Thiruvananthapuram 

15-11-2013

To,

Food Safety Commissioner for Kerala,

Office of the Commissioner of Food Safety,

Vazhuthacaud, Thiruvananthapuram.

Respected sir,

Sub : Issual of notice to “Organic Bazaar” under the FSSAI Act 2006, Section 32 – Reply and request for re-consideration and cancellation of notice – reg.

Dear Sir,

On 8th November 2013, on the 10th anniversary celebrations of the social enterprise “Organic Bazaar”, we were issued a notice by the Designated Officer and State Licensing Authority of Thiruvananthapuram District, represented by Sri D Sivakumar.

The Notice demanded that within 7 days we reply with details regarding

1)      The Organic standards we follow for our organic products

2)      Organic farms from where we collect the products

3)      The approved certifying agency that has certified the products from these farms

4)      Results of accredited laboratory analysis of the products to prove it is pesticide free.

5)      Proof that products supplied to the Bazaar does not have non-organic food materials

6)      Other matters related

 We would like to submit the following

1)      Organic Bazaar is a social enterprise presently run by a registered society “Trivandrum Organic Farmers Producers and Consumers Association (TOFPCA)”. Organic Bazaar was initially launched by Thanal in 2003 to help Organic farmers and producers to connect to the health conscious consumers in Thiruvananthapuram and be involved in the efficient exchange of organic food. Since its inception, it was working in a very informal basis, and was only connecting produce from small and marginal farmers, women farmers and Kudumbasree groups to the consumers in Thiruvananthapuram.

2)      Thanal is a public interest research organization working on issues related to environmental health and environmental justice since 1997. It started to work on issues of industrial pollution, pesticides, toxic waste from 1997 onwards and working towards sustainable solutions like organic /ecological agriculture, zero waste , sustainable development from 2002 onwards. Founder members of Thanal have an experience of working in the field of agriculture and environment for the last 30 years.

3)      In 2002 Thanal started to work on Zero Waste Kovalam project with the support of Tourism department and Venganoor panchayath. As part of this project it started a training programme for the local women on paper bag making, coconut shell products, tailor discards and organic farming.

4)      Initially 3 groups of women were trained on organic farming and they started the cultivation, mostly of vegetables. Most of these women were landless , were part of Self help groups under Kudumbasree Mission and very poor. They took land on lease and cultivated. Initially they were consuming whatever they produced, and later they started to market them in the local markets. With small quantities of produce it became uneconomical to go to the local markets. They discussed this issue with the Thanal team about what can be done. It was Thanals commitment to support these small farmers with an organic market that led to the establishment of the Organic Bazaar.

5)      Organic Bazaar was initially a joint project, supported by an organization called IIRD, Institute for Integrated Rural Development, based in Aurangabad. They had some experience in organic markets by then. Dr Alexander Daniel , who was the director of IIRD then , was also a pioneer in the field of ecological organic agriculture and was a member of IFOAM. The main idea of starting a Bazaar was to motivate more farmers to convert to organic safe food production systems.

Without assuring a market this was not possible. Even now many organic farmers are not able to sell their produce because there is no market near by. Basically we consider Organic Bazaar as a platform where organic farmers and consumers can come together, and support each other .

6)      Thiruvanathapuram Organic Bazaar began on November 1^st 2003 at Sugathan Memorial Hall as a monthly fair of organically produced vegetables and fruits. This was a time when the national standards for Organic produce was still being finalised and Thanal adopted the standards and adapted it for its Organic farmers and produce ( copy attached). The Organic Bazaar based itself on the four principles of Environmental Stewardship, Accountability, Transparency and Building an Alternative approach in local marketing. Even, during those times, when there was no FSSAI Act, the Farmers who supply to the Organic Bazaar maintained a record of their farm, their practices and was verified by Thanal's technical staff. They also took an Organic farmers pledge. There were only handful of farmers who were selling through the Bazaar in 2003.

