EXECUTIVE SUMMARY AND RECOMMENDATIONS OF THE COMMITTEE ON THE PESTICIDES RESIDUE IN PACKAGED DRINKING WATER AND PACKAGED NATURAL WATER
The print and electronic media had highlighted some shortcomings in the quality of bottled water, on 5th February, 2003. In particular, it was mentioned that residues of extremely harmful pesticides were found in popular brands of bottled water sold in Delhi and Mumbai. These reports were based on an independent study conducted by Centre for Science and Environment (CSE), an NGO. The Department of Consumer Affairs responded to these reports immediately and constituted a committee on the same day viz 5th February, 2003 under the chairpersonship of Smt. Satwant Reddy, Additional Secretary, Department of Consumer Affairs. The Committee was required to address the issues relating to the adequacy of prescribed standards for packaged drinking water and natural mineral water and enforcement thereof; the effectiveness of testing facilities at present available with BIS; the alignment of standards for packaged drinking water and natural mineral water with current international standards; and the linkage of BIS standards with Prevention of Food Adulteration Act (PFA). It was also required to fix responsibility and prescribe remedial measures.
The committee obtained voluminous information from BIS as also from other sources on the various issues to be addressed by the committee. In addition, it went through the process of discussions and interactions with various stakeholders including consumer organizations, experts from WHO, scientists from National Physical Laboratory, Ministry of Food Processing Industries etc. It also obtained views of various related organizations in writing.
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II ADEQUACY OF PRESCRIBED STANDARDS
The BIS standard for packaged drinking water (IS:14543) was formulated and the other one for packaged natural mineral water (IS:13428) was revised in 1998. The Drinks and Carbonated Beverages Sectional Committee, constituted by the Food and Agriculture Division Council of BIS initially considered amendments in an earlier standard for mineral water (IS:13428 : 1992). Due to divergent nature of comments, a panel was set up to examine various aspects related to such standards in totality. The panel included a representative each from Ministry of Health & Family Welfare (Directorate General of Health Services) Government of India, a Scientist (Chief Water Analyst from Department of Public Health and Preventive Medicines, Coimbatore) and a consumer organization (Consumer Guidance Society of India), in addition to three representatives from industry.
The above mentioned panel prepared two draft standards for packaged drinking water and packaged natural mineral water. The requirement for pesticides residues was revised as “not detectable” on the basis of comments received on the draft standards. The Codex standards as also WHO guidelines for drinking water were considered while finalizing these standards. In the Codex standards the requirements for pesticides residues is mentioned as “below the limit of quantification”, which is not very different from ”not detectable” mentioned in the two Indian Standards. They were adopted after obtaining the approval of the Chairman of Food and Agriculture Division Council on 19.1.1998.
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It came to the notice of the Department of Consumer Affairs as also of the Ministry of Health and Family Welfare that a large number of manufacturers of bottled water were not adhering to quality specifications prescribed for water. Therefore, it was felt that there should be some check on such unscrupulous manufacturers in order to protect the interest of the consumers. The issue was deliberated in the Central Committee of Food Standards (CCFS) set up under PFA Act by the Ministry of Health (DGHS) in its 42nd meeting held on 26th & 27th November, 1997, which considered the mechanism for compulsory certification of packaged drinking water and packaged natural mineral water. It also considered the adequacy of BIS standards and decided that the same should be adopted under PFA before it is made mandatory. The Central Committee for Food Standards set up under Rule 3 of PFA Act is a broad based body under the chairpersonship of Director General of Health Services. It includes Directors of Central Food Laboratories, experts nominated by the Central Government and representatives of Ministry/Department of Food, Agriculture, Commerce, Defence, Industry and Railways. It also includes representatives of State Governments, consumer organizations, medical profession (nominated by Indian Council of Medical Research) and representative of BIS.
Finally, through two notifications dated 29.09.2000(GSR No. 759 E & 760 E), Ministry of Health and Family Welfare made BIS certification of packaged drinking water and packaged natural mineral water mandatory under PFA Act. The specifications prescribed for packaged drinking water/natural mineral water in these two notifications mentioned pesticide residues as ‘below detectable limits” as per test method standards of BIS.
