Gaps in appplying food regulation and standards in bangladesh dr. sreekanta sheel

by
Sreekanta Sheel2, PhD
International Food Value Chain Expert
Andhra Pradesh Irrigation and Livelihood Improvement Project (APILIP-2)
Andhra Pradesh, India
1 Keynote Paper -Presented in a seminar organized by Bangladesh Agro-Processors’ Association on 25 April 2021
2 https://www.linkedin.com/in/dr-sreekanta-sheel-271a9938/
1

Introduction
´ The global food trade has enormous impact on both the health of
populations and the economies of nations.
´ Around 600 million people become ill and 420,000 die each year from
food-borne diseases, according to WHO.
´ Losses in productivity and trade and treatment costs amount to
US$110billion annually, mainly in low and middle-income countries.
´ The global trade in food products has tripled in the last decade,
reaching US$1.7 trillion by 2015.
´ In the long, complex supply chains, it’s vital that food is kept safe, is of good
quality and is suitable for consumption when it reaches the consumer.
´ Food safety standards and regulations are essential to ensure food is safe at
all points along supply chains in both international trade and within nations.

´ The most important global body for food standards is
the Codex Alimentarius Commission (CAC) that is the
global reference point for food producers, processors,
consumers, national food safety agencies and the
international food trade. CAC is run jointly by
the FAOand WHO and comprises:
´ The regulations are standardized under ISO code that
coordinates the various national regulations in line with the
Act of the World Trade Organization. Its purpose is to
facilitate trade, exchange of information and contribute
to internationally recognized common standards for the
development and transfer of technologies.

Basic Terminologies
Food laws & regulations
´ In all countries, food is governed by a complexity of laws and
regulations, which set out the government’s requirements to be met
by food chain operators to ensure food safety and quality.
´ The term “food law” applies to legislation which regulates the
production, trade and handling of food and hence covers the
regulation of food control, food safety, quality and relevant aspects
of food trade across the entire food chain.
´ However, standards aren’t the same as regulations and following a
standard doesn’t guarantee that you’re within the relevant laws. In
fact standards rarely cite the law as legislation could change within
the lifetime of the standard.

´ The implementation of food safety involves a complex mix of laws, standards and
accepted good practices, involving governments, international organizations
(e.g. WTO), industry organisations (e.g. GFSI, BRC), research agencies, independent
standards bodies (e.g. BRC, IFS) and independent certification bodies.

As per ITC, Total standard, 303:
´ Mandatory and Voluntary standard- 63: Example- Codex Alimentarius
Food Hygiene, Halal Food - MS 1500:2009 - General Guidelines, Halal
food - NM 08.0.800 - 2012 (Morocco), UN Global Compact, UN
Guiding Principles on Business and Human Rights, Sustainability
Assessment of Food and Agriculture systems – SAFA, International
Labour Organization Labour Standards, UNCTAD BioTrade Principles
& Criteria - Terrestrial Food Sectors, IFC Performance Standards on
Environmental & Social Sustainability
´ Private Standard – 223: Example- BRCGS Food Safety, FSSC 22000,
Initiative for Compliance and Sustainability (ICS) Environmental
Criteria, Initiative for Compliance and Sustainability (ICS) Social
Criteria, Fair for life, Fairtrade International Trader, Food Alliance, For
Life,

Some Important Standards Relevant to
Food Products
Good Agricultural Practices (GAP) and Good Handling Practices (GHP):
´ Good Agricultural Practices (GAP) and Good Handling Practices (GHP) are
voluntary audits that verify that fruits and vegetables are produced,
packed, handled, and stored to minimize risks of microbial food safety
hazards.
´ GAP & GHP audits verify adherence to the recommendations made in the
U.S. Food and Drug Administration’s Guide to Minimize Microbial Food
Safety Hazards for Fresh Fruits and Vegetables (pdf) and industry
recognized food safety practices
´ Global GAP, EUREP GAP

GMPs:
More precisely, GMPs help define whether 1) food has been manufactured under conditions that it is unfit
for food; or 2) food has been prepared, packed, or held under insanitary conditions whereby it may have
become contaminated with filth, or whereby it may have been rendered injurious to health (21 CFR 110.5).
´ Hygiene: Facilities must maintain a clean and hygienic manufacturing area.
´ Controlled environmental conditions in order to prevent contamination and cross contamination.
´ Manufacturing processes are clearly defined and controlled.
´ Instructions and procedures are clear and unambiguous.
´ Operators are trained to carry out and document procedures.
´ Records are made either manually or by instruments during manufacture that demonstrate compliance
with these guidelines and regulations.
´ Records of manufacture (including distribution) enable the complete history of a batch to be traced are
retained in a comprehensible and accessible form.
´ The distribution of the products minimizes any risk to their quality.
´ A system is available for recalling any batch of the product from sale or supply.
´ Complaints are examined and investigated, and appropriate measures are taken with respect to the
defective products and to prevent recurrence.
´ FDA has finalized revised GMP regulation, as per 21 CFR Part 117 Subpart B.

