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  • Writer's pictureDr. P.K. Shrivastava


(The article examines the reasons and suggests remedial measures, for safety of dairy foods)

Author: Dr PK Shrivastava, Dairy Business Guru, Bangalore

Food is a major factor contributing to the people’s health, nutritional condition, and productivity. As a result, the food we eat must be nutritious and safe. Food safety is a basic human need that must be met to achieve a world free of hunger and poverty on a global scale. Food safety standards are the rules and practices that food producers, processors, food supply outlets and consumers must follow to ensure food safety in terms of hygiene and health.

A country must enact and enforce proper laws and regulations to build and operate a comprehensive food safety system. Food safety has become a serious problem around the world, specifically in India. Food safety issues can originate from two main sources, a failure to follow established protocols or an intentional attempt to deceive(1). Source:

It is more than a decade (from 2011), when India’s food safety and standard Authority came into existence (FSSAI ACT 2006, Regulations 2011). It is more than 2 decades (from 1997), when India surpassed US in milk production to become the largest milk producing country in the world, though it is second to US in cow milk production. Means India gets the top position in milk production, due to adding buffalo milk with cow milk. Most of the developed countries do not have buffalo population, as such they maintain only cow milk data (New Zeeland, USA, etc.). Majority of Indian dairy houses do not maintain separate line for cow and buffalo milk, as a result, whatever comes to the consumer is mostly a mixed milk or a product prepared from the mixed milk.

The adulteration of food in India is a big concern, says Karan Chechi of FnB in his publication on 14th Sept 2021 (Figure 1).

Figure 1: Food safety is a concern for India

Be it any type of claim, any country’s presence in the world matters the most, which is achieved through exports of its products to other countries. Looking at the available Indian dairy export scenario, we find that it took a noose-dive after 2013 (705 million USD) till 2016 (50.63 million USD), thereafter revived a bit during 2017 (366.6 million USD) and dwindle thereafter till 2020 (73.33 million USD). Quality of milk could be one of the factors for dwindling dairy exports in India, besides COVID-19.

In developed countries the milk is generally collected from organised farms and tested for total solids, protein, presence of bacterial load, fungal toxins, hormones, adulterants, etc. at the entry level. However, in India, most of the milk is collected from several small milk pooling centers, where large number of “small-herd” owning farmers pour milk. Here, generally Fat & SNF is tested at the entry level. There was a need felt by FSSAI to actually examine, what is the level of adulteration in milk in India. A survey was conducted during May-October 2018 by FSSAI using, 6432 samples from all states and UTs of India. The survey reported only 12 (0.19%) out of 6432 samples unfit for human consumption (Brief in Figure 2, details in (reference 2).

Figure 2: Brief of National Milk safety and Quality Survey 2018, by FSSAI

We know that once the milk gets adulterated at the pooling points, it remains adulterated throughout its journey, till it reaches to consumers, may be in diluted concentration, for which the consumers are unaware (no branding needed for the adulterants found under permissible limit). Adulterants could be urea, neutralizers, H2O2, maltodextrin, mycotoxin, formaldehyde, colouring agent, etc. Similarly, if milk is collected with heavy bacterial load through the collection point, the bacteria multiply in logs till the milk gets processed. The cold chain helps only to restrict the speed of bacterial growth, it never kills the bacteria.

The mycotoxins, specially, Aflatoxin M1 (AFM1) found in milk, comes by feeding infected (with fungus) feed & fodder to the animals (reference 3). Testing strips are available to detect the presence of mycotoxins in raw materials, which can indicate use of suitable toxin-binders to negate the effect of toxins, from finished livestock feed. The permissible limit for AFM1 has been fixed by the FSSAI for various food items (including milk 0.5 μg/Kg) and also it has suggested the use of suitable toxin-binders in livestock feed manufacturing. FSSAI has come out with a regulations and manuals for the users for restricting entry of adulterants in food items, including milk.

A study (reference 2) published in “Food Additives & Adulterants-Part B”, by Himani Sharma, et al, concluded that AFM1 presence in milk in Hisar city (Haryana), which ranged from not detectable to as high as 2.281 μg/Kg (very high compared to the permissible value 0.5 μg/Kg). The study observed that pasteurised milk samples were more contaminated with AFM1, than those sold by local traders and vendors. This may be due to contamination of milk with AFM1 at large scale in the raw milk samples subjected to pasteurisation (reference 2) (Figure 3). We all know that most of the urban population consumes pasteurised milk.

Figure 3: Research paper of Himani Sharma et al:

Presence of AFM1 has been into milk, much before the FSSAI undertook the National Food safety & Quality survey in 2018. Due to sufficient evidence with respect to its cancer-causing potential, WHO International Agency for Research on Cancer (IARC) has classified AFM1 under group 1 i.e. carcinogenic to humans (Ostry et al. 2016) (reference 2). An analysis of 122 articles from Jan 1988- Feb 2020, with sample size of 18921 found that the prevalence of aflatoxin M1 in milk is high worldwide4. Therefore, considering the importance of the milk group and its products, special measures should be taken to protect the ration from aflatoxin moulds and milk quality (reference 4). Such studies might have alarmed FSSAI to take up “Food Safety survey” and include assessment of AFM1 (reference 2) (1st time a survey for assessment of AFM1 was undertaken in India), which indicated that the adulterants were found in various states of India. The top three states were Tamil Nadu (88 out of 551 samples), Delhi (38 out of 266 samples) and Kerala (37 out of 187 samples) (reference 3). Figure 1 indicates that in overall adulteration in food, UP and Mizoram were severely affected states (reference 1).

