The workshop identified the following action points that could be addressed at regional national and local level.
- Review examples of MRAs already finalized within ASEAN as possible models for adaptation (e.g. on cosmetic, electrical appliances) by the ASEAN Consultative Committee on Standard and Quality (ACCSQ).
- Review the regional and international frameworks such as that of Codex Alimentarius, among European Union, between Australia and New Zealand, etc. for establishing an MRA.
- Evaluate the adaptability of those existing MRAs and their frameworks to the proposed ASEAN MRA.
At national level, it is important to establish an inventory of competent agencies that have jurisdiction for health and food safety inspection. For example, clarification of the agencies responsible for control programs and their authority and scope of jurisdiction should be identified. Within this, elaboration of the following should be addressed:
laws and regulations;
inspection programs and procedures - elements of food control system;
existing facilities/infrastructure;
organizational structures;
types of services provided; and
competency/capacity of personnel.
Apart from the national agencies, it is also important to identify the other national key players who have stake in the health and safety inspection, but which may not actually have specific authority. These stakeholders will include both private and public sectors:
private sector groups (farm producers, seed and feed producers, processor, distributors, exporters);
national fishery related agency;
other national agricultural related agency (i.e. Veterinary);
national health related agency;
national commercial and trade related agency; and
research institutions.
The workshop identified that it was important to have private sector buy-in to the process and that to ensure their involvement, it was necessary to create awareness of the opportunities and mechanism that exist for improving product safety and quality. The workshop emphasized the need to improve awareness and access to information related to health and safety requirements (e.g. certification systems, accreditation, etc.). The responsibility for this was delegated to the national institutions.
The workshop highlighted the importance of demonstrating the application of risk analysis to the private sector and this was most likely to be achieved through undertaking a practical/model example with collaboration between the government and private sector.
At the higher level, the workshop also emphasized the need for policy level support to the process. The active awareness and involvement of government and the coordination of related agencies was highlighted as important in ensuring that resources and commitment were available for the harmonization and equivalence process.
Developing competence and equivalence
promote required capacity building exercises to ensure equivalent level of competence among national competent agencies in countries in the region;
develop national criteria including regulations for MRAs on health and food safety inspection with realistic goals;
identify required studies or research on health and safety inspection throughout the whole supply chain to support the formulation of the MRAs;
identify supporting activities to materialize the agreed national MRAs in the whole supply chain; and
formalize the national MRAs through the relevant national mechanism.
Capacity in risk analysis
The workshop concluded that in those countries where Risk Analysis is not generally practiced at the national level, there is a need to create awareness on the importance of RA and promote the use of the RA concept as a guiding principle to develop quality and safety standards for the whole food supply chain.
In countries where Risk Analysis is already in use (possibly in other sectors) the following actions are suggested:
establish a National Committee/Task Force on Risk Analysis (with particular emphasis on risk assessment aspect) composed of representatives from various stakeholders' groups, to develop and promote the framework of risk analysis;
identify research institutions in the region capable of performing risk analysis for possible networking and unified approach;
identify and categorise aquatic products or commodities on the basis of risks on trade
In order to identify the gaps and develop the required information for risk analysis, identify the research capacity/capability needs for antibiotic residue testing and the analysis of bacteria and heavy metals (with reference to culture d shrimp in particular);
it is important that ASEAN countries should be involved in, or be aware of, research on harmful effects of chemicals on human health and incorporate such knowledge in the production and supply chain to build up confidence of consumers; and
review legal and institutional framework, and where appropriate, make necessary adjustment to support the promotion of the use of Risk Analysis.
The workshop mentioned several times the value of undertaking a model MRA and/or risk analysis as a means to learn the process. In most of the countries, the lack of practical experience means that the national mechanisms and the steps that need to be taken have not yet been identified and often cannot be identified until the process is initiated.
Model MRAs for a specific commodity
establish the minimum criteria required to ensure regional MRAs;
promote sample models for implementation;
identify missing areas and fill the gap of each country's MRAs to ensure regional MRAs;
use Codex documents to provide guidance on equivalence agreements; and
undertake studies of shrimps/prawns regulations in the ASEAN countries that could help in facilitating the consensus on MRAs.
Example risk analysis for a specific commodity
In order to promote capacity building for stakeholders in understanding and using Risk Analysis, models could be developed for a commodity such as shrimp.
the risk analysis should include hazard identification, risk management and risk communication;
develop common risk profile for the relevant hazard/ product pairs;
the acceptable levels of risk for domestic and export food chains should be the same, however, their monitoring and control mechanism may be different; and
the data/information needs for some parts of the risk assessment process can only come from industry (e.g. temperature/exposure assessments). However, the industry is often cautious about this due to confidentiality and therefore it is critical that they are involved in this process from the start.