HACCP
The Hazard Analysis and Critical Control Points (HACCP) system is a logical, scientific approach to
controlling hazards in meat production.
´ An ideal application would include all processes from the farm to the table.
´ The seven principles of HACCP are:
´ Conduct a Hazard Analysis
´ Identify Critical Control Points (CCP)
´ Establish Critical Limits for CCP
´ Establish Monitoring Procedures
´ Establish Corrective Actions
´ Establish Recordkeeping Procedures
´ Establish Verification Procedures
GMP AND HACCP AS THE BASIS OF SAFE FOOD
´ Good Manufacturing Practices (GMP) is an important part of the Hazard Analysis and Critical
Control Point (HACCP) food safety system, and together they work as a basis to produce safe
food.
´ GMPs, along with standard operating procedures (SOPs), form the basis for HACPP and the
ISO9000 quality management standard. They are often visualized as a pyramid of dependencies.

The foundation of HACCP and ISO9000

Codex Alimentarius Food Hygiene
´ Codex codes of practice – including codes of hygienic practice – define the
production, processing, manufacturing, transport and storage practices for
individual foods or groups of foods
´ Codex standards are based on the best available science assisted by
independent international risk assessment bodies or ad-hoc consultations
organized by FAO and WHO. Codex members cover 99% of the worlds
population.
UN Guiding Principles on Business and Human Rights
´ The Office of the High Commissioner for Human Rights (UN Human Rights) is
the leading UN entity on human rights.
´ The High Commissioner for Human Rights (OHCHR) provides assistance to
Governments, such as expertise and technical trainings in the areas of
administration of justice, legislative reform, and electoral process, to help
implement international human rights standards on the ground.

BRCGS
The BRCGS, A Voluntary Standard for Food Safety can be applied to any food processing or packing
operation where open food is handled, processed or packed. The standard is divided into 9 chapters:
´ 1. Senior Management Commitment and Continual Improvement
´ 2. The basis for the Food Safety System is an effective HACCP programme based on the
requirements of the internationally recognized Codex Alimentarius system
´ 3. Food Safety and Quality Management System - building upon the principles of ISO 9000.
´ 4. Site Standards – These define expectations for the processing environment
´ 5. Product Control - product design and development stage, Allergen management
´ 6. Process Control – This covers the establishment and maintenance of safe process controls,
weight/volume control and equipment calibration.
´ 7. Personnel – This defines requirements for the training of staff and expectations on protective
clothing and personnel hygiene.
´ 8. High-risk, high-care and ambient high-care production risk zones - This section covers the
additional product safety controls need for ready-to-eat products
´ 9. Traded products - Requirements for products that are purchased and store onsite, but are not
manufactured, processed or packed at the site.
´ BRCGS - a focus on safety and quality certification, used by over 30,000 certificated suppliers in
over 130 countries,1700 auditors. 65 publications.

Food Safety System Certification 22000
´ The FSSC 22000 certification scheme contains detailed requirements for food safety
systems of organizations in the food chain, certification system of certification
bodies, and accreditation by the accreditation bodies.
´ The FSSC standard for Food Manufacturing is fully based on the international,
independent standards: ISO 22000, ISO 22003 with sector specific technical
specifications for Pre-Requisite Programs (PRP)’s and additional scheme
requirements
´ FSSC 22000 is applicable to all organizations in the food chain, regardless of size and
complexity, profit-making or not, public or private.
´ ISO 22000 certified manufacturers can obtain FSSC 22000 certification by meeting
the requirements of technical specifications for sector PRPs and the additional
scheme requirements.
´ A voluntary ISO 9001:2015 module has been added to the FSSC 22000 Scheme,
making it possible to offer combined FSSC 22000 and ISO 9001 certification.
´ Over 19.000 FSSC 22000 certified organizations, Certificates in 146 countries

Export Status of Agro-processed Products of Bangladesh (as per
Financial Year 2017-18 reported by BAPA)

(10 groups have been made taking the 1st 9 categories of product followed
by integrating the remaining 11 categories and renamed as other categories)

Requirement of Food Standards for the End Users
Searching the Standard Requirement Using ITC Trade Map for Specific Products

Finding out the Constraints
Use of Market System Checklist to find out the Constraints in relation
to Food Safety and Quality Assurance focusing gaps in Regulations
and Standards

