II. Current Status of Traceability Systems for Aquaculture Products in the Philippines
and trade. It is known to be an essential tool to identify risk and problems, and facilitate immediate action and management intervention. There are new regulations on food safety and traceability requirements for fish and fishery products that have been enacted. This paper will discuss the status of the traceability system and other relevant activities being implemented at different stages of the aquaculture supply chain.
II. Current Status of Traceability Systems for
system. The FHMQAS has eight (8) permanent staff and twenty eight (28) support contractual staff. The Regional Fish Health Unit (RFHU) in fifteen regions is manned by ninety one (91) Regional Fish Health Officers.
The Fish Inspection Unit (FIU) is responsible for the inspection, accreditation and approval of the post-harvest processing establishments to be able to export aquaculture and fishery products. There are eleven (11) staff at the FIU and fifty three (53) Regional Fish Inspectors nationwide. The Fishery Product Testing Laboratory (FPTL) and the Marine Biotoxin Monitoring Unit (MBMU) serve as support laboratories for the regulatory units particularly on inspector’s verification activities, and other regular monitoring activities related to food safety. Health certification of aquaculture and fishery products is issued by the Administrative Support and Product Certification Unit (ASPCU) based on the recommendation of the Fish Inspectors and results of laboratory analysis. Checking of documentation requirements and border clearance of the product is being done by the Quarantine Unit. All the enumerated activities are being coordinated at the regional counterparts that serve as the arm of the central office in implementing the programs. Figure 5 shows the location of BFAR offices.
The BFAR is in the process of re-organization where additional manpower with permanent positions is proposed to cope with the changes and needs of the industry, as well as the new requirements that need to be complied with, such as the enactment of the Food Safety Act and Amendment to the Fisheries Code of the Philippines.
Regulations on Food Safety and Traceability Requirements for Aquaculture Products
Several regulations have been ratified to ensure aquaculture and fishery products safety and quality from farm-to-table. Regulations are in the form of Republic Acts, Administrative Orders and Fisheries Office Orders. Among the relevant regulations with traceability requirements are:
• Republic Act 10654, Series of 2014, an Act to prevent, deter and eliminate illegal, unreported and unregulated fishing amending Republic Act 8550, otherwise known as the “Philippine Fisheries Code of 1998” and for other purposes.
• Republic Act No. 10611 or the Food Safety Act of 2013. An act to strengthen the food safety regulatory system in the country to protect consumer health and facilitate market access of local foods and food products, and for other purposes.
• Republic Act 8550 otherwise known as the Philippine Fisheries Code of 1998. An act providing for the development, management and conservation of fisheries and aquatic resources integrating all laws pertinent thereto, and for other purposes.
• BFAR Administrative Circular Order No. 251, Series of 2014. Traceability system for fish and fishery products.
• Department of Agriculture Administrative Order (DA-AO) No. 24, Series of 2009. Implementing guidelines on the national veterinary drug residues control program in food pursuant to Administrative Order No. 14, Series of 2006.
• Fisheries Administrative Order (FAO) 227, Series of 2008. Rules and regulations governing the export of fish and aquatic products to European Union Member Countries.
• FAO 228, series of 2008. Rules governing the organization and implementation of official controls on fishery ad aquatic products intended for export to the EU market for human consumption.
• DA-AO No. 14, Series of 2006 – Implementation of the National Veterinary Drug Residues Control Program and Creation of the Inter-agency Committee.
• FAO No. 210, Series of 2001 – Regulations for the Exportation of Fresh / Chilled and Frozen Fish and Fishery Aquatic Products.
• FAO No. 212, Series of 2001 – Guidelines on the Implementation of HACCP System.
Aquaculture Supply Chain
Based on the BFAR Administrative Circular Order on traceability, the aquaculture supply chain is divided into three main groups, namely: i) pre-production (hatchery / nursery, feedmill / aquatic veterinary products); ii) production (grow-out farm), and; iii) post-harvest (auction market, transport, processing establishment, cold storage, shipment). Each stage of the supply chain requires documentation system for traceability.
1. Pre-production Hatchery and Nursery
Generally, the hatchery maintains information about the source and distribution of the broodstock, fry and post larvae (PL) in the receiving and distribution logs, respectively. The nursery keeps fry and PL receiving and distribution logs. Both hatchery and nursery keep wild caught fry collection report when fry is sourced from the wild.
The hatchery and nursery keep records on the management practices being implemented i.e.
feeding, supplementation, medication and other inputs. For feeding, the data required is kept in the feed receiving, dispatch and feeding logs.
The records on the use of drugs / biological / chemicals are kept at the receiving and supplement / medication log sheets. The details on the traceability documentation are indicated in Table 4.