Lack of accurate information available for the private sector (including both farmers and processors) was identified as a limiting factor, which affects the awareness and perception of risk in the farm level. This strongly affects farmers attitudes to the use of chemicals and antibiotics. The production sector was also considered to be generally slow or unwilling to comply with government measures because of lack of awareness of the reasons for the measures or perception that they were not really important.
The workshop emphasized the need for involvement of private organization in both risk management activities and the development of whole risk analysis exercises and MRA. Some mechanisms for achieving this were identified:
improve communications/consultation between government authorities and private sector;
inform the private sector of the advantages and benefits of collaboration in the areas of risk assessment and MRA;
promote safe image of seafood produced in ASEAN (through various fora, trade missions, etc.);
encourage industry to share its information/data (such as temperature data in storage, spoilage times, microbiological test results etc.) so that research institutions can develop risk analyses;
involve the private sector in the risk assessment process and reassure them that this is intended to facilitate trade, not prevent it;
encourage collaboration in the private sector to establish an ASEAN aquaculture industry association; and
collaborative on-farm research on alternatives to chemical use in farm management would be a parallel requirement and assist in raising awareness at the farm level.
In order to develop regional approaches and achieve regional harmonization and equivalence, the various national examples would have to be drawn together, comparing similarities and identifying common ground for consensus.
ASEAN Sectoral Working Group on Fisheries can take the lead in identifying regional training needs.
There is a need to organize regional workshops and practical training for ASEAN member countries e.g.:
- production of safe fish products from aquaculture (HACCP, CoC, GHP and GMP in aquaculture production);
- introduction to risk analysis with particular reference to fish aquaculture;
- development of equivalence on fish and fish products in Codex Alimentarius terms;
- organization of reference labs for fish and fish products; and
- introduction to hazard identification and risks to consumers from veterinary drugs utilized in fish aquaculture.
Establish a regional information and knowledge network on risk analysis.
The existing APEC/NACA/FAO manual/activities in risk analysis of transboundary movement of aquatic animals are complementary and coordination between this and ASWGFi is encouraged.
The workshop was informed of the important difference between the issues of residues of antibiotics that are prohibited for veterinary use and those for which no such prohibition exists (but for some of which residue limits are specified). It was emphasized that in cases where an antibiotic was prohibited, the best policy was to ensure that farmers (use most appropriate, but not both) complied with the ruling and did not use the chemical or drug in the production system.
Avoidance of use of antibiotics not allowed for veterinary use
Since it is increasingly difficult to challenge import regulation standards once they have been established, a more constructive route for addressing the issue of problems with residues of banned chemicals or drugs is to avoid their use.
The appearance of residues in a crop can come from deliberate or inadvertent application:
farmers apply the drug because they believe the drug will improve their production or prevent disease - possibly because they have received misleading information from colleagues or sales representatives;
the farmer has a production problem and will try anything to save the crop;
the farmer is applying an approved treatment to the pond which is mislabelled or is contaminated;
the feed or supplemental feed is contaminated (deliberately or inadvertently); and
there is contamination of the water supply.
The control of deliberate addition of any substance and its final residue in fish is one or more critical control point (CCP) in a HACCP plan for aquaculture fish production. Examples of substances to be controlled are:
veterinary drugs
commercial feeds
commercial feed supplements, top-coatings, vitamin mixes, 'growth enhancers'
other 'additives/treatments' such as colour enhancers, etc.
The lack of coordination between control agencies concerned with chemical trade, supply, distribution and usage is most evident in the lack of involvement of prescribing authorities in aquaculture production. Whilst there is a high degree of capacity in the area of production amongst professionals in the aquaculture sector, they may not have as much experience in public health aspects related to fish as food. The availability and accessibility to drugs in the market is a problem, especially for the drugs that are not allowed for veterinary use (e.g. Nitrofurans and Chloramphenicol) that very often can be purchased "over the counter".
The workshop recommended that:
it was important to enforce stricter controls over chemical and drugs not authorized for veterinary use;
develop a process for making the activities of the aquaculture service providers (feed, seed, drugs) more responsible by bringing them under a system of code of practice or self-regulation;
improve or strengthen existing law enforcement and monitoring systems for sale, distribution and use of such drugs and chemicals; and
training of all professionals and technicians working on aquaculture production should be enhanced and updated in regards of safety of fish as food products. There is an urgent need to bridge this gap.