GAP
GHP
Mango Product Market System –An Example…
GMP,
HACCP
1. Agro-processing Value Chain (for Mango
Products)
2. Service
Providers
3.
Enabling
Environment.
….
….
….
…
3.
Enabling
Environment
….
….
….
…
3. Enabling Environment …. …. …. ….
3. Enabling Environment …. …. …. ….
BRCGS
UN
Guiding
Principles
on
Business
and
Human
Rights

Value Cain Actors
Features of Business Enabling
Environment
Prevailing Constraints
1. Value Chain Actors include
input suppliers, producers,
processors, traders, distributors,
wholesalers, and retailers that
provide services required to get
the product to the final
consumer)
Still lacks the common effective platform
among the value chain actors to develop
interfirm relationship
1. Vertical linkage among the VC
Actors
Weak linkage
Lack opportunity for traceability
Application of Block chain technology not
initiated

Service Providers (Private Sector/ Public Sector)
Features of Service Providers (Private
Sector/ Public Sector)
Prevailing Constraints
1. Service Provider (Contractual
Private Sector Provider for Specific
Tasks)
Still lacks proper skill.
1. Technological SP Still lacks Business Incubator
Service provider in the
country!
1. Business Promotion SP

Business Enabling Environment
Features of Business Enabling Environment Prevailing Constraints
1. Formal—laws, regulations, policies,
international trade agreements and
market standards
Compliance gap: Lacking
international market standards in
most cases
1. Informal—norms, customs and codes of
conduct
Lacking quality management
system in most cases
1. Public infrastructure and services—roads,
education, health services, electricity,
Reliable access to water, energy and ICT
etc.
Still not sufficient!
1. A healthy, appropriately skilled
workforce
Still not sufficient!

WB Policy Suggestion Working Paper (2020)
´ At the present time, development and implementation of standards for primary
production is in its infancy in Bangladesh.
´ The majority of farmers have no concept of Good Agricultural Practices (GAP) and
keep no records at all.
´ The Government is developing BangladeshGAP with a primary goal to export more
fruits and vegetables to the EU and other high-value markets. BangladeshGAP is
based on a major international standard known as GLOBALGAP or FAO-RAP GAP.
´ However, experience elsewhere in the world has shown that major retailers in the
importing countries tend not to trust locally developed GAP standards.
´ In Kenya the private sector developed KenyaGAP but buyers in the EU and US
continued to demand GLOBALGAP as the minimum entry requirement making
KenyaGAP redundant for exports to these markets.
´ Building a consensus between public and private actors over the objectives
pursued by the creation of quality standards.

USAID Comprehensive Private Sector Assessment Report
(2019)
Environmental and compliance practice status quo
´ Among the food processing companies of Dhaka, Rajshahi, and
Chattogram area, only 14 percent and four percent of enterprises
are HACCP compliant and ISO certified respectively.
´ Only 30 percent of the enterprises hold the certificate of BSTI (BAPA,
2019). Processing companies are facing barriers in getting the
certificate due to lack of knowledge regarding the issues and the
complexity of the systems.
´ Only two percent of the four hundred food processing companies
use the wastewater treatment plant. Although a valuable organic
fertilizer can be prepared from the waste material, none of the
companies are using the waste material to prepare compost.
(BAPA, 2017).

Food Safety and Quality assurance
´ The global market has been always concerned about the quality of processed food.
To be a global exporter, Bangladesh has to diversify the portfolio of its consumer.
´ Countries in an advanced economy follow certain standards to maintain the quality
of processed food/vegetables. To operate in such a market, Bangladesh has to
ensure the quality according to the standard.
´ However, the current situation of the industry indicates, in the case of processed food
quality management in both endogenous and exogenous market, Bangladesh has
lagged behind in terms of resources and logistics (The Financial Express, 2017).
´ Due to the absence of quality testing in national boundary, Bangladeshi processed
food items required third country scanning which put up to 65.5 times of extra cost
burden on exporters (The Daily Star, 2017).
´ Moreover, the presence of lead in the turmeric powder and pesticides and formalin in
mango juice has reduced consumer confidence in some products and the processors
have seen a decline in sales of these products nationally.

Lack of a nodal agency for agro-processing sector
´ There is no dedicated nodal agency/body to look into the
development of the sector, considering the multi-billion-dollar global
food-processing business and its direct benefit to the farmers.
´ According to BAPA, entrepreneurs have to visit different ministries,
including industry, agriculture, food, and commerce, to get things
done (The Financial Express BD, 2017).
´ Export peer like India has a dedicated ministry to supervise food
processing industries named Agricultural and Processed Food
Products Export Development Authority (APEDA).