In shrimp, hatcheries import specific pathogen free or specific pathogen resistant (SPF / SPR) Penaeus vannamei broodstock into the country. Since this is an exotic species in the Philippines, hatcheries are required to obtain accreditation from BFAR prior to importation. Accreditation requires evaluation of the hatchery facility, management system documentation and implementation. It includes document desk review and on-site inspection and verification of implementation of the management system including biosecurity measures.
Upon importation, the shrimp hatchery is required for traceability purposes to submit a copy of the import permit and documents such as airway bill (flight schedule, number of broodstock, shipper, consignee, etc.). In addition, documents about broodstock are needed such as: (i) certification of a competent authority from the country of origin that the broodstock facility has a 2 years disease free status; (ii) disease history of broodstock facility for a period covering its commercialization; (iii) laboratory results of samples taken from a lot intended for shipment from competent authority; (iv) samples shall be subjected for laboratory analysis.
The fry produced by the imported broodstock needs traceability profile as indicated in the table of data requirements for farmed fish. The hatchery has to submit disposition report within five working days upon shipment.
Feedmill / drug / biological / chemical supplier The aquatic feed manufacturers keep traceability records such as suppliers, delivery receipt of each batch of raw materials received for production and feed produced dispatch. They also implement internal traceability covering the production process until release of the finish product.
Registration of aquatic feedmills is the mandate of the Bureau of Animal Industry (BAI). Through a Memorandum of Agreement, the BFAR was deputized to conduct monitoring of the aquatic feedmills as part of the national residue monitoring program.
Sampling for antibiotic and aflatoxin analyses is being done at least twice a year. Violations committed are reported to the BAI for their issuance of non- compliances memorandum and appropriate actions
Table 4. Documentation and data required for traceability of aquaculture products at different stages of the supply chain
the inspection and sampling procedure for aquatic feedmill monitoring.
The Food Safety Act of 2013 has provided for the BFAR, as the Food Safety Regulatory Agency for fish and fishery products, to implement and enforce controls at the primary production including all inputs used in fish farming including feeds, veterinary drugs and chemicals. BFAR is now in the process of drafting regulations for this purpose.
2. Production Grow-out Farm
The grow-out farms maintain traceability records including fry / fingerling / PL receiving report, feeding, supplement and consumable inputs, and harvest logs. Small- scale farms retain records by keeping all delivery and purchase receipts of fry, feeds, medication, and other inputs. In bigger farms, detailed records of their farm management practices including feeding, water quality monitoring, health monitoring of stocks, medications and other information relative to their stocks are kept (DA- BFAR, 2008; Regidor & Dabbadie, 2010).
A farm registration scheme is being implemented by BFAR based on Good Aquaculture Practice (GAqP).
This is voluntary for the farms that would like to be included in the national residue monitoring program and to be able to supply their raw materials to the accredited processing establishments for export market. Registered farms are assigned with a unique
identification number which is valid for two years and renewable thereafter. These farms are monitored for hygiene inspection, disease surveillance and residue monitoring. The procedure for farm registration is shown in Figure 7.
At present, there are a total of three hundred thirty three (333) registered farms, one hundred seven (107) milkfish farms, forty nine (49) shrimp farms, forty one (41) tilapia farms and one hundred thirty six (136) farms with polyculture system. The list of registered farms can be accessed through the BFAR website (www.bfar.da.gov.ph).
These registered farms are being monitored at least once a year by the regional fish health officers. They conduct inspection and sampling for residue analysis.
In case of non-compliance with the standards being followed by the Competent Authority on aquatic animal health and food safety, particularly the World Organization for Animal Health (OIE) and Codex Alimentarius Commission, the farm is subjected to stricter monitoring and sampling.
In case of detection of banned antibiotics or residues above Maximum Residue Limits (MRLs) for regulated substances, the fish health officers inform the farm operator and ask to trace the current location or destination of the batch where positive sample were taken, as well as its origin, and determine the cause of having sample positive detection and conduct additional sampling. Figure 8 shows the farm inspection and sampling for residue monitoring program.
Figure 6. On-spot inspection and sampling at the aquatic feedmill
Figure 7. Mechanism of farm registration
Figure 9. HACCP accreditation process
The aquatic animal health services of the Philippines has been evaluated by the OIE experts mission in 2013 against the four fundamental component of the OIE PVS tool such as the human, physical and financial resources, technical authority and capability, interaction with stakeholders and access to market.
It was aimed to establish current performance and develop strategic priorities for improvement of aquatic animal health services.