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Whether procedure outlined in BIS Act and Rules was followed
After careful consideration of the documents provided by the BIS Directorate General and of the presentations made by BIS officials, which provided an opportunity to obtain clarifications, it is found that the two standards in question were developed as per normal procedure followed by BIS for other standards.
Linkages with other BIS Sectional Committees and Standards
In the preparation of the two standards references have been made to various standards prepared by other Sectional Committees and Division Councils such as Water Sectional Committee of the Chemical Division Council and Pesticides Residues Sectional Committee under Agriculture and Food Division Council. The pesticide residue test method standards for individual pesticides were developed and published during 1985-1993, much before the two standards for packaged water were taken up for standardization. The scope and applicability of most of these standards has been questioned as not being suitable for detection and estimation of low level of pesticides in water. The criticism appears to be justified as the methods are more suited for soils, foods, fruits and vegetables. It would have been appropriate to have a coordination meeting of the concerned sectional committees and Division Councils to discuss the suitability of test methods for pesticide residues in water. This would have enabled BIS to make a better use of the pool of expertise available with it.
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Other National & International Standards Considered During the Preparation of the two standards
The Sectional Committee FAD 14 was aware of the standards for drinking water declared acceptable by international bodies like WHO, Codex, EEC etc. In particular assistance was obtained from the following:
(a) Manual on Water Supply and Treatment (third edition),1991, prepared by the expert committee constituted under the Ministry of Urban Development, New Delhi.
(b) Codex Code of Practice for Collecting, Processing and Marketing of Natural Mineral Water (CAC/RCP 33-1985).
( c) EEC Directive, 80/778/EEC relating to the quality of water intended for human consumption.
Safety Aspect of Standards
It was mentioned by WHO experts that water accounts for only 10% of the total human intake in a day. It is, therefore, essential to look at the safety aspect of packaged drinking water/natural mineral water in its proper perspective.
The detection limits of pesticide residues as per prescribed test methods, compare favourably with pesticide residues in other food items such as milk, fruits, vegetables and food grains, which account for a major portion of daily intake by human beings. For example existing test methods detect DDT in packaged water upto the level of 0.02 ppm, whereas in milk and milk products (on a fat basis), it is permitted upto 1.25 ppm under PFA. BIS standards were accepted by CCFS
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under PFA Rules in order to harmonize the two. The Central Committee for Food Standards (CCFS) set up under Rule 3 of PFA Act is a broad based body under the chairmanship of Director General of Health Services.
III ADEQUACY OF ENFORCEMENT OF THE PROVISIONS OF STANDARDS THROUGH THE BUREAU OF INDIAN STANDARDS PRODUCT CERTIFICATION SCHEME
The powers vested in the Bureau to grant, renew, suspend or cancel a licence to use the Standard Mark are under Section 15 and 16 of the BIS Act and further details are given in the Bureau of Indian Standards Certification Regulations, 1988. The licensing scheme is a third party product certification scheme, usually on a voluntary basis; the presence of the Standard Mark of BIS on a product is a means of conveying to the consumer that the product meets the applicable standards for quality of performance and safety.
The certification system followed by BIS is in agreement with the system 5 described in ISO Guide 28 – 1987 followed in several countries.
Certification for packaged Natural Mineral Water (IS : 13428) & Packaged Drinking water (IS : 14543)
The certification of packaged natural mineral water and packaged drinking water was brought under mandatory certification scheme of BIS, under PFA Act, 1954 through notifications No. GSR 759(E) and GSR 760(E) issued by the Ministry of Health & Family Welfare on 29.9.2000. For processing applications for grant of licence, BIS has formulated two schemes of testing and inspection (STI). They specify the levels of
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control and the frequency of test considered necessary for manufacturing units to ensure adequate quality control and compliance to the specifications. The frequency for monitoring and testing for pesticide residues in both the STI has been specified as once in two years at a recognized laboratory, and similarly for radioactive chemicals (alpha and beta emitters) once in two years at Bhaba Atomic Research Centre. Ever since the scheme was launched, 776 licences have been issued for use of the Standard Mark on packaged drinking water and 6 licences have been issued for the use of the Standard Mark on packaged natural mineral water. So far BIS has drawn in all 3259 samples of which 1016 samples were for testing of pesticide residue. Only two of the latter have been reported to have failed to comply with the requirement of “below detectable limit”. In all, 494 samples have failed to meet one or other requirement.
