residue monitoring system issuance of health certificate gap including ethical practices in export
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residue monitoring system issuance of health certificate gap including ethical practices in export

Residue Monitoring SystemIssuance of Health CertificateGAP including ethical practices in export

MAMTA RANI

ASSISTANT DIRECTOR

06 September 2011

EXPORT INSPECTION AGENCY - DELHI

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

EXPORT INSPECTION AGENCY - DELHI

eic ca structure
EIC (CA)-STRUCTURE
  • Apex Body – Council, Chairman, 18 members,

Member Secretary- Director, EIC

  • Specialist Committees
  • EIC – The Central Competent Authority
    • CEO Director, office at Delhi
    • Regional Competent Authorities– 5 EIAs at Mumbai, Kochi, Kolkata, Delhi and Chennai, under administrative & technical control of EIC
    • 28 Sub-offices & labs

EXPORT INSPECTION AGENCY - DELHI

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

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

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

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

Others - Other EU countries, Canada, Argentina etc- under negotiation

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our website www eicindia org
Our website (www.eicindia.org)

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sps tbt
SPS/TBT

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

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residue monitoring system11
Residue Monitoring System

Preventing prohibited substances getting into the food chain, which are harmful or likely to be harmful to human health.

Monitoring of substances which are harmful or likely to be harmful to human health to ensure that the level is within the prescribed limit (based on scientifically established risk analysis) in the particular food.

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basis of residue monitoring
Basis of Residue Monitoring
  • GoI Notifications on products of animal origin:

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systems of residue control
Systems of Residue Control

NRCP :EIC is implementing through MPEDA in aquaculture products

RMP : EIC’s Annual Residue Monitoring Plans (RMP). Implemented by EIC in Egg Products, Milk Products, poultry meat products and honey

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why nrcp and rmp
Why NRCP and RMP?
  • WTO Agreement:
    • SPS Agreement: Compliance of Sanitary and Phyto-Sanitary requirements of importing country- setting up country specific standards based on risk assessment & scientific evidences, Harmonization, Transparency, Mutual recognition
    • TBT Agreement: No importing country should impose Technical Barrier to Trade.

Global food trade is Food Safety (The food free from health hazards). Consumer is entitled for safe, sound and wholesome food free from any physical, chemical and microbiological hazards

  • Requirement of Harmonization

SPS and TBT agreements require National Standards to Harmonize with International ones

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

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

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

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nrcp rmp for eu18
NRCP/RMP for EU
    • Council Directive 86/363/EEC and Commission Regulation (EC) 1881/2006 - Maximum Residue Levels (MRLs) for a wide range of pesticides and maximum levels (MLs) for certain environmental contaminants, respectively.
  • Annual submission – RMP for each food commodity from third countries to EC, (plans + previous year results by the 31st March every year)
  • Approval of Plan by EC- listed in the Commission Decision 2004/432/EC, (updated).
  • According to the last update India is eligible for export the products of aquaculture, eggs to EU.

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basis for plant products
Basis for plant products

In the EU, as from 1 September 2008, a new legislative framework (Regulation (EC) No 396/2005 on pesticide residues is applicable,

Covering approx. 1100 pesticides currently or formerly used in agriculture in or outside the EU.

It lists MRLs for 315 agricultural products. These MRLs also apply to processed products, adjusted to take account of dilution or concentration during processing.

To access the database, http://ec.europa.eu/sanco_pesticides/public/index.cfm

EFSA - responsible for the safety assessment.

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benefits of rmp implementation
Benefits of RMP implementation

Food products of animal origin

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

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nrcp salient features
NRCP – Salient features

Implemented by MPEDA

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

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rmp salient features
RMP – Salient features

Implemented by EIC - EIC – CCA, EIA- RCA

Responsibilities of processors-

    • To ensure that the registered feed mills supplying feed to the producers / farmers and farms / producers supplying animal products) – records – EIA M.O

Sampling Procedure:

  • Multiple sampling of same matrix from same source - avoided
  • The Representative samples - traceable to source of farm / producer
  • Samples - collected and secured in clean and inert containers & labelled
  • Samples should be sent to designated EIA lab/ EIC approved lab under controlled conditions.

