Proposed Amendments to the Food Reg Max Limit for Inorganic Arsenic in Husked Rice

AgriFood Veterinary Authority of Singapore

Consultation Period: 31 Jul 2017 - 29 Sep 2017

Status: Closed - Summary of Responses

Consultation Outcome

RESPONSE TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON PROPOSED AMENDMENTS TO THE FOOD REGULATIONS REGARDING MAXIMUM LIMIT FOR INORGANIC ARSENIC IN HUSKED RICE

The Agri-Food and Veterinary Authority of Singapore (AVA) initiated a public consultation exercise for the period 31 July 2017 to 29 September 2017 on the proposed amendments to the Food Regulations regarding maximum limit for inorganic arsenic in husked rice. Feedback was sought from stakeholders (rice importers and food manufacturers) on the following:

I.  Whether the husked rice imported by the company is able to comply with the new proposed maximum limit of 0.35 ppm inorganic arsenic.

II. Whether the company would be able to find alternative sources should their imported husked rice be unable to comply with the new proposed maximum limit, and the estimated timeframe required to do so.

A total of 13 comments were received at the close of the public consultation exercise.5 out of the 13 comments were affirmation from the industry that they were able to comply with the proposed maximum limit for inorganic arsenic in husked rice. There was 1 comment received from a rice importer requesting AVA to adopt a more stringent limit for inorganic arsenic in husked rice, following the limit imposed by the European Union. The remaining comments mostly pertain to enquiries on requirement for laboratory testing for inorganic arsenic in husked rice, (with one importer voicing concerns on the additional costs to be incurred should AVA require testing for every batch of imported rice) as well as import requirements for rice.

AVA has responded to all the comments provided by stakeholders. With regard to the concern raised by a rice importer on the additional cost incurred for laboratory testing for inorganic arsenic in husked rice, AVA has clarified that rice importers do not need to submit test reports to AVA to certify that every batch of rice imported by them complies with the new limit. Rice importers should periodically conduct laboratory testing on the imported rice to monitor compliance with the legislative requirements.

With regard to the request to adopt a more stringent limit for inorganic arsenic in husked rice, AVA has explained that the proposed maximum limit of 0.35 ppm for inorganic arsenic in husked rice is consistent with the maximum limit adopted by the Codex Alimentarius Commission (the international food standards setting organisation) in 2016. AVA will continue to monitor international development in this area and review our limits in future, if needed, so as to protect public health.

Based on the feedback received, AVA notes that in general, stakeholders have no objection to the proposed maximum limit for inorganic arsenic in husked rice. As such, AVA plans to incorporate the proposed maximum limit for inorganic arsenic in husked rice in the 2018 amendments to the Food Regulations. After the official gazettal of the amendments, the industry will be given a 12-month grace period to transition to the new limit of 0.35 ppm. 

AVA appreciates the time taken by stakeholders to submit comments which have contributed to the decision making process. We would like to encourage all stakeholders to actively participate in future calls for comments.  

Response to Comments Received from the Public Consultation on Proposed Amendments to the Food Regulations Regarding Maximum Limit for Inorganic Arsenic in Husked Rice

Detailed Description

Aim

The Agri-Food and Veterinary Authority (AVA) is seeking feedback from stakeholders (rice importers and food manufacturers) on proposed amendments to the Food Regulations concerning the maximum limit for inorganic arsenic in husked rice.

Background

Maximum limits for incidental constituents, commonly termed “contaminants” are specified under the Food Regulations. Arsenic is a naturally occurring element, and is present in many foods due to absorption from the soil and water. In order to safeguard consumer health, maximum limits for arsenic in food are specified under the Food Regulations. 

Rice, in particular, takes up more arsenic than other foods, and due to its high consumption, can contribute significantly to arsenic exposure. Inorganic arsenic is the more toxic form of arsenic and long-term dietary exposure can cause cancers and skin lesions.

Proposed Amendment

The current limit, specified under the Tenth Schedule of the Food Regulations is 1 ppm of total arsenic for “Other food not specified above [in the Schedule]”. Husked rice is included in this category.

In 2017, AVA amended the Food Regulations to include a maximum limit for inorganic arsenic in polished rice, to better protect consumer health. Following the adoption of the maximum limit for inorganic arsenic in polished rice, AVA proposes to adopt a new limit of 0.35 ppm for inorganic arsenic in husked rice. The proposed new limit is consistent with the maximum limit of 0.35 ppm (inorganic arsenic) adopted by the Codex Alimentarius Commission¹ in 2016. The proposed new limit will ensure that consumers are better protected from overexposure to arsenic.

The proposed new limit will apply to husked rice (brown rice or cargo rice) imported under the following HS codes:

HS CodeDescription
10062010 Thai Hom Mali husked or brown rice
10062090 Other husked or brown rice

Once the amendments take effect, husked rice containing inorganic arsenic at levels exceeding the new limit will not be allowed for import into Singapore for sale or use as ingredients in food manufacturing.

¹ The Codex Alimentarius Commission is the international food standards setting body formed by the Food and Agriculture Organisation (FAO) and the World Health Organisation (WHO).

Request for comments

AVA invites views and comments on:

i. Whether the husked rice imported by your company is able to comply with the new proposed maximum limit of 0.35 ppm for inorganic arsenic.

ii. Whether your company would be able to find alternative sources should your imported husked rice be unable to comply with the new proposed maximum limit, and the estimated timeframe required to do so.

Procedure and timeframe for submitting views and comments

AVA welcomes views and comments on the above proposal. All submissions should be clearly and concisely written, and should provide a reasoned explanation for any proposed revisions. Submissions should reach AVA no later than 6:00 p.m., 29 September 2017, through mail, or email (preferred), to the following addresses:

Mail:

Regulatory Programmes Department
Agri-Food & Veterinary Authority of Singapore
52 Jurong Gateway Road #14-01
Singapore 608550

(Attention: Mr Cheng Chee Seng)

Email: cheng_chee_seng@ava.gov.sg