In view of repeated failure to comply with the specifications, BIS had imposed stop marking order on 108 licences at different points of time till February, 2003. In the two cases of failure of samples for pesticide residues, appropriate penal action like stoppage of marking was carried out.
The cases of grant and operation of the licences by three different branch offices of BIS were scrutinized. In all cases, the factories have been inspected and samples were evaluated for compliance including that of pesticides residues, in recognized laboratories. Surveillance inspections were carried out and in all three cases presently the marking is suspended for unsatisfactory performance.
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Adequacy of Number Of Inspections and drawal of samples
BIS (Certification) Regulations, 1988 provide for a minimum of two inspections in a year in respect of each licence. It was mentioned by BIS that with regard to packaged water it was decided to increase the frequency of inspections from two to three per year. As per details provided, a total of 2650 inspections were carried out for 784 licensees with the average being 3.38 inspections per licence. However, in some of the branches, the number of inspections is abysmally low. In Ahmedabad Branch Office (ABO), for example, only 64 inspections were carried out for 64 licensees, with the average of one inspection per licensee. Position in Rajkot Branch Office (RBO) with 15 inspections for 12 licensees is only slightly better.
The number of market samples drawn was less than one per licensee. There is scope for substantial improvement in drawal of market samples. As a matter of fact, drawal of market samples is a simpler and more cost effective means of quality control and should be made better use of. BIS had also mentioned that normally two market samples are drawn per year. However, in case of packaged water, BIS had decided that four market samples may be drawn during an operative year. The achievement in this regard was far short of even the general norm of two market samples per licensee.
Adequacy of Enforcement Under Section 26 of BIS Act
It is observed from the information provided by BIS (Annex III.7) that during the period April 2001-March 2002, search and seizure operations were carried out only on 8 manufacturers under section 26. 4 of these cases were closed due to reasons such as lack of evidence.
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The number of search and seizure operations has further came down to 4 during the period April 2002 to 6th March, 2003. It is also observed that all such operations have been carried out on the basis of specific complaints and prosecution has not reached its logical conclusion in any case. There is a need to sharpen BIS procedures for proper enforcement under this Act.
Adequacy of Scheme of Testing & Inspection (STI) for the Packaged Drinking Water
In the case of packaged drinking water, BIS has developed two STI documents, namely, Doc. 13428/1 February, 1999 for packaged natural mineral water and Doc. STI 14543/1 May 1999 for packaged drinking water. The STI has defined the levels of control in terms of analysis and tests that have to be carried out on the given frequency for various parameters. The manufacturer has to make a decision to accept or reject the quality produced, based on the in-house testing as specified in STI. In the STI, frequency for toxic metals analysis has been specified as once in six months and for pesticides residues and alfa and beta emitters once in two years. The STI also provides for test and analysis of the raw water as also the hygienic criteria of the material in manufacturing premises.
In the European directives, it is found that the frequency of sampling and analysis for water put into bottles or containers for sale varies according to the capacity of production. The number of samples increases with the increase in production. Based on this observation as also comments from several scientific bodies, it is suggested that BIS may consider the desirability of linking the frequency of testing with the
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quantum of production. In other words, instead of a single STI for all licensees, BIS may take into account the quality of raw water, the technology used for purifying and quantity of water produced in a day and develop a STI for that individual manufacturing unit.
The suggestion to have an outside expert committee to examine the suitability of the product specific STI prepared by BIS has also been considered. The certification system of AFNOR, the French National Standard Body, (similar to BIS) which also operates a similar product certification scheme, has a provision for seeking advice on policy matters from a Certification Committee, which deals with all management and developmental policies. BIS may consider setting up product specific committee, as prevailing in AFNOR, having provision for outside expert participation at least for certification of mandatory items. This will enable BIS to involve the mandating body say PFA of DGHS or its nominee to advise on the STI, choice of testing laboratories and overall implementation effectiveness of the scheme.