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rmp salient features23
RMP – Salient features

Analysis and handling of samples:

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

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rmp salient features24
RMP – Salient features

Corrective Action in case of failure of samples:

Processor to be kept on ‘ On-Alert’ and advisory issued to exporters, for;

  • Identification of the exact source
  • Stop procurement of raw material from the source.
  • Refrain from exporting the products processed from the identified source
  • Find the root cause for the failure of the samples from the identified source
  • Take corrective actions to prevent recurrence
  • Review the HACCP and revise if necessary
  • Conduct regular training for farmers / producers / suppliers to prevent recurrence

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rmp salient features25
RMP – Salient features

Corrective Action in case of failure of samples: (Contd.)

  • Assessment by the EIA official to find out the source and root cause of the contamination including backward linkages and assists in identifying preventative measure to stop the recurrence
  • The live stock concerned and the product is kept under official control
  • The source producer/farm is subjected to more checks

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rmp salient features26
RMP – Salient features
  • Provision for re-testing of positive samples
      • Re-testing of the positive samples - on request from the unit ( re-confirmation).
      • The control sample - tested in two different EIA labs/ EIC approved labs other than one tested earlier.
      • The result to be treated as positive even if one of the two samples is found to be positive on re-testing.
      • In case both the samples pass the MRL requirement on re-testing, the concerned EIA shall withdraw internal alert , which shall take effect from that date.
    • Recording and reporting:
      • All records relevant to planning, sampling and testing to be maintained at EIAs.
      • monthly / quarterly summary in the prescribed format to be submitted by the Sub-office to the EIA concerned, in the end to EIC

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issuance of health certificates
Issuance of Health Certificates
  • What is HC? –

A document for a consignment of food product certifying that:

    • the consignment has been processed under proper sanitary and hygienic conditions, and that
    • the food product is safe for human consumption.

issued by a competent authority, acceptable to the health authority of the importing country.

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

EXPORT INSPECTION AGENCY - DELHI

health certificates29
Health Certificates
  • Issuing authority?: Competent authority specified by the importing country.
    • Export Inspection Council of India – CA for F&FP meant for export to EU, countries other than EU.
    • EIA issues HC on behalf of EIC using the official rubber

stamp (seal) of EIC

    • Some countries accept HC issued by official veterinary authorities.
    • If an EU approved establishment obtains HC from any
    • body other than EIC/EIA, its approval is liable to be withdrawn

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requisites to issue hc
Requisites to issue HC

On request from approved processor/exporter

On the basis of controls carried out, - on or before the date of shipment

HC not issued after the date of shipment (indicated in the Bill of Lading)

Note: HC is issued only for F&FP processed in establishments/factory vessels/freezer vessels approved by EIC/EIA, likewise milk products, egg products, honey etc.

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requisites to issue hc31
Requisites to issue HC

HC for consignments of F&FP meant for non-EU countries to be issued by the EIA concerned in the prescribed format given at Annexure XXII(A) of EI

If any country has prescribed format of HC, the specific format will be used as required by the importing country. For e.g. Australia

EXPORT INSPECTION AGENCY - DELHI

formats of hc
Formats of HC
  • COMMISSION REGULATION (EC) No 1664/2006 – for

HONEY AND OTHER APICULTURE PRODUCTS

  • COMMISSION REGULATION (EC) No 1250/2008 –
  • FISHERY PRODUCTS INTENDED FOR HUMAN
  • CONSUMPTION
  • COMMISSION REGULATION (EU) No 364/2011- for egg

products (EP)

HC is prepared in triplicate: Original (White) for importer; Duplicate (Pink) for HO; Triplicate (Blue) for office record

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formats of hc33
Formats of HC
  • Multilingual HC format is used for EU

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certificate of analysis for aquaculture shrimps meant for export to japan
Certificate of Analysis for Aquaculture Shrimps meant for export to Japan

If processor/exporter approaches EIA - consignments of Aquaculture Shrimps meant for export to Japan

for the samples shall be drawn by an authorized EIA officer and the same shall be tested for Antibiotic Residues including Nitrofuran Metabolites, in EIA lab under its jurisdiction.

The cost of testing to be borne by the processor.

