The application of HACCP principles in aquaculture, which aims to produce shrimp as a safe food, is a totally new concept in Sri Lanka, despite the accelerated introduction of the HACCP-system at the shrimp/fish processing plant level, and with the exception of Indiriwary Aqua (Pvt) Ltd. They observe an incipient HACCP-based system, mainly directed to control shrimp diseases, white-spot disease in particular.
Among the food safety hazards which have been identified by shrimp producers are:
At the shrimp farm level, contamination of pathogenic micro-organisms would be the result of the natural presence of some of these organisms in the water source (mainly Vibrios but also Enterobacteriacae such as Salmonella and E. coli) and/or through water pollution from animal sources (birds, lizards, turtles, other animals) {Salmonella, Shigella, E. Coli). Control measures applied to fight white-spot contribute in decreasing the problem, particularly through pond and water treatment before grow-out, re-circulation, prevention and control of bird predators, and prevention of fish and other crustacean invasion.
Growth of pathogenic micro-organisms is controlled by most farmers through their efforts to chill shrimp in water and ice as soon as possible after harvesting, and by keeping the shrimp chilled in ice until it reaches the processing plant. Shrimp spoilage is controlled with the same measures.
An obvious un-identified food safety hazard would be the contamination of final frozen products with SO 2. Such contamination would be the consequence of dipping shrimps in sodium meta-bisulphite solutions at farm and/or plant level aiming to control black-spot (melanosis). No attempt is made to control the excess of the residual SO 2. There is no mention of the addition of sulphides on the label of frozen shrimp packs, including those directed to the US market.
Concrete information on the use of veterinary drugs in shrimp farming was not available. Therefore, a much more detailed investigation should be carried out in order to assess the existence of such a hazard. The same lack of information was found concerning shrimp contamination by agro-chemicals and/or heavy metals. However, most experts interviewed assured that they were convinced that this would not be the case.
Four of the five shrimp processing plants visited had an operational HACCP plan. The HACCP plans' preparation dates from the period the INFOFISH - J.Slavin & Associates HACCP Training Course was provided in Colombo (May–June 1996). The plans did not differ greatly, all of them being based on the USFDA new seafood HACCP legislation. The HACCP plans examined have in common both positive and negative issues: for instance, all of them share the same identified hazards, critical control points, and control measures; the plans also include Standard Sanitation Operating Procedures (SSOPs) with monitoring and verification procedures. Differences among the HACCP plans were mainly related to details of monitoring procedures, records and record keeping procedures.
Practical application of the HACCP plans at the aforementioned plants varied considerably, mainly in accordance with the following factors: (1) management's commitment to HACCP application, (2) implementation time, (3) training level of plant personnel, (4) plant physical structure and equipment facilities, and (5) efficiency of SSOPs.
Although management's commitment varied from plant to plant, it was generally found to be far from necessary. The main reason for this being that Japan is the main market for Sri Lanka shrimp export, and no pressure is felt by the plant management to apply the HACCP-concept.
Most of the HACCP plans were at the initial stage of their application and, as other plants in most parts of the seafood industry world-wide, the plants are struggling to introduce the new system.
Training of plant personnel on the application of the HACCP-concept in the shrimp industry is literally limited to a middle level industry working force (Production Manager, QC Manager, etc.). Efforts to train lower level plant personnel, including basic food hygiene and personnel hygiene, are at this moment in time terribly neglected, with obvious negative results in the application of SSOP and HACCP programmes.
The physical structure of the plants is generally of a higher level when compared with other developing countries, particularly in the case of newly built plants. But there is still room for considerable improvement, the main negative areas being facilities of personnel hygiene (lavatories, changing rooms, hand washing/disinfecting basins, canteens). The plant lay-out is not up to standard and there should be a distinct division between “dirt” and “clean” areas, production flow, and lack of chill rooms.
The shrimp handling/processing equipment present at all the various plant stations is rather obsolete, consisting mainly of flat stainless steel tables which are used for all kinds of shrimp handling operations (sorting, beheading, peeling, grading, packing, etc.). They do not have the correct apparatus for shrimp washing under running water, nor water flumes or conveyor belts in order to assure an adequate continuous flow of production. In all plants, batches of shrimp, whether iced or not, accumulate at several phases of production. Modern equipment is limited to refrigeration (ice making machines, freezing equipment and cold stores) and water treatment (sedimentation, filtration, UV light and/or chlorinating utensils).
Four of the plants had SSOPs in a rather incipient stage of application: many efforts should still be made to have these programmes efficiently implemented. However, one of the plants is much farther ahead compared to the other industries, namely ALPEX Marine (Pvt) Ltd.
All HACCP plans need revision since their hazard analysis is incorrect, as evident from the fact that the plans were unable to identify all existent hazards (contamination and growth of pathogenic micro-organisms, spoilage, excess of residual SO 2, absence of indication of addition of sulphites in product label). Another common mistake is the establishment of incorrect control measures at wrongly identified Critical Control Points (CCPs). The most clear error is the identification of the freezing operation as a control measure against the hazard of the presence of pathogenic micro-organisms in the final product. The establishment of monitoring procedures, corrective actions, and verification procedures also require revision and intensification of implementation efforts: most of the plants completely neglected the application of these steps.
Updated information was obtained from Dr. L.S. K. de Silva, Director, Quality Assurance, Sri Lanka Standards Institution (SLSI) and Mr. A.S. M. Muzzamil, President, Sri Lanka Seafood Exporter's Association concerning the actual status of fish inspection and quality control in the country.
