Formalin in Fish is now “Permissible” and “Safe”!

By Ashwin Tombat
16 June 2019 11:51 IST

A notification issued by the Food Safety and Standards Authority of India (FSSAI) on 10 June 2019 has fixed the ad-hoc limit of Formalin (Formaldehyde in water) in fish.  The limits are:
(1) Sweet Water Fish, including shellfish and prawns: 4.0mg per kg
(2) Fish/shellfish/prawns from the Sea or brackish water: 100.0mg per kg
The Scientific Panel of the FSSAI says these are the ad-hoc permissible limits of “naturally occurring formaldehyde” in fish till a final, detailed assessment is done.

For sea-fish-eating Goans, this means that all fish containing less than 100ppm (parts per million) of Formalin is now “legal” and can’t be stopped from being sold. Up to now, fish could not contain any Formalin at all, as the Food Safety and Standards Rules, 2011, did not set any permissible limit. The FSSAI has not disclosed the names of the scientists in its “Scientific Panel”, nor their reasoning for setting these limits.

Some clues can be found in the FSSAI’s earlier “Guidance Note” on Formalin in Fish, issued on 20 July 2018. It says that Formaldehyde is a natural breakdown product of a chemical in fish known as Trimethylamine Oxide (TMAO) — after fish die, it breaks down into Formaldehyde and Dimethylamine. The note says that fish can have between 5 to 140 mg per kg of “naturally occurring Formaldehyde”.

In contrast, a report by a group of experts for the World Health Organisation (WHO) — the names of the experts were disclosed — says the highest concentrations of Formaldehyde naturally occurring in foods are up to 60mg per kg in some fruits and marine fish. It says Formaldehyde is formed during the ageing and deterioration of fish flesh, but high levels do not accumulate in fish tissues because it gets converted to other chemical compounds. WHO’s maximum estimates are less than half of FSSAI’s! 

There is absolutely no doubt that Formalin is harmful to human health. The US Dept of Labour Occupational Safety and Health Administration (OSHA) says that ingestion of dilute Formaldehyde solutions (300 to 400mg per litre) can cause acute discomfort in the throat and stomach. A study of women workers exposed to Formaldehyde in the garment industry revealed an increased incidence of menstrual disorders, sterility, anaemia, and low birth weights in children.

The US National Toxicology Program (NTP) lists Formaldehyde as "known to be a human carcinogen."  The US Environmental Protection Agency (EPA) has classified Formaldehyde as a "probable human carcinogen". The US National Cancer Institute says Formaldehyde may cause Leukaemia in humans. The International Agency for Research on Cancer (IARC) has concluded that Formaldehyde is "carcinogenic to humans".

The US Occupational Safety and Health Administration limits workplace exposure of Formaldehyde to 0.75ppm over an 8-hour workday. The highest concentration that a worker can be exposed to is 2ppm, only for 15 minutes. This includes workers in beauty parlours which use hair smoothing products that release Formaldehyde.

It’s not just fresh fish. Dried fish is at risk too. A report in February said that Odisha's dried-fish industry continued to use Formalin despite being warned, and the Naveen Patnaik government was planning urgent measures including punishments to curb this practice. If Odisha is doing it, the rest of the country can’t be far behind.

The problem is that the FSSAI has now made Formalin in fish legal up to a limit. It's a major complication, since there is no way of distinguishing “naturally occurring formaldehyde” from the chemical version that is added to fish by unscrupulous traders.

Public spirited citizens or non-governmental organisations (NGOs) could approach the High Court to challenge this. But what can ordinary fish-loving Goans do?

We should wash fish thoroughly with running tap water for 10 minutes (soaking it in water is not enough). We should cook fish to an internal (not external) temperature of 75°C or above. A study conducted in Bangladesh has proved that proper cooking significantly reduces Formalin.

Last, but not least, meet your MLA. Demand that the government makes the rapid detection “CIF Test Kit" — jointly developed by the Indian Council for Agricultural Research and the Central Institute of Fisheries Technology (ICAR-CIFT) and produced by the Mumbai company Hi Media — available for sale at every fish market. The kit has 25 test strips, a reagent solution and a standard colour chart. The strip has to be scraped on the skin of the fish or its flesh (in case of slices). Then 1 to 2 drops of the reagent solution are added. If the colour is light pink, the sample is free of Formalin. If the strip turns green and then becomes deep blue, the level of Formalin is between 20-100 mg per kg.

The complication here is that earlier, this indicated that the fish was not fit for human consumption. But after the FSSAI’s recent intervention, it is now officially “safe”. You decide…


Disclaimer: Views expressed above are the author's own.

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Ashwin Tombat

Ashwin Tombat has been the Editor of Gomantak Times and Herald. Worked as an Associate Editor of national magazine Gentleman in Mumbai, before shifting to Goa. Loves sailing, also participates in Marathons. Has worked as an activist in students's union and trade unions in Maharashtra. Also an artist of Street Theatre during student days.

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