IV EFFECTIVENESS OF TESTING FACILITIES
It is understood that out of 7 laboratories of BIS, only the Central Laboratory, Sahibabad has the capability of testing of packaged drinking water/packaged natural mineral water for the biological and chemical parameters except pesticide residues and radioactive emitters. BIS is still dependent on the facilities of independent laboratories. It has a documented system of recognizing the competence of laboratories, which ensures broadly the adherence to requirements of ISO 17025. So far BIS has recognized 75 laboratories for various products. Out of these, 13 laboratories have been recognized for
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analysis of water: 10 of them have facilities for testing pesticide residues in water. Six of these independent laboratories have also been accredited by NABL for testing of pesticides residues in water.
The certification scheme is dependent on timely and reliable testing of samples drawn during inspections and from the market place. The laboratories (BIS own and recognized ones) are entrusted with the testing work to be carried out for parameters for which the laboratory is recognized. Thus for pesticides residues only those 10 laboratories have been used which have facilities for testing such residues. As per the scheme of Testing and Inspection, this test is required to be carried out at the initial decision making time for grant of licence and thereafter at two yearly intervals. Two test reports selected at random have been examined for their completeness. It is observed that in both cases the test report is complete, each parameter (organoleptic and physical, general chemical constituents, toxic substances, microbiological) has been tested, the values obtained have been compared with the values specified in the standards and prescribed test methods have been used for each parameter. The test reports for pesticides residues have identified all the 33 pesticides residues, their detection limit as per gaschromatographic test methods was adopted for judging conformity. In one such test report the results have been quantified. For example p-p-DDT result is reported as less than 0.001 mg/l “against detection limit of 0.001 mg/l”. In another laboratory report the results state “not detected”, against the same pesticide. In both the cases the purpose of establishing whether the packaged water sample has met the limits for all the parameters specified other than pesticide residues has been served satisfactorily as the test results are quantified, clear and unambiguous for all requirements. For pesticide residues also the results are expressed as per the requirement of the Indian Standard. The utilization of testing facilities for grant of licence and the periodic surveillance have been examined and considered adequate.
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V STATUS OF ALIGNMENT OF BIS STANDARDS FOR PACKAGED NATURAL MINERAL WATER AND PACKAGED DRINKING WATER WITH CORRESPONDING INTERNATIONAL STANDARDS
One salient feature of international standards is that they have only one standard for drinking water, which would apply to drinking water from a distribution system as well as in bottles or in other containers. For mineral water, however, different standards have been prescribed. The Indian Standard (IS:10500 1991) (first revision) for drinking water specifications derived assistance from the WHO guidelines 1984. The standard also derived assistance from the Manual of Standards for Quality of Drinking Water Supply, Indian Council of Medical Research, 1971 and a similar Manual of Ministry of Urban Development, 1989. The subsequent standards for packaged natural mineral water (IS:13428) and packaged drinking water (IS:14543), formulated in 1998 were also broadly in compliance with the Codex standards and WHO guidelines.
A comparative analysis of the norms for pesticide residues given in BIS standards (derived from detection limits of the test method standards specified in IS:13428 Appendix N), WHO guidelines for water quality 1996 and 2003 (draft), US FDA/EPA, NPD WS of USA and EU Directive 98/83/EC of November 1998 was carried out. It was observed that the list of pesticides, which can be detected by Indian test methods is quite exhaustive and many of these pesticides do not find specific mention in other standards/ directives. The list of pesticides is dependent on the use of pesticides for purposes of agriculture and public health and the situation in different countries may not be comparable.
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A comparative analysis of the parametric values concerning safety of drinking water as given in EU Directive, USFDA, WHO and BIS specification for packaged drinking water ( IS:14543) was also carried out. It was seen that there are differences for the same parameters in different standards and in some cases the BIS norm for contaminant substances is more stringent when compared with corresponding EU Directive, e.g. copper is 2.0 mg/l in EU norm against 0.5 mg/l in BIS, EU norms for fluoride is 1.5 mg/l against 1 mg/l in BIS, similarly EU norm for sulphate is 250mg/l against 200 mg/l in BIS.
BIS, as also the Ministry of Health and Family Welfare have already taken steps to amend the existing standards for packaged natural mineral water and packaged drinking water with a view to align pesticide residues with EU standards. However, it may not, always, be feasible to align the Indian Standards with international standards in totality.
