All food industries, including those involved with spices and botanical ingredients, face challenges in providing safe products to consumers. These challenges are complicated by an ever-expanding global supply chain. The U.S. Food and Drug Administration (FDA) in 2013 released Draft Risk Profile: Pathogens and Filth in Spices.[1] The document describes the nature and extent of public health risks in spices posed by the most commonly occurring microbial hazards and filth, current and potential mitigation and control strategies to reduce risk, critical data gaps and research needs. Prior to the publication of this document, FDA reached out to the University of Maryland Joint Institute for Food Safety and Applied Nutrition (JIFSAN) to initiate a food safety training partnership with organizations in India that had been identified by the U.S. FDA India Office. This article describes ongoing international collaborative efforts to address these challenges using the case of India-sourced spices. It identifies partnerships between organizations in the U.S. and India.
The Draft Risk Profile reports that from 1973 through 2010, there were 14 reported outbreaks of illness associated with the consumption of spices. Outbreak investigations confirmed 1,946 known illnesses, 128 hospitalizations and 2 deaths. Although a number of human pathogens have been identified in spices, Salmonella contamination has been responsible for the largest number of illnesses reported. Since the majority of spices consumed in the U.S. are imported, it is essential that we foster partnerships with foreign governments and industries to help them implement supply chain preventive control principles including recognized Good Agricultural Practices (GAP), current Good Manufacturing Practices and, when appropriate, Hazard Analysis and Critical Control Points (HACCP). FDA identified poor and/or inconsistent application of these principles as one cause of contamination in spices with microbes or filth.
The Regulatory Environment
An abundance of literature is available for the advancement of food safety in general. Although numerous guidance documents from public and private sectors exist, their utilization has been limited internationally by a number of factors. They may not be accessible to all primary producers, and some are either too general or perhaps culturally insensitive. They also may be unavailable in the local language or rely solely on the written word. We are challenged with the task of developing and disseminating known science-based information in a manner that will be understood and accepted by producers and handlers of foreign-sourced spices. Consequently, international partnerships in food safety education and effective training programs are keys to achieving the goal of controlling food hazards in all sectors of the supply chain.
JIFSAN[2] is itself a collaborative partnership between the University of Maryland and FDA. As such, it has as one of its strategic thrusts the delivery of international capacity-building programs to help foreign suppliers implement best practices to help ensure the safety of food. JIFSAN now offers four international training programs that are delivered in-country.[3] These are GAP, directed to fresh produce, Good Aquacultural Practices (GAqP), including, in some programs, seafood HACCP and/or Good Fishing Vessel Practices, Commercially Sterile Packaged Foods and Food Inspector Training. As a subset of the GAP program, JIFSAN developed a specialized offering in Supply Chain Management for Spices and Botanical Ingredients (SCMSBI). These programs are complemented by activities of the JIFSAN International Food Safety Training Laboratory[4] and the Risk Analysis program.[5]
To further increase the cadre of trainers in some countries, JIFSAN implemented a Collaborative Food Safety Training Initiative. A focus of this initiative is to establish Collaborative Training Centers (CTCs) with in-country partners. In concept, a CTC is a mechanism for JIFSAN to leverage and enhance its training efforts and extend its resources by developing a cadre of in-country trainers in selected countries where some specific commodities have presented food safety concerns. These resident trainers have significant advantages in that they understand local problems, language and culture. This JIFSAN initiative is aligned with the key principles of developing partnerships identified in FDA’s International Capacity Building Plan: Ownership, Alignment, Leverage, Managing for Results, Mutual Accountability and Sustainability.[6] This effort has been highly successful with the establishment of a GAqP-CTC in Bangladesh and a SCMSBI-CTC in India. Most recently, a formal agreement with Thailand outlines collaborative work that is expected to include the establishment of a CTC there for training in processed packaged foods. Plans for a GAP-CTC with Mexico also have been outlined in a Memorandum of Understanding developed by JIFSAN that is being reviewed by Mexican officials. The active participation of FDA foreign posts is essential to the successful creation and sustainability of the CTC model.
The SCMSBI-CTC Program
The world spice trade is estimated at 1.1 million tons, of which India produces 48 percent and is the largest supplier of spices to the U.S. market. The SCMSBI program was originally developed with the intent of establishing a CTC in India to help the public and private sectors develop and implement their own capacity-building programs in safe practices for spices and botanical ingredients. This requires partnerships with entities capable of reaching out to primary producers and subsequent handlers in the supply chain. The in-country partners in this initiative, fostered by the U.S. FDA India office, include the Spices Board India and the Confederation of India Industry – Food and Agriculture Centre of Excellence (CII-FACE). FDA, as a partner with JIFSAN, helps with oversight and technical expertise when appropriate to advance the mission of the CTC. The development of this CTC involved three phases or levels of activity.