RECOMMENDATION
Benchmarking
The process of comparing the price, quality and other attributes
of a product or service against those from competing businesses
or countries
´ Develop and Implement the project addressing the issues
Introduce Business incubation System
´ Business incubation is applicable at the “early-stage
entrepreneurial activity” stage of enterprise development, as
represented in the Figure below developed by the Global
Entrepreneurship Monitor (GEM). At this stage, the
entrepreneur has transformed their idea into a business.

Figure – Enterprise Development Stages
34

Business incubation has four basic components :
Components of Business Incubation
35

Introduction of Blockchain technology: Blockchain technology can be defined as
a decentralized distributed ledger that keeps records of all the transactions made
in the network. Since the technology is distributed it is not owned or controlled by a
single body like the centralized system.
Key Advantages of Blockchain Technology in the Food Industry
´ Blockchain enables industry in managing food safety issues by making the
system with improved transparency.
´ If the collected data is error-free there are fewer chances of fraud to happen.
´ Its application in the food industry amplifies the payment process. The farmers
get benefited with the technology as it offers more value and better selling
chances by connecting farmers directly to the consumers without any
intervention from the intermediaries.
´ Blockchain empowers the agri-food industry to Uberize by reducing transaction
charges and intermediaries.
´ Block reduce post-harvest loss by regulating the process of transaction and
data collection in a much better way

Recommendation from
WB Policy Suggestions (2020)
Improve the food safety regulatory and oversight system and support adoption by the
private sector of appropriate food safety practices
´ Private actors along the agri-food value chain will also need support in complying
with food safety rules, once they are clarified.
Promote improved quality standards in the market
´ There is a need to support the private sector in coming together to develop industry-wide
harmonized commercial standards, that comply with minimum legal food safety standards,
for both primary production and food processing.
´ Such a private sector-led approach has proved successful in other parts of the world,
examples include the UK Red Tractor Standards and British Retail Consortium (BRC)
´ Food Standards. Success would be derived from the public sector supporting the
harmonization process, and for the public and private sectors to work together to ensure
close linkages and harmony between regulatory requirements and the private standards.
´ The definition of domestic product standards needs to be tailored to domestic market
conditions, making sure to protect consumers, while ensuring that value chain actors will be
able to eventually comply

Encourage and promote aggregation models to bring economies of scale in operations
´ Aggregation models such as productive partnership, contract farming, or producer
group, among others need to be encouraged to facilitate the delivery of extension
services and improve farmer’s ability to access finance, develop joint infrastructure,
lower marketing logistics costs and better connect with large buyers and off-takers.
´ Develop and adopt good agricultural practices :Local good agricultural practices
(GAP) standards should be developed and adopted through public- private
collaboration to address the misuse and overuse of certain inputs like fertilizer and
pesticides along with other food safety concerns (see recommendation on food
quality standards). Subsequently, GAP should be the key area of focus for both public
and private extension service delivery to farmers.
´ Improving marketing infrastructure and logistics services
´ Reliable access to energy
´ Facilitate access to finance for value chain actors

Bangladesh Agro-Processing Promotion Policy 2020
Measure will be taken to upgrade agro-industry to meet international standards to be followed, for
instance,
´ Good Agriculture Practices (GAP),
´ Food Safety Management System (ISO 22000),
´ Sustainable Forest Management System (SFM, ISO 14061) or other equivalent international
standards.
´ Investment or expenditures according to the plans is required and such international
standards must be achieved within 3 years after issuance of the investment promotion
certificate.
Measures will be undertaken to promote Bangladesh’s image as a source of supplying safe and
quality food products:
´ Promoting Bangladeshi’s quality certification as the premium standard in the world market for
the production, preparation, handling and storage of safe and quality foods;
´ Ensuring the entire supply chain, from farm to plate, complies with the halal requirements;
´ Establishing a one-stop centre to facilitate the compliance on food safety and quality; and
Encouraging the industry to adopt a self-regulatory approach in meeting the requirements on
safety and quality.

CONCLUSION
´ The WTO encourages member states to use Codex standards as a benchmark
for harmonisation in its Agreement on the Application of Sanitary and
Phytosanitary (SPS) Measures and Agreement on Technical Barriers to Trade
(TBT).
´ It sees the use of common standards as a way to avoid unnecessary costs for
producers and consumers and to help prevent the creation of barriers to
trade.
´ WTO, WHO and FAO also view food safety and trade as major contributors to
helping nations achieve the UN’s 2030 Agenda for Sustainable Development.
They are key components to achieving several Sustainable Development
Goals
Not with only the Supply Chain Approach, let’s follow the Value Chain Approach
that are inclusive of Essential Standards having capability to meeting up
international demands towards enhancing the efficiency of the country’s agro-
processing sub-sector!

Gaps in appplying food regulation and standards in bangladesh dr. sreekanta sheel

Gaps in appplying food regulation and standards in bangladesh dr. sreekanta sheel

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