VI LINKAGE OF BIS STANDARDS WITH PREVENTION OF FOOD ADULTERATION ACT, 1954
The Prevention of Food Adulteration Act, 1954 has been enacted to ensure availability of pure and wholesome food to consumers and also to prevent fraud or deception in matters related to food. The Ministry of Health and Family Welfare is the nodal administrative Ministry under the Central Government to administer this Act.
The subject of Prevention of Food Adulteration is in the concurrent list of the Constitution. The enforcement of the PFA Act is mainly done by the State/U.T Governments. The Central Government has formulated Prevention of Food Adulteration Rules, including standards of various food products, which are implemented by State/UT Governments uniformly throughout country.
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With a view to cover packaged drinking water under the PFA Act, 1954 Ministry of Health and Family Welfare issued a Notification on 21.3.2001 declaring packaged drinking water as Food. Prior to that packaged drinking water was not an item of food and hence was not covered under the PFA Act.
The Ministry of Health and Family Welfare also issued Notifications bringing Packaged Drinking Water and Natural Mineral Water under the Compulsory Certification Scheme of BIS through the PFA Act, 1954. Standards prescribed for packaged drinking water/natural mineral water by BIS were adopted under PFA Act after due consideration by the Central Committee of Food Standards under the chairmanship of Director General of Health Services. According to these standards pesticides residue should be “below detectable limits”, when tested in accordance with the test methods of BIS.
The Central Government though empowered under PFA Act to enforce its provisions has taken a conscious decision to leave the enforcement with the States/UTs and local bodies. It, however, monitors enforcement by these bodies through periodical meetings, Annual Reports and surveys.
Section 23 of Prevention of Food Adulteration Act, 1954 lays down the procedure for amendment of Prevention of Food Adulteration Rules including prescribing/amending the standards of food products. As per this provision, the proposal is considered by the Central Committee of Food Standards (CCFS), which is a statuary committee set up under Rule 3 of PFA Act. On the basis of the recommendation of CCFS, the draft notification is published for inviting comments. After receiving comments from public and other interested parties, the final Notification is issued.
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Before BIS certification for a food product is made mandatory under the PFA Act, the standards under BIS and PFA are aligned after due consideration by members of expert committees.
BIS is a certifying agency of these products. Its responsibility is to check the quality of the product at the manufacturing stage, before it is marketed. PFA authorities are the implementing authority in the country who check the product from the market in such cases.
Critical evaluation of the procedures followed by BIS in the context of packaged drinking water/natural drinking water for standardization, certification, enforcement and testing, outlined in previous chapters does not indicate lapses on the part on an individual or organization. However, some weaknesses were observed in the procedures and systems, which have been analysed in the previous pages. No single individual can be held responsible for these weaknesses.
The reported shortcomings in packaged water led to the formulation of this Committee and gave it an opportunity to look into various aspects of standards formulation, certification and testing. The recommendations, which emerge from this study, are summed up in the following paragraphs. Some of them have also been mentioned in earlier chapters.
A. STANDARD FORMULATION
1. These two standards on Packaged Drinking Water were formulated by deriving assistance from Codex and WHO guidelines. At
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that time Codex had not yet agreed upon the relevant test method for detection and determination of pesticide residues. Hence the FAD 14 Committee decided to adopt the test method standard established by another technical committee of BIS, for pesticides residues in fruits, vegetables and soils. These standard test methods were not specifically meant for drinking water. In the normal course these standards were due for review in 2003 and in all likelihood the Sectional Committee would have derived assistance from the test methods now available. Hence, a pro-active approach towards keeping the standards dynamic and at par with international developments in related fields is necessary. This would ensure that BIS strives for continuous improvement of standards by providing for an in-built alert system, which would flag emerging problems before they assume threatening dimensions.
2. BIS has stated that its standards are dynamic. However, beyond a provision for reaffirmation or review after five years, no means of evaluating the validity of standards in a rapidly changing scenario have been explicitly laid down. For this, BIS should have a Core Group of Scientists from various fields with the responsibility of keeping track of recent scientific and technical developments in critical areas. These scientists would alert the BIS management on the need to update and revise particular standards even before the review is due.