Labelling and certification
The workshop was informed that there are now some indications that consumers are no longer using only the price of the product in their purchasing choice. It is also apparent that food safety is becoming a principal factor affecting consumers' choice for some products and that consumers are prepared to pay more for food safety.
It was stressed however that the guarantee (or credibility) aspect is crucial, since certification is not particularly trusted. This is because product packaging now has a wide range of certificates and labels and the addition of a further label may not necessarily have any additional impact on a consumer. It was also mentioned that there is a critical impact if a certification/labelling scheme fails to deliver what it claims and that consumer confidence will collapse completely in such circumstances.
There is a question as to whether the additional price that a consumer will pay for improved safety products will actually be passed on to the producer. This is partly due to so called 'market imperfections' and the length of the market chain.
Most CoC/BMP schemes target a product that is safe to eat and certify it as such. However the workshop questioned whether such schemes could also guarantee whether a product was free of disease from a quarantine perspective. This concern was raised because some importing countries require that the imported product should also be certified free of specific diseases that are unrelated to human health.
The solution in this case is to undertake a risk assessment of the product in relation to the risk of transmission of a disease. An example of this is the export of shrimp to Australia which is concerned over the transmission of viral disease such as WSSV. Shrimp imported to Australia must be head off and frozen, and not the product of an emergency harvest. Following a risk analysis, it was concluded that this form of product is presented the lowest risk of transmission of WSSV.
The workshop was informed that in the future it can be expected that importing countries will increasingly require this certification related to animal health as well as ensuring the product is safe from the human health perspective. It is therefore timely that ASEAN countries should start to cooperate in dealing with this issue. In Thailand, one feature of the CoC is to encourage good environmental management and this tends to reduce incidence of animal disease (but this does not necessarily mean that it is safe with respect to human health). Actually, in testing product as disease free is problematic because the sensitivity of testing methods inevitably means that disease can be detected - it is therefore more productive to engage is a process of risk assessment in order to determine what can be accepted and what must be controlled.
The workshop concluded that:
there is an opportunity for labelling schemes - with strong ownership from the private sector that would assist in the promotion of reputation of ASEAN products;
there should be collaboration along the market chain to provide incentives to farmers to produce quality products (farmers-processors/traders-consumers);
facilitate import and export procedures for traders that supply quality products (provide an incentive to traders through reduced transaction costs);
use market-based incentives as far as possible and caution should be exercised in using government subsidies when considering incentives (This is due to trade (WTO) implications); and
encourage local farmer organizations to take responsibility for quality production and self-regulation.
Codes of Conduct, Best Management Practice
The workshop was informed of several schemes that were aimed at improving farmers' practices. Different approaches were used but all were based around the concept of farmers being encouraged to adopt some standardized practices or protocols[5].
An example of producers in India using a BMP/GAP approach through cluster management (see section below), were able to achieve better production results and reduced risks. Monitoring of the adoption of BMP has shown several positive results - the reduction in antibiotic usage as well as increased crop duration, better yield and increased survival. An additional benefit to this was that processors are becoming interested in purchasing from producers within the scheme because they do not use antibiotics.
In another example from Thailand, producers who were certified under a Code of Conduct scheme were able to obtain a higher price for their product because the producers did not use restricted or banned chemicals. Additional benefits were reduced problems with between farm pollution and reduced environmental impact.
The ability to sell products preferentially to producers, enter into forward contracts or obtain higher than market prices for products are strong incentives for farmers. Higher prices may be due to a better market value at the consumer end or may be due to the reduction in testing costs being passed onto the farmers. Increasingly it may become the case that farmers cannot actually sell their product unless they are part of such schemes due to the unwillingness of processors to risk purchasing products that contain residues.
At the global level there are a number of schemes for codes of conduct and best management, ASEAN countries engagement in the development of standards for best management is important. This is because many of the 'best management principles' may vary according to size and type of the farm and scale of production including factors such as:
zoning (buffer zones between farms or shoreline);
requirements for effluent treatment (percentage of farm area for settlement, treatment);
maximum stocking densities, feeding rates, growout duration; and
monitoring and inspection protocols.
All of these factors vary considerably between different shrimp producing regions.
The workshop concluded that:
it is important to encourage and provide incentives to farmer to enter schemes for improving management practices (priority in giving loans, certification process, higher product price, preferential purchasing) to those who meet the requirements and abide by good practices;
identify set of ASEAN-wide operating principles as the basis for national aquaculture product certification (encourage linkages to the Consortium programme FAO/NACA/WB); and
communication with farmers is important in order to raise awareness of the potential benefit and that farmer to farmer communication is an important feature of this.