Format of Certificate of Analysis to be issued is given at Annexure XXVIII of Ex. Instructions.

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best agriculture practices in export
Best Agriculture Practices in export

Reforming agriculture and making the produce internationally competitive in quality & food safety.

Green revolution – uncontrolled usage of chemical fertilizers, irrigation water & pest control products – adverse environment impact, degradation & increased salinity in soil, deforestation and depletion of water resources.

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gap role in export
GAP- role in export

Structured methodology, innovative technology without its adverse impact on environment, health & safety of people.

GAP – collection of principles – on farm production, post production processes –

- integrated pest management

- integrated fertilizer management &

- conservation agriculture

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basic elements of gap
Basic elements of GAP

Farm selection & Farm management

Rational use & application of pesticides

Judicious use of fertilizers

Soil conservation & soil management

Irrigation & water conservation

Integrated pest management

Produce storage & handling

Pre – harvest application of pesticides

Harvesting practices

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basic elements of gap contd
Basic elements of GAP Contd….

Post harvest treatment

Workers health, safety & welfare

Traceability – from farm to fork/back tracking from fork to farm, batch/lot recall

Protection of environment

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standardization of good agricultural practices
Standardization of good agricultural Practices

GlobalGAP - key reference for GAP in global market place- GLOBALGAP Secretariat

GlobalGAP standards cover entire range of agriculture including animal husbandry & fisheries – (next slide)

Consists of set of normative documents covering GLOBALGAP general regulations, the GLOBALGAP control points & Compliance criteria and the GLOBALGAP checklist.

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globalgap standard structure
GLOBALGAP STANDARD STRUCTURE

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

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harmonization with globalgap46
Harmonization with GLOBALGAP
  • In India, both the streams of standards – under the aegis of NTWG set up by QCI and another FSSAI with assistance from QCI
  • India GAP standards prepared - GAP-Basic requirements, fresh fruits & vegetables, combinable crops, green coffee, & tea

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certification of good agricultural practices
Certification of Good Agricultural Practices
  • More than 100 independent and accredited certification bodies in more than 80 countries.
  • Open to all producers worldwide
  • FSSAI led IndiaGAP cover:
  • Certification Criteria
  • Certification Process
  • Certification body requirements

‘Draft available at QCI website’

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certification of good agricultural practices48
Certification of Good Agricultural Practices
  • NABCB (National Accreditation Board for Certification Bodies) of QCI –
  • Accreditation of certification bodies based on ISO Guide 65 along with relevant scheme – GlobalGAP or IndiaGAP
  • Two options:
  • Individual certification: Multisite without implementation of QMS, Multisite with implementation of QMS, Basic progressive model
  • Group certification

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certification of good agricultural practices49
Certification of Good Agricultural Practices
  • Ensure conformity to standards on IndiaGAP standards
    • IndiaGAP-Standard intending for Bench marking with GlobalGAP
    • IndiaGAP – basic requirements (progressive in nature)
  • Evaluation against control points and compliance criteria (CPCC)
  • Compliance to relevant statutory and regulatory requirement applicable in area of operation
  • Before certification process applicant shall:-
    • Selection of farms for GAP certification
    • Assigning identification number to the different units of the farm
    • Establish legal identity & registration
    • Selection of certification model depending upon nature of operation
    • Training on IndiaGAP to farmers

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certification of good agricultural practices50
Certification of Good Agricultural Practices
    • Establishing documented system to meet the requirements & its implementation
    • Training of inspectors/auditors
    • Conducting internal evaluation and appraisal of the system by trained farm inspectors
    • Taking corrective action and improving the situation
    • Appointment of certification body
  • Documents for introducing IndiaGAP certification:
  • IGAP-01 – certification criteria (voluntary)
  • IGAP-02 – Certification process (voluntary)
  • IGAP-03- group certification (voluntary)
  • IGAP -04 – basic module (voluntary)
  • IGAP -05 – certification body requirements (voluntary)

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gap certification process
GAP Certification Process

Applicant → Application

Scrutiny Application

Review of application

Farm Inspection Audit

Farm Inspection Audit Report

Decision on certification

Award of certificate → surveillance → Renewal

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slide52
THANK YOU

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