3. When BIS establishes a standard, it must specify the corresponding test methods. In the amended standards (Amendment No. 4 of February 2003) it has been stated that “the analysis shall be conducted by using internationally established test methods meeting the residue limits specified”. This is vague and has left the choice of method to laboratories, which will lead to confusion, as it will not permit comparison between the results of different laboratories. BIS should constitute a Committee of Experts from the leading research institutions like Central Pollution Control Board (CPCB), National Institute of
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Nutrition (NIN), Central Food Technology Research Institute (CFTRI), Central Food Laboratories, Indian Toxicological Research Centre (ITRC), Indian Institute of Technology (IIT), National Environmental Engineering Research Institute (NEERI) etc engaged in evaluation of water quality for a review of the standards specified in IS: 13492 and IS: 14543 in order to specify the test methods to be followed by the testing laboratories.
4. For standard formulation different Sectional Committees and Divisional Councils should not work in isolation. It is desirable to have a coordination meeting of all concerned Divisional Councils and Sectional Committees for a closer participation of the experts in all related fields, before the standards are finalized.
5. Draft standards should be put on the website of BIS with a view to obtain comments from all interested individuals and groups. This should be brought to public notice by giving advertisements in the print and electronic media. For the sake of transparency, the constitution of the various committees, panels etc. involved in standards formulation should be on the web. This would exert covert pressure on the members as each has a reputation to protect.
6. It is sometimes stated that vested interests, particularly of big industrial houses, influence the standard formulation activity of BIS. This criticism emanates from the fact that standard formulation is a voluntary activity and BIS does not pay anything, even in terms of TA/DA, for participation in meetings of the Technical Committees set up for standard formulation. As a result, at times, participation of scientific organizations and consumer organizations remains on paper while industry participates in a more active manner. There is, therefore, an urgent need to take remedial measures to get over this problem.
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7. Drawal of market samples is a simpler and more cost-effective means of quality control and should be made better use of. There is a scope for substantial improvement in drawal of market samples.
8. Enforcement under section 26 of BIS Act is weak. Search and seizure operations are carried out on the basis of specific complaints and prosecution does not reach its logical conclusion for several years. There is a need to sharpen BIS procedures for effective enforcement under this Act.
9. The Scheme of Testing and Inspection (STI) is prepared by BIS by in house consultation with the concerned Departments. The scheme is crucial to certification and specifies the levels of control and the frequency of tests considered necessary for manufacturing units to ensure adequate quality control and compliance to the specifications. BIS prepares one STI for each product, after due consideration of the specifications in the relevant standard but this STI, once prepared becomes applicable to all licensees of that product. In the European directives, it is found that the frequency of sampling and analysis for water put into bottles or containers for sale varies according to the capacity of production. The number of samples increases with the increase in production. Based on this observation as also comments from several scientific bodies, it is suggested that BIS may consider the desirability of linking the frequency of testing with the production. In other words instead of a single STI for all licensees, BIS may take into
account the quality of raw water, the technology used for purifying and quantity of water produced in a day and develop a STI for that individual manufacturing unit.
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10. The certification system of AFNOR, the French National Standard Body (similar to BIS) which also operates a similar product certification scheme, has a provision for seeking advice on policy matters from a Certification Committee, which deals with all management and developmental policies. BIS may consider setting up product specific committees, as prevailing in AFNOR, having provision for outside expert participation at least for certification of mandatory items. This will enable
BIS to involve the mandating body, say PFA of DGHS or its nominee to advise on the STI, choice of testing laboratories and overall implementation effectiveness of the scheme.
11. When BIS certification for an item of mass consumption like packaged water is made mandatory, it increases the responsibility and answerability of BIS towards the consumers. BIS should have a complete in-house review of its resources before accepting this responsibility. Inadequacies of manpower and other resources should be identified and ways to fill up those gaps be explored before the challenge is accepted. But once BIS has accepted this responsibility, it must discharge it faithfully and not cite lack of manpower or resources as justification for non-adherence to the norms. BIS Act already has provision for appointment of ‘Agents’ for purposes of “inspection, testing and such other purposes, as may be prescribed” (section 10(l) of BIS Act). The provision needs to be put to proper use.