Phase I for the SCMSBI-CTC project was the delivery of a modified GAP program in India with the intent of reaching as many people as realistically possible. The objectives were to present the principles of GAP in the context of spices and botanical ingredients; to raise awareness of the importance of food safety in international trade; and to provide an adaptable framework of information that could be utilized by the host country to develop its own training materials. The Phase I program was conducted in Cochin, Kerala, India in September 2012. The audience included approximately 43 individuals from the Spices Board India and CII-FACE, Indian government officials and industry representatives, all of whom were expected to support the new initiative. FDA provided experts to address technical issues as well as matters of food law pertinent to the spices and botanical ingredients industries. For example, proposed revisions of the Food Safety Modernization Act relevant to Indian food industries were identified so that those involved in India could better provide comment on the newly proposed rules. The food safety principles outlined in Codex Alimentarius also were considered. The program included 4 days of classroom training and 1 day of visits to a farm and a spice manufacturing facility to review practices and conduct mock farm and facility inspections. Audience participation was excellent. During the Phase I program, a formal agreement to establish the CTC was signed by representatives from JIFSAN, the Spices Board India and CII-FACE.
Phase II entailed the selection of a small group of trainees having superior training skills and food safety experience to travel to the U.S. for advanced training. In March and April of 2013, nine of the trainees selected from Phase I traveled to the U.S. They received 6 days of instruction at the JIFSAN Training Center in College Park, Maryland. Sessions included lectures on specific topics but focused heavily on interactive discussion sessions and case studies. A visit to a large food manufacturing facility was included. From there, the group traveled to the University of Mississippi’s National Center for Natural Products Research (NCNPR)[7] for 3 days of instruction on laboratory techniques and analytical procedures.
Throughout all the Phase II sessions, the focus remained on the manner in which the trainees would develop and deliver their own educational programs in India. They considered the requirements for production of different spice crops and subsequent handling procedures. Methods of instruction and tools to facilitate instruction, including printed literature, videos, computer-based tools, etc., were discussed in detail. Clearly, small-scale producers require either one-on-one training or meetings of small groups that could benefit from printed guidance literature in a format that is easy to utilize, whereas growers who deliver their products to “Spices Parks,” discussed later, for consolidation and preprocessing can come together in a venue with larger groups. Established manufacturing facilities, most of which already have a food safety plan in place, will benefit from visits from experts who can review practices and conduct mock inspections. The goal is not only to identify challenges but also to offer practical and pragmatic management solutions to mitigate potential food safety risks. The partnership between JIFSAN, Spices Board India and CII-FACE provides a means of sharing knowledge and resources to address this wide variety of training needs. By the close of the Phase II program, the trainees had developed and presented for discussion their preliminary plan for furthering the mission of the SCMSBI-CTC in India.
Phase III and additional phases of CTC activity require the trainers to refine and implement their own training programs in India directed to primary producers and subsequent handlers of the products. These activities are well underway. The CTC leaders began with a series of meetings with National/State Horticulture Mission officials in May and June 2013 in the southern, central and northern regions of the country. Program leaders worked to sensitize mission officials to food safety issues and to encourage them to join with the newly formed CTC to conduct food safety training. The responses from the meetings were highly encouraging, and CTC leaders moved on to the next steps. Additionally, the Spices Board India and CII-FACE wrote a manual, Food Safety and Supply Side Management of Spices and Botanical Ingredients, that was published by the Spices Board India in September 2013. The manual includes sections on food safety issues in the supply chain; GAP for the production and handling of spices; managing food safety during transportation, storage, processing and packaging; as well as licensing and registration of food businesses in India.
Plans were laid by CTC to develop 2-day Train-the-Trainer programs. Two of these were to be delivered in each state, giving a total of 20 programs. The goal was to train approximately 50 people in each program, so a total of 1,000 newly trained trainers was projected. In October 2013, the first three programs were delivered to a total of 218 people. The newly trained participants are expected to branch out and deliver training programs to constituents in their regions. This is the concept that has been advanced in JIFSAN GAP Train-the-Trainer programs for more than a decade. Phase III program evaluation forms completed by course participants indicate that the methods and training materials are on target. Going forward, the effectiveness of training will be monitored and evaluated not only for the purpose of measuring success but also with the intent of continuously searching for ways to improve the programs.
A side activity of the World Spice Congress, which convened in Kerala on February 16–19, 2014, was to work with SCMSBI-CTC collaborators to discuss and develop a monitoring and evaluation (M&E) strategy to assist in understanding the impact of the Phase III training programs. The M&E activities are currently being piloted in collaboration with local partners involved in SCMSBI-CTC in India. This will enable the team to measure outcomes to determine the contribution of these programs to improved livelihoods and health benefits. Assessment tools were piloted in the inauguration training program in the villages of Kaloor and Kaloorkad in Kerala, led by Benjamin Mathew, Ph.D., program coordinator for the Santhanpara, Idukki, District, who had previously been trained through the SCMSBI-CTC. Representatives from JIFSAN and NCNPR participated. The plan in the upcoming year is to extend the training programs to a number of villages that are involved at critical stages in the supply chain of spices and botanical ingredients exported to the U.S. It is important to note that countries besides the U.S. also benefit from this initiative, so the impact is expected to be far-reaching.