7)      When number of farmers ( mostly women with 3-50 cents of land and some even cultivating in pots/ bags ) increased we increased the frequency of the Organic Bazaar to twice a week, and then again thrice a week. From 2009 onwards it became a full time market where business happens every day. In 2010, the Trivandrum Organic Farmers Producers and Consumers Association was registered, and the Organic Bazaar is now run under this Society as a Social enterprise.

8)      Unlike many other organic outlets, Organic Bazaar is a social enterprise . Here profit is not the objective. The objective of the bazaar is to help small and marginal organic farmers and consumers who are interested ( parents with small children, people who are chronically ill, people who are sensitive to environment etc) to access safe and nutritious food.

9)      Now we have 50 local farmers from Trivandrum district and 3 groups of farmers who are from Wayanad, Palakkad and Thrissur districts. Many of these farmers are part of state level Jaiva Karshaka Samithy or Zero budget farmers alliance. They are all self motivated organic farmers who are committed to environment and peoples’ health. They are not cultivating just for doing business. They are actually doing a service to the society.

10)Organic Bazaar assures traceability of its products through a documentation process, farmer-consumer interaction, field visits by Thanal team, exposure visits of consumers to the organic fields etc. Even consumers honor the best organic farmers and encourage them by various means. This is a process that Thanal has been runnning to ensure Organic integrity for now 10 years.

111)Organic fields of farmers who supply to Organic Bazaar are often visited by officials from agriculture department and agriculture university and also students from various institutions to learn about organic farming. This also ensures the integrity of the product. Numerous media reports have also been published regarding the farmers of the Organic Bazaar, as well as the integrity of the programme itself.

112)We have built this marketing system pain stakingly and with a lot of care so as to ensure quality of the produce. This is accepted as a model by various agencies and many small groups have started similar enterprise in the state to encourage more people to cultivate and consume safe and healthy food. Here we wish to upfront state that this is a model which is a clear, safe and responsible alternative to the exploitative model of present markets.

113)This model was widely discussed during the formulation of the organic farming policy of Kerala and the policy has accepted the idea of internal control system( ICS) and Participatory Guarantee System( PGS) of assuring the quality of organic products, as an alternative to the third party certification system, and even costly lab tests. Here we would like to state that converting farmers and farms totally to organic is a much better guarantee than the Third Party System (TPS) system of certification, and even irregular lab tests, which can be manipulated.

114)The National Programme for Organic Production (NPOP) has its National Standards for Organic Production (NSOP) that is the approved standards for Organic production in India. NPOP is implemented under FTDR Act 1992, under the Ministry of Commerce for exports. NPOP is implemented under AGMARK by Ministry of Agriculture for the domestic market.

115)Apart from the Third Party Certification Systems (TPS), the NPOP has recently accepted the Participatory Guarantee System (PGS) for certifying organic farms and farmers for local markets. This production standard approved under NPOP is what many farmers are slowly adopting for their farms. Its one standard that does not focus on product certification, but certifies farms / farmers. This was discussed in detail with the FSSAI Authority as well, requesting that they adopt this system for standards, since third party certification is not suitable to the small and marginal farmers of the country.

116)We wish to point out here that the present FSSAI Act 2006 section 22(3) clearly says - “organic food” means food products that have been produced in accordance with specified organic production standards. But the Act has not specified the organic production standards that need to be followed. Infact even after 7 years of its promulgation, we do not have a standard specified under the Act for Organic food. In this situation, we have been following a standards developed by Thanal, that is fully compliant with the NSOP.

117)Neither the NSOP nor the approved PGS system demand any testing to prove that products are pesticide-free. Even in the case of third party certification this is not mandatory. The inspection agencies demand only clear processes, inspections and proper documentation. It is not possible for small farmers to undertake such costly testing in the first place and it is not reasonable to ask for it since many factors are not in their control, like water, arial drift, environmental contamination etc. They can only control their production systems.

