The Managing Directors/CEO's/Owners/Director/Partners/General Managers
All FHRAI Members
CC: All Members of the Executive Committee
All Regional Associations
SUB: FSSAI’S RESPONSE TO FHRAI REPRESENTATION ON CONCERNS RELATED TO FSS ACT, RULES AND REGULATIONS
Dear Member,
This is in reference to a stakeholders meeting hosted by Food Safety and Standards Authority of India (FSSAI ) on 18th February 2022 to discuss concerns related to the FSS Act 2006, Rules and Regulations.
A delegation of FHRAI participated in the meeting and raised many concerns of the industry related the FSS Act 2006 and other Regulations having a bearing on the hospitality industry and requested for requisite relief. Subsequently, FHRAI submitted a detailed representation on the subject.
We wish to inform you that FSSAI has acknowledged the concerns raised by FHRAI and provided a point wise response against the issues mentioned in the representation vide its letter dated 5th April 2022.
We are happy to share the highlights of the positive responses received from FSSAI in respect to the following major concern areas of the industry. For details, please find the enclosed letter from FSSAI.
(i) Concerns related to penalty clause of the FSS Act 2006
Response of FSSAI : ‘It may be noted that the penalties are being rationalized and the proposal to decriminalize the offences under Sections 59 (1), 61 & 63 of the FSS Act 2006 are also under active consideration’.
(ii) Concerns related to mismanagement of samples
Response of FSSAI : ‘ Suitable changes in the FoSCoS / FoSCoRIS are being made to ensure that the system generated mails are sent to the FBO from whom the sample is taken as soon as the report of the Food Analyst on the same is updated on the system. The same will make the system transparent and ensure that the FBO is kept updated about the results of every sample drawn from the premises / establishment.’
‘Further in order to strengthen the sample Management system in the country, various technological interventions through FoSCoS, INFOLNET are also being made which will bring efficiency and transparency in the system.’
(iii) Concerns with Sample Testing
Response of FSSAI : ‘ The strengthening and capacity building of the laboratory infrastructure is being carried out by FSSAI on war footing by providing adequate budgetary support as well as training of the manpower to be deployed ’.
(iv) Concerns related to Supply Chain ( for non-vegetarian raw material )
Response of FSSAI : ‘ As per the directions issued in this matter, the slaughter houses fall under the High Risk Category of food businesses and therefore the same are subject to frequent inspections to ensure cleanliness and hygiene as well as other regulatory compliances’.
(v) Concerns related to compliance with ISO 10500 and other concerns with water
Response of FSSAI : ‘ FSSAI is already seized with the issue and the appropriate changes to ease the said compliance in the Draft Food Safety and Standards (Licensing and Registration of Food Business ) Amendment Regulations, 2020’.
‘Since the final notification of the said Regulation will take some time and keeping in view of the concerns of the industry, FSSAI is considering to clarify the matter by issuing FAQs on the same. The proposed FAQs are under consideration and will be released shortly. ‘
(vi) Concerns related to third-party audit and hygiene rating
Response of FSSAI : ‘ The suggestion of the industry is well taken and FSSAI is already considering the same. Further, the said aspect shall be taken care of while issuing the updated order on the Risk Based Inspection System (RBIS) shortly.
- Training of FBOs in Hospitality Industry
Response of FSSAI : ‘ FSSAI has already entered into an MoU with Sector Skill Council for Food Processing Industries (FICSI) to train the food handlers on food safety and hygiene practices through relevant FoSTaC courses and to develop capacities of MSME. FHRAI is advised to approach the FICSI to avail the benefits under the said program / MoU.
We shall keep our members updated on any further development on this subject.
We look forward to your continued support and cooperation.
With kind regards,
Jaison Chacko
Secretary General
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The Federation of Hotel & Restaurant Associations of India
Regd. Off.: B-82, 8th Floor, Himalaya House, 23 K.G. Marg, New Delhi - 110 001
Tel.: 011-40780780, Email: fhrai@fhrai.com Website: www.fhrai.com