12. BIS should recognize only those labs, which have NABL accreditation for all parameters of contaminants in water as per revised standards. Further, BIS’s own laboratories should take such action as is necessary to comply with the requirements of ISO 17025 by obtaining accreditation from NABL for testing of water.
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D. GENERAL RECOMMENDATIONS
13. The Bureau of Indian Standards, the National Standards Body of India, became functional as a statutory body under the Bureau of Indian Standards Act, 1986 with effect from 1 April, 1987 taking over the staff, assets and liabilities of Indian Standards Institution established in 1947. For over 50 years this institution has been successfully promoting and nurturing the standardization movement in the country. It has provided for the harmonious development of standardization, marking and quality certification of goods. However, there is now a need for BIS to revitalize its core competencies. The existing procedures of BIS formulated several years ago are somewhat shrouded in secrecy and confidentiality. Government is, however, committed to greater transparency. There is also a greater participation of people in decision making. The increased use of computers, the internet and websites has made it possible to reach out to people in a cost effective way. BIS should overhaul its procedures in the light of these developments and increase transparency in its operations. List of members of Technical Committees, draft standards, list of licensees and their present status may be put on its website and updated at monthly intervals. The possibility of placing test reports of samples drawn from factory or market on the web may also be considered. The present provisions in BIS Act and Rules, which specify confidentiality of various details obtained from licensees, may be reviewed by expert groups, which may include legal experts, with a view to achieve maximum transparency.
14. BIS certification system has adopted the self-certification model of ISO Guide 28, which has served the purpose of ensuring compliance to the standards as against a 100% inspection and testing scheme. To remove any doubts about the effectiveness of the products certification scheme, BIS may consider accreditation of its product certification system following the ISO 65 Guidelines by suitable bodies like RVA, The Netherlands. Such an accreditation is a mechanism to bring
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transparency in operations, making the systems more credible, having built in diagnostic and corrective measures. The quality management system of BIS (ISO 9000 standards) is already accredited by RVA, The Netherlands.
15. The presence of pesticides in packaged water caught many a headline in prominent newspapers in February 2003. The study into this
issue has revealed that pesticides in bottled water are there because they are present in the source of water. Also, that we are consuming much higher quantities of pesticides in milk, foodgrains and other food products. No doubt pesticides in packaged water can be reduced even to trace level by amending the standard, resorting to better manufacturing practices and ensuring that the source of water is not
polluted. However, some thought needs to be given to the overall problem of increasing water pollution, since it has serious implications for the health of our people. In the developed countries, there is only one standard for drinking water and countries are expected to ensure that all drinking water for human consumption, whether it is made available through the distribution network or in containers, conforms to those standards. Why should these standards be limited to bottled water alone, which after all is consumed only by the privileged? It is time that consumers demand pollution free drinking water and Government/Municipal machinery gears itself up to meet this rightful demand.
16. The provisions of product certification in BIS Act, 1986 and BIS (Certification) Regulations 1988 are basically the same as they were in ISI (Certification Marks) Act, 1952 and Regulations 1955, a model of voluntary certification. It needs to be considered whether those provisions, which were more appropriate for a voluntary certification system are adequate to provide safety for certifying the quality of every single bottle/container of packaged water and ensure the safety of public health. This aspect also requires an examination by a technical
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committee which should advise either improvements in BIS operations or identify other means of assuring the quality of packaged drinking water. This may mean appointing outside agencies which have necessary resources and expertise in monitoring water quality.
17. There is also need to review the permissible limits of contaminants in other food products under PFA. This may also lead to a wider discussion regarding permissible levels of use of pesticides and fertilizers for agriculture and horticulture purposes. As long as pesticides and fertilizers are used for agriculture, they would have an adverse effect on food and water.
18. It is a matter of concern that due to constant tapping of ground water, the water level gradually goes down and it may change the total dissolved solids concentration (TDS) in the water and may require aggressive processing to keep the TDS in desired concentration. To cut the cost of processing it is likely that industry may start by-passing the total processing of the whole water. Hence it is recommended that a water re-charging system should be made mandatory for this industry and before renewal of licence, a NOC from the concerned monitoring agencies should be obtained. Some guidelines regarding selection of sites for installation of packaged drinking water industry are also required to ensure their location in pollution free areas. Disposal of wastes from the water purification plants also needs to be monitored.