Cluster management
Cluster management is a self-regulation mechanism for the implementation of standards at farm and processing level. Typically, state agencies do not have the capacity to regulate the numerous small farms that often exist in an aquaculture producing area. This inevitably means that monitoring and control of practice are effectively outside of the government's capacity to control. This means that the avoidance of use of banned or controlled chemicals and the production of healthy and safe aquaculture products relies heavily on the behaviour of farmers and their willingness to modify their practices.
CoC and BMP exist in various countries and for various aquaculture systems, but their introduction to such a large and dispersed sector faces the same constraints as monitoring and control as noted above.
Taking two examples (i.e. the shrimp farming area of ~70,000 ha in Andhra Pradesh, India and the ~24,000 shrimp farms in Thailand) it is clear that some form of grouping of farms or farmers is required in order to deliver services, transfer information and ensure a degree of self or mutual monitoring for responsible practice.
Cluster management seeks to achieve this by encouraging farmers to adhere to codes of practice or best management practices as a group and to monitor each others activities to ensure that the group complies with the principles of the particular scheme.
Typically farmers are unwilling to do this initially, but experiences have shown that the benefits are soon realized by the group and this encourages others to join (these benefits include: priority market access, ability to join certifications schemes, improved reliability of production, reduced risks)
The workshop recommended to:
encourage application of the cluster management concept in aquaculture, to reduce the risks of production and trade through internal mechanism or systems.
The workshop noticed that agreed Codex Alimentarius Commission standards have not been incorporated in actual regulations of many countries and that these standards do not necessarily cover all the situations found in current fish production and trade practices. The prioritization of areas that are covered by the CODEX Committee depends upon the participation of the member countries. The important role of risk analysis in elaborating CODEX standards was also emphasized.
It was recognized by the workshop that the impact of the ASEAN countries on the CODEX process is still limited and that it is important that this is strengthened to ensure that the relevance of CODEX to ASEAN issues is improved.
The importance of Trade Associations in the CODEX process was also mentioned. Such associations can participate in CODEX discussions as observers, however they have no voting rights in this capacity. Trade and producers' associations can be more effectively involved in Codex Alimentarius activities if they participate as members of their own country delegation.
Recommendations for action by the workshop included:
arranging consultation/dialogue with trading partners collectively on seafood safety issues as an ASEAN voice;
continuing linkage with international agencies like FAO and other relevant organizations for assistance and support; and
challenging standards that are unfair (using science based evidence and arguments e.g. risk analysis and results of research.
The workshop deliberated on what local, national and regional mechanisms could be used (both public and private sector) for collaboration in food safety issues. In particular, how to enhance the reputation of the ASEAN region as a supplier of safe products to export markets. The workshop identified the need for attention to be directed towards the promotion of the image of ASEAN seafood products (especially shrimp) as being safe and healthy. This requires the reassurance of importers and consumers regarding methods of production and the meeting of product standards.
- build an ASEAN Shrimp Website under ASEAN Food Safety Network;
- participate in existing seafood trade shows as ASEAN cooperation/booth i.e. under ASEAN-Japan center mechanism;
- promote confidence in the country products among ASEAN members and importing nations outside ASEAN through:
Transparency - in procedures, rules and regulations, certification systems, government and private sector food safety procedures
Encouraging responsible practice among public and private sector
Consumer awareness - promoting food safety as part of country reputation etc
Many of the workshop recommendations had a strong feature that required improved communication between the various actors and there were a number of areas where action was needed. The importance of promoting awareness building on quality and safety of fish and fishery products in the whole supply chain (seed and feed, chemical, farm, processing, export) as well as with 'consumers', featured in several of the working group's conclusions
encourage producers' groups/associations;
encourage better links between ASEAN Fisheries Federation and other producer associations;
strengthen the linkages of national fisheries federation and ASEAN Fisheries Federation and national ASEAN FWG focal points;
promote clear and strong consensus between government and private sector in promoting quality and safety issues;
establish dialogue between national fishery related agencies and other national trade and tourism related agencies to have a clear position on the promotion of quality and safety issues of fish and fishery products at regional/international level; and
incorporate mass media as a means to promote reputation.
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[5] It should be noted here
that whilst CoC or BMP may be able to ensure that a product is not contaminated
or contain certain residues, it still does not ensure that the product is safe
with respect to human health. It is in this area that HACCP is seen as the
effective means to control quality and safety of the product. |