The impact of the evaluation has lead to some developments such as provision for permanent positions in BFAR reorganization, creation of veterinary positions, capacity building on aquatic animal health, strengthening of laboratory services through procurement of equipment and improvement of facilities. The technical committee of regulatory board of veterinary medicine proposed to incorporate aquaculture medicine and aquaculture production in draft curriculum to the Commission on Higher Education. There will be a follow-up mission by
the OIE to conduct gap analysis following the PVS pathway.
3. Post-Harvest Auction market
Auction market keeps log that contains information on the supplier such as the name of the farm and its registration number, volume of the product, and distribution list. Since there are many farm sources, auction markets are pooling and mixing fish / shrimp, but they have a method of identification for each lot and their origin.
The BFAR Fish Inspection Unit started to implement a voluntary registration system for auction market in 2010 based on HACCP principles. The registration system focuses on hygiene requirements. They are required to develop and implement SSOP / GMP on their operation. Their facilities are being inspected to verify compliance. Since registration system has just recently started, auction markets are not yet adept with the standards and have difficulty in their compliances. There is still a need to continue the information and education campaign about the registration system and help them understand their
important role in the traceability of aquaculture products being part of the supply chain.
The processing plants have been implementing a high level of traceability. This is incorporated in their management system throughout the production / processing. They keep fish receiving report / batch monitoring report, production report, labelling and packing report. The lot / batch number is reflected throughout the production, processing, value adding and at the label and package. The shipment and buyers records are also maintained. They are also required to have a recall procedure in case problem on their shipment happens.
Processing plants are registered with BFAR. They are required to have GMP / SSOP program and HACCP plan. HACCP accreditation process is in Figure 9. Evaluation process includes document review and series of inspection and verification by fish inspectors. Official control sampling is also conducted (Figure 10). For those that export their products to the EU member countries, an EU approval number is required upon recommendation by the competent authority.
Figure 10. Official control sampling at the processing establishment
BFAR Fish Inspection Unit
The BFAR Fish Inspection Unit has developed its quality management system and has obtained its accreditation on ISO / IEC 17020 for the inspection system from the Philippine Accreditation Bureau.
Presently, there are a total of one hundred twelve (112) processing establishments approved by BFAR for fishery and aquaculture products. Sixteen (16) processing establishment are allowed to export aquaculture products to non EU market, and thirteen (13) are approved for EU market.
The documents required for the transport are indicated in the transport logs at different stages of the supply chain. The documentation requirements for transport at the pre-production and production stages still need to be disseminated. At the post- harvest stage, transport documentation is already implemented particularly during the van loading and pre-shipment inspection.
Cold storage facilities are inspected and approved by the Fish Inspection Unit. The facility keeps data required in the cold storage report for traceability according to the type of the product.
The product shipment requires traceability documents such as health certificate issued by the Certifying Officer, export commodity clearance from the Quarantine Officer and airway bill / bill of lading from the shipping line.
Challenges Faced in Implementation and Solutions and Other Relevant Information
1. Lack of understanding on the importance of traceability in the supply chain
Generally, there is lack of understanding on the importance of traceability at different stages of the supply chain. Considering that implementation of traceability entails resources, the small scale farmers have constraints in documentation and record keeping. Although minimum records are kept like purchase and selling invoices / receipts, other relevant information on management practices are not recorded which is important for internal traceability. Unlike in bigger farms where the required documentation and record keeping are already practiced and maintained.
The GAqP developed thru the European Union Trade Related Technical Assistance (EU TRTA) project has been approved as the Philippine National Standard
serve as guide for the farmers in the documentation and record keeping according to the requirements of the standard. The extension officers of BFAR will be trained on GAqP for them to teach farmers on the requirements of the standard.
2. The weak traceability system at the auction market
The auction market is part of the aquaculture supply chain that distributes either to the processing establishments or to the retailers. They can provide the volume required for processing at once through pooling or mixing of raw materials from different sources, generally, even with incomplete documentation.
Since farm registration is voluntary, other farms that are not registered can supply their harvest to the auction market. Further, harvest from small scale farms, with inadequate traceability data is also a limitation of the traceability system.
There is a need to strengthen the registration program of BFAR for the auction market. At present, there is still a minimum traceability data that can be obtained at the auction market. The recently approved BFAR Administrative Circular No. 251 Series 2014 on traceability system for fish and fishery products provides for the traceability documentation requirements for all stages of the supply chain including the auction market.
3. Difficulty in documentation and maintaining records
Small-scale farms generally do not practice documentation and record keeping. They use their extensive experiences in farming and monitor their stocks through observations without keeping records.
Traceability documentation template for farmers was developed as one of the outputs of the project under the EU-TRTA3 project on the implementation of Good Aquaculture Practice. The farmers will be trained and will be provided with the forms for their guidance and implementation.
IV. Future Plans / Programs for Implementation