118)On a more logical note, is it not ironical that those farmers who produce using dangerous pesticides and chemicals go scot free and have never been pulled up for their practices, nor have they been asked to prove that their products are pesticide-free ( logic says that those who use pesticides should demonstrate that they remain within the MRLs specified). Instead the organic farmer who does not use pesticides and take a lot of trouble to produce safe and ecologically friendly products is forced ( or harrassed ) to produce certificates etc for their produce.

119)Moreover, it is also a fact that even if we have to ask our farmers that products must be tested, the FSSAI has not accredited any lab under the Act for organic products testing. Moreover we acknowledge that pesticide residues in food and products is a major concern. But simply asking for testing of pesticides alone, without setting any standards for organic products is too arbitrary and not-scientific at all. Infact, organic food is defined by many aspects; shelf life, taste, texture, water content, process gurantee, natural smell and many more including nutritional factors. Agencies across the world are struggling to find a laboratory protocol for measuring this and till date we do not have an accredited lab that can test and certify the product. Hence various agencies including in India ask for a process based guarantee. The present testing of pesticide residue are on codex standards and not based on organic standard requirments, which simply does not capture the quality of organic produce.

220)We would like to put before you that what ever local organic produce we procure from farmers in 3-4 panchayaths near Trivandrum follow the standards developed by Thanal based on the NSOP, and adopted by the Organic Bazaar, for want of other approved standards under the FSSAI Act, and Thanal does the field monitoring and process documentation. 

221)  Hundreds of small organic retails in the country also follow the same methods . They all got in to marketing not to do business and make money , but to support organic farmers and consumers. Now many farmers also have started their own outlets . We see it as a great opportunity for us to save ourselves from the pesticide trap.

222)  In Kerala now Kudumbasre Mission and some Jilla panchayaths have started projects on organic farming and it is encouraging . They are mostly small and landless women and cannot afford any testing of chemicals in their products. It is unjust to ask for such testing right now, that too without even a proper guidelines under the FSSAI Act 2006. 

223)The controversy now raised due to finding of pesticide residues in vegetables collected from some organic outlets in Trivandrum should not in any way kill the growing organic farming movement in the state and the development of small organic retail. This issue need to be discussed at the state level with organic producers and small retailers. We hope that you will take the initiative to do that before taking any action on such social enterprises. In this context, we wish to reveal that on our own enquiry, the scientists who did the study told us that they did not take samples from Organic Bazaar because we already have a standards, and full traceability and our farmers and processes are known. 

224)Thanal is also a member of a national alliance called ASHA( Alliance for Sustainable and Holistic Agriculture), with 400 organisations and experts working on sustainable agriculture. Thanal is also part of the Organic Farmers Association of India (OFAI) and were founder members of the Participatory Guarantee System (PGS) Council of India. The ASHA network has identified this local level small retail marketing of organic produce as being seriously affected by the provisions of the FSSAI Act 2006, and we had official discussions with Sri Chandramouli, the Chairperson of the FSSAI and have been interacting with Col. C R Dalal, Director (Enforcement/Surveillance) on this matter. They have also told ASHA that there is very little clarity regarding standards for Organic produce, and hence can start acting on compliance only after such standards are developed and promulgated after wide discussions with all stakeholders.

This being the situation, we humbly request that

1.      Organic Bazaar be allowed to operate at its present level, with the present system of standards, till such time as proper standards for Organic produce is established by the FSSAI.

2.      A consultation meeting be called up as soon as possible with all the Organic retailers and outlets in Kerala, to understand the issues faced by them in organic produce retailing. Thanal, with a decade of experience on this, can help organise such a consultation if needed, as it is directly connected with all such retailers, as well as national level experts on this matter.

3.      Since the matter and the issues raised here need resolution at a higher level, we request that the notice issued to Organic Bazaar be cancelled.

Thanking you in anticipation

Yours truly

Sridhar R

Programme Director

(Ph: 09995358205 ; email :  mail.thanal@gmail.com ) 

(Incharge of Organic Bazaar)

OD-3, Jawahar Nagar, Kawdiar, Thiruvananthapuram – 695003, Kerala,

email :  ob@thanal.co.in, Ph : 0471-2727150