A copy was obtained of the Action Plan (June 1998) submitted by the Ministry of Fisheries and Aquatic Resources Development (MFARD) to the European DG 24 aiming at including Sri Lanka in the list of Third Countries authorised to export fish and fishery products to the European Union (EU).
According to the above-mentioned document, new regulations have been developed and are in the process of promulgation. The new regulations were prepared following the new European Union safety requirements for the production and marketing of fish and fishery products. The promulgation process includes translation into two national languages (Sinhalese and Tamil), official finalisation by the Legal Draftsman, approval by the Cabinet, and publishing in the Government Gazette; following which the regulations are submitted to Parliament for approval. The Minister (MFARD) has studied the proposed regulations and has agreed to recommend such to the Cabinet and the Parliament for approval. It is expected that the regulations will become operational before the end of 1998.
Sri Lanka faces the difficulties of the multiplicity of Government agencies involved with fish inspection and quality control. Among those agencies, SLSI appears to be the government body which has most of the experience, knowledge and long-term involvement with the subject matter. SLSI's, albeit small, well prepared technical staff face however serious infrastructure problems. According to the new legislation, a new competent authority for fish inspection will be nominated to the European Commission. This will be the Directorate of Fisheries, which is a Department of MFARD. However, since the Directorate of Fisheries is presently unprepared to cope with this new task, an “ad hoc” agreement has been maintained with SLSI for all field work activities. According to the work plan, SLSI will carry out all local inspections of processing facilities and will report directly to MFARD.
Quality Control Laboratory services are at present provided by three Governmental institutions: SLSI, National Aquatic Resources Research and Development Agency (NARA) and Ceylon Institute for Scientific and Industrial Research (CISIR). It shall be noted that in some cases the exporting establishments seek testing services in England from accredited laboratories to secure the fulfilment of the EU requirements. At present a comprehensive programme in enhancing the performances of the laboratories of NARA and CISIR is underway. The aim is that both laboratories will be accredited and this will thus fulfil the requirement of the European standards EN 45001. The Sri Lanka Accreditation Board, in co-operation with the Swedish Board, will do the accreditation for “Accreditation and Conformity Assessment (SWEDAC)”. The on-going programme is expected to end by the end of 1999.
A two year assistance programme entitled “Technical Assistance in Strengthening the Fish Industry in Sri Lanka” is being provided by Swedish International Co-operation Development Agency (SIDA). The programme funds are SeK 4 700 000 and, amongst the consultants involved, an Icelandic consultancy firm takes care of the inspection of quality control matters. The programme aims to restructure the Sri Lanka fishing industry in order for it to meet the EU requirements from fishing at sea through land, transport and production to the export point. Moreover, in meeting the EU requirements the programme is expected to adhere to the requisitions of all the major markets for fishery products throughout the world.
The draft text of the SIDA's assistance project was obtained and carefully analysed. It is clear that it is a comprehensive document that, if well implemented, will greatly improve the fish industry in Sri Lanka.
The objectives of the programme and its main operational details can be briefly summarised as follows:
Overall objectives:
To support the authorities in Sri Lanka in adopting the legal framework and the enforcement activities in order to adhere to the requirements of the major exporting markets, to develop the necessary quality infrastructure to secure the required conformity assessment environment for the producers and to support the producers in adopting the production facilities to the new requirements.
Immediate objectives:
The programme is expected to be implemented over a period of two years through four main components:
Concerning fish inspection services, on the basis of the policies developed and the decisions taken on the organisation of the inspection activities when making the necessary legal framework, support shall be given to the MFARD in developing the inspection activities in line with the requirements of the EU Directives. The support should include:
The Swedish Assistance Programme briefly describes other donors' activities, and co-ordination with them. Among other donors activities the following are mentioned:
A six-year Asia Development Bank Project covering the construction/improvement of six harbours in Beruwala, Hikkedwa, Mirissa, Pavanawella, Galle and Kirinda.
The parallel S1DA programme - Technical Assistance in Strengthening the Quality Control Infrastructure in Sri Lanka. Included in this programme is the establishment of a national accreditation body (SriLac) and support to 6 laboratories in adapting to the EC accreditation requirements.
The EU is financing a programme to support the food industry, excluding the fish industry. Such a programme also includes the support to 3 laboratories, which potentially can serve the fish industry in the future.
FAO also runs through the Food Quality and Standards Service (ESNS) a TCP project similar to the above EU programme.
The Government and industry in Sri Lanka are presently making serious efforts to upgrade the safety and quality of fishery products, in particular those directed to the international trade. The country presently receives substantial international assistance from a specific project funded by the Swedish International Development Agency (SIDA). Parallel international assistance is being provided by the European Union and FAO in the field of food control in general.
The assistance provided by SIDA appears comprehensive, covering all aspects of fish as food. Therefore, no input from FAO is required, apart from close liaison with SIDA and the Government of Sri Lanka to aim at providing complementary assistance, if and when necessary.
The implementation of the HACCP-concept is accelerated at the shrimp processing plant level but practically non-existent at the shrimp farm level. Both, government and industry should continue their efforts to put into practice the HACCP system at plant level. With this aim, special attention should be dedicated to the revision of existing HACCP-plans and training of personnel at all levels. Verification procedures should be intensified. The government and the shrimp industry in Sri Lanka should consider the convenience of extending the application of HACCP principles to shrimp farming as a control measure in order to assure the safety and quality of farmed shrimp products, as well as consider the possibility of using HACCP-based systems to control shrimp diseases. NARA must initiate a number of basic research studies aiming at providing the necessary scientific information to the private sector and government food control agencies concerning the proper identification of food safety hazards related to fish/shrimp as food in Sri Lanka.
