  Punjab Sugar Supply Chain order,2021 License for Sugar Broker PFA-007 07
 The Sugar Factories Control Act,1950 License for Private Purchasing

 Not Defined PFA-008 08
 The Sugar Factories Control Rules, 1950 Agent

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R3: 2nd Interim Report The Assessment & Formulation of Reform Implementation Plan to Simplify and Automate Compliance

pliance with Business Regulations in Punjab

The Assessment & Formulation of Reform

EY Ford Rhodes 1|Page

EY Ford Rhodes 2|Page

 Punjab Food Authority Act,2011

 Punjab Food Authority Act, 2011

 Punjab Food Authority Act, 2011.

 The Food Grains (Licensing Control) Order, Food Grain License

 The Sugar Factories Control Act,1950

EY Ford Rhodes 3|Page

EY Ford Rhodes 4|Page

EY Ford Rhodes 5|Page

Review of Laws, Rules and Regulations with Respect to Digitization

No Law, Rules or Section(s) Relevant Clause

EY Ford Rhodes 6|Page

B) Improvement Opportunities at RLCO Level

PFA-001: License for Food Business Operation

The grant of a food business Singapore Comments on overall Regulatory  Regulatory

EY Ford Rhodes 7|Page

EY Ford Rhodes 8|Page

3 Final Inspection – Once the renovation work is

EY Ford Rhodes 9|Page

PFA-002: Certificate of Product Registration

PFA-003: Label Approval

PFA-008: License for Sugar N/A Procedural Reforms  

PFA-009: License for

sugarcane is carried out under

Defined Timelines Attached Dept. / Directorate / Division RLCOs RLCO ID Sr. No

License for Food Business

 Defined in the Food Authority

 Defined in Punjab Pure Food

 The Food Grains (Licensing Control) Order, Food Grain License

Flour Mill Registration/Wheat

 The Sugar Factories Control Act,1950 License for Private Purchasing

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