FSSAI had imposed penalties on FBOs (Food Businesses Operators) in case of non-compliance with food standards. Clear message is being sent that “someone is watching”. Rupees 10 lakhs was fined for misleading advertisement or false description, Rs 2-5 lakhs penalty was imposed for substandard food qualities (reference 1). One can observe that advertisements in TV for food items are now using “safe statements”, to save their skin. However, I fail to understand, under which regulations the “gutkha” advertisement is allowed on TV?


In India almost all big organized dairies use “multi-point pooling system” for procuring raw milk. In this system, thousands and lakhs of individuals pour milk to pooling pots, where the quality assurance and food safety, in the absence of affordable testing tools, is almost impossible. In farm milk production system, the milk testing could be done at farm gate and entry of adulterants could be restricted to a great extent, however, enroute adulteration need to be ensured. In the farm milk production system, ensuring food safety is easier compared to the procurement through multiple pooling points. As such, time has come to promote “farm-produce milk” by (a) providing special subsidy to “large-herd-farms”, (b) offering premier pricing to farm fresh milk by procuring dairies (as small quantity of farm milk improves the quality of a large quantity of procured milk) and (c) providing subsidy to dairy farms on testing tools, etc. This will encourage establishing more organized dairy farms in India, which will reduce the adulteration in milk, to a large extent.

Restricting, the entry of AFM1 in milk pooling system, seems next to impossible as feed & fodder getting tested at each & every farmer level is difficult. In this system majority of pourers are small or medium farmers and/or landless laborers, who can’t afford the cost of testing tools for feed & fodder. In view of above, the large dairies may not be able to restrict entry of AFM1 adulterant into the raw milk at pooling points and AFM1 will keep coming in pasteurized milk (reference 2).

The livestock feed factory owners (many of the big dairy houses own livestock feed factories) can do a lot good to restrict the presence of AFM1 in milk, by using the toxin-binders, as suggested by FSSAI, while manufacturing the livestock feed.


FSSAI is an apex body, which is responsible for deciding the “food safety standard parameters” for all the food items in the country, including imported food items and milk & milk products. FSSAI work with the state authorities for enforcement of the provisions on food safety. It is a huge job for FSSAI. Enumerable Indian cuisines (standard or non-standard), vendors, FBO, raw materials, etc., and day-in and day-out the innovation in food-cuisines create a tortuous route for FSSAI.

In the humpty number of food items, dairy is also one sector, which has got several products and thanks to the ever-changing food habit of Indians, it adds new dairy products in the market every time. Dairy itself has a vast organized & un-organised market. Vegan foods have entered with misbranding (Example: soya milk & Paneer-tofu). It is obvious that the FSSAI personnel posted in particular location need to keep them abreast with the various technical details of milk & milk products. Understanding this fact and looking to the vast milk-market segment; the big Dairy organizations are raising demand for constituting a separate regulatory body for milk & milk products. The body so constituted may regulate the food safety & standard parameters and provide other supports to dairy industry, thereby reducing the job of over-burdened FSSAI.


1. Despite having a legal framework in place, India still struggles with enforcing food safety norms and standards effectively. Mainly due to insufficient number of laboratories & technical manpower in the country. Even today, the number of laboratories per million people in the country is far below compared to other countries like China and US.

2. To bring more & more non-standard food items into the ambit of standard-food items and decide their standard is a dynamic process.

3. To build infrastructures, as the total labs available in India are about 915, of which 615 are for food and 300 for water testing, only 172 labs are FSSAI notified, 72 state & public food labs, 12 referral labs, 82 NABL accredited private labs, others are the institutional labs, which tests samples only for their own institutions.

4. To urgently upgrade the infrastructure in most of our existing food testing laboratories. In many cases, laboratories have had to be shut down due to the absence of Food Analysts. FSSAI has published list of food testing laboratories in the country (reference 6).


1. Encourage private sector participation in setting up, upgrading and maintenance of laboratories, under the Ministry of Food Processing under the scheme “Setting Up/Up-gradation of Quality Control/Food Testing Laboratory”, which provides assistance to Central/State government organizations/Universities and other implementing agencies/private sector organizations,

2. Use WHO suggested “5 keys to safer food” for all handlers and consumers (reference 5);

· Keep Clean

· Separate Raw & cooked

· Cook thoroughly

· Keep food at safe temperature

· Use safe water and raw materials

Food safety is a shared responsibility, individual consumers and food handlers play a huge role in preventing food-borne diseases(Reference 5)

3. Govt to promote establishment of “large-herd dairy farms” through suitable subsidy schemes, which can actually reach to the entrepreneurs, by improving ease of working,

4. Big dairy houses to encourage & support “large-herd farms” and increase the percentage of farm fresh milk into the total procured milk,

5. Govt to subsidize the “Adulteration testing kits” and “arrange for affordable testing devices” for quick detection of adulterants in milk at farms and pooling points,

6. Govt should not allow CF manufacturing without the testing and neutralizing AFM1 from raw materials

7. Create an apex regulatory body for milk & milk products



2. Food Additives & Contaminants-Part B; Aflatoxin M1 in milk in Hisar city, Haryana, India and risk assessment: Author: Himani Sharma, Vijay J. Jadhav, Sudhi R Garg; page 59-63, published online:25th Nov 2019

3. 18_10_2019.pdf (National Milk Safety and Quality Survey 2018 by FSSAI from)

4.; Aflatoxin in milk worldwide from 1988 to 2020, a systematic review and Meta-analysis; Volume 2020 |Article ID 8862738


6. Validity_03_12_2021.pdf

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