Multiple training programs in Phase III are being conducted for different segments and stakeholders of the supply chain in various spice-producing states with a minimum target of two programs per state. State agricultural and horticultural departments have been requested to form GAP cells with their nodal office in each state. Training was provided to 11 government groups in 2014 in the states of Andhra Pradesh, Assam, Gujarat, Kerala, Madhya Pradesh, Rajasthan and Tamil Nadu plus four industry programs in the states of Andhra Pradesh, Karnataka, Kerala and Tamil Nadu. To date, Spices Board India has conducted 15 programs, reaching a total of over 500 people trained. Further, 10 additional programs were implemented through the first quarter of 2015. These will be conducted in 10 states in India focusing first on the most important spice-producing states.
Participants in training programs are being drawn from numerous sectors. The Spices Board reports participation from the India Department of Agriculture, Indian Council of Agricultural Research, university researchers and Extension professionals, farmers’ representatives, spice manufacturers and processors, and possibly other groups. Certainly, these programs are meeting the goal of raising awareness of food safety issues in the supply chain.
The Spices Board India programs also will work to provide technical and financial assistance to farmers to help them improve their postharvest operations to ensure high-quality, safe spices. Further, registered exporters are encouraged to upgrade their processing and packaging facilities, and establish accredited laboratory facilities. The Spices Board India has helped establish Spice Grower Societies to encourage the adoption of food safety programs through their supply chain, from production through export, and has recently established a committee on Spices and Culinary Herbs under the Codex Alimentarius Commission.
The Spices Board India also is in the process of establishing Spices Parks in the major spice-growing centers. These will have handling facilities that meet global standards for food safety programs. These Spices Parks will be able to perform some or all of the following steps in the supply chain: cleaning, drying, grading, grinding, sorting, sterilization, packing and warehouse storage for spices. The Spices Board India also is taking leadership to help implement practices for traceability from farm to final destination.
An International Reach
India has become increasingly active on the world stage in matters of food safety. As mentioned earlier, India hosted the World Spices Congress in 2014 and a Global Food Safety, Security and Nutrition Summit is planned there for 2015. At each of these conferences, JIFSAN and FDA were and will be present. At the World Spices Congress, speakers from FDA and the Universities of Maryland and Mississippi delivered presentations in support of the training efforts.
The CTC concept for reaching international suppliers of spices and botanical ingredients to the U.S. is an effective approach to help ensure the safety of these products. All partners in the CTC recognize that efforts to improve food safety programs must be continuous and sustained. Ultimately, consumers in the U.S. and worldwide will be provided safer spices and botanical food ingredients from India as a result of these efforts. We anticipate that the Indian producers and exporters will experience a stronger business environment and that Indian consumers will have positive health benefits with the consumption of safer products.
James W. Rushing, Ph.D., currently works with the University of Maryland JIFSAN as the manager of International Food Safety Training Programs. He earned a Ph.D. from the University of Florida in 1985 and since then has worked in more than 40 countries in the fruit and vegetable industries as a postharvest specialist and food safety trainer. He has been involved in the JIFSAN training program in GAP since it was first offered in 2000.
Clare Narrod, Ph.D., is manager of the Risk Analysis Program at the University of Maryland JIFSAN. She also leads the monitoring and impact evaluations effort of JIFSAN’s Food Safety Training Programs. She received her Ph.D. in energy management and environmental policy from the University of Pennsylvania in 1997.
M. R. Sudharshan, Ph.D., has worked most recently as director of research with the Spices Board India. He has more than three decades of experience in the field of crop improvement, especially cardamom, black pepper and vanilla. He has been the coordinator of the SCMSBI-CTC and is the chairperson of the newly formed Codex Committee on Spices and Culinary Herbs. He earned his Ph.D. from the University of Mysore.
Pratyasha Chakravarty is a counselor with CII-FACE. She is a Certified Food Professional, having obtained her training at the Indian Institute of Technology, Kharagpur, Department of Food Engineering and Technology, and has worked for over 22 years as a trainer and consultant to many sectors of the food industry. She has been working with the JIFSAN training effort in India since it was initially planned.
John Sproul, Ph.D., is a program analyst/investigator with FDA’s Office of Regulatory Affairs. He recently completed a 2-year deployment to the U.S. Embassy in New Delhi, India, as FDA’s Assistant Country Director (Foods), where he worked to develop sustainable partnerships between FDA and India’s food safety regulators and the food manufacturing and export industries. John received a Ph.D. in international business economics and trade from Hokkaido University Faculty of Fisheries in Hakodate, Japan.
References
1. www.fda.gov/downloads/Food/FoodScienceResearch/RiskSafetyAssessment/UCM367337.pdf.
2. jifsan.umd.edu/.
3. international.jifsan.umd.edu/.
4. ifstl.jifsan.umd.edu/.
5. risk.jifsan.umd.edu/.
6. www.fda.gov/Food/GuidanceRegulation/FSMA/ucm301708.htm.
7. www.pharmacy.olemiss.edu/ncnpr/.