A conceptual understanding of FS risk in Fisheries Trade Perspective Different types and sources of FS risks associated with FP FS Risks related to the import trade of FP FS Risks related to the export trade of FP Major challenges impacting import & export trade facilitation of FP A Few WAY UOT suggested.

1. Nittya Ranajn Biswas
Addl. Director General (Rtd.) DoF
Member of the BFSA Expert Committee
Food Safety Specialist, JPZ Consulting (under SCMFP, DoF)
Risk in Import & Export of Fish & Fishery Products:
Importance in Trade Facilitation

2. Presentation overview
 A conceptual understanding of FS risk in Fisheries Trade perspective
 Different types and sources of FS risks associated with FP
 FS Risks related to the import trade of FP
 FS Risks related to the export trade of FP
 Major challenges impacting import & export trade facilitation of FP
 A Few WAY UOT suggested.

3. Control Approach:
Risk-based Control Approaches Towards Safer Fishery
Products of Bangladesh Facilitating Trade.
FS Hazards become risk based on the severity and likelihood of
the hazards.

4. Assessing the Food Safety Risks
Codex schematic framework for risk analysis

5. Assessing the Food Safety Risks
Usually Food Safety Risk determines on the basis of Exposure calculating
Average Daily Intake (ADI):
• But lack of Research Works to assess the standards of risk factors,
• Standards mainly set for the Fisheries export products based on the regal
requirements of major importing countries and in some cases following
CODEX guidelines,
• No risk standards have set for imported fishery products; just adopted
from the standards of export except radiation,

6. Food Safety Risks & Trade Barriers
• Tariffs.
• Non-tariff barriers: (Import licenses. Export control / licenses. Import
quotas. Subsidies. Voluntary Export Restraints. Embargo. Currency
devaluation. Trade restriction, etc.)
• TBT: TBT refers to mandatory technical regulations and voluntary
standards on Sanitary and Phytosanitary (SPS) measures; that define
specific characteristics that a product should have, such as its food
safety, size, shape, design, labelling / marking / packaging,
functionality or performance.
• TBT also refers as Food Safety Standards or requirements
• Harmonized with CODEX Alimentarius and WTO guide line.

7. An overview of the Food Safety Risks associated with F & FP
refers to Trade Facilitation
Biological hazards Chemical hazards Physical hazards
 Infectious
bacteria
 Toxin-producing
organisms
 Moulds
 Parasites
 Viruses
 Naturally occurring
toxins
 Food additives
 Pesticide residues
 Veterinary drug
residues
 Environmental
contaminants
 Chemical contaminants
from packaging
 Allergens
 Metal, machine
filings
 Glass
 Jewelry
 Stones
 Bone chips
 Jelly, Agar, water
Others
• Lack of
equivalence
with
requirements
of importing
countries,
• Fraudulent
practice
(Fake certificates,
test reports and
other documents

8. Different Groups of Chemical Hazards in FP of BD
• Group A1- Stilbenes (Diethylstilbestrol, Hexes-sterol, etc.)
• Group A3 - Steroids (Methyl Testosterone, Estradiol)
• Group A6 - Chloramphenicol, Nitrofuran metabolites (AOZ, AMOZ, AHD,
SEM), Metronidazole, Dimetridazole)
• Group B1- TC, OTC, CTC, Amoxycillin, Gentamycin, Tylosin,
Sulfonamide,
• Group B2(a)- Flubendazole, Mebendazole, Fenbendazole,
• Group B3(a)- Organochloride pesticides (DDT, Heptachlor, Endrin, Aldrin,
Di-eldrin)
• Group B3(c)- Chemical elements (As, Pb, Hg, Cr, Cd), PCBs
• Group B3(d)- Micotoxins (Aflatoxin B1,B2,G1,G2)
• Group B3(e)- Dyes (CV, LCV, MG, LMG)

9. Biological hazards in fishery products in Bangladesh
Pathogenic bacteria & virus
Pathogenic bacteria can be introduced to fish through many
ways:
 the aquatic environment;
 Water used for washing cleaning;
 humans and animals;
 Dirty tools;
 Poor handling and hygiene practices
Examples:
 Vibrio spp.
 Salmonella and Shigella species.
 Pathogenic Escherichia coli
 Staphylococcus aureus
 Viruses

10. FS Risks depend on Types and Sources of Fish & its products
Types of Fish:
Live fish for human consumption or aquaculture (All groups including pathogens)
Ready to cook (All groups if fish from aquaculture)
Ready to Eat (MB & All groups if fish from aquaculture )
Sources fish:
Marine fish ( B3 (c) particularly Cr and As if fish caught from marine mining zone
Inland Open-water (MB, B3(c) )
Aquaculture (MB & All groups)
Specific geographical region (Radiation)
Supply chain:
Seed (Hatchery- All groups)
Feed (ingredients- All groups)
Processing & Preservation (preservatives; schedule-16 of FIQC Rules)
Transportation (depends on types of products)

11. Trade Volume of Import & Export of Fish & Its
Products
2017-18 2018-19 2019-20 2020-21 2021-22
Import (MT) 45860.03 87511.75 78997.12 71421.71 102732.05
Export (MT) 68935.45 73171.32 70945.39 76591.69 74042.67
45860.03
87511.75
78997.12
71421.71
102732.05
68935.45
73171.32 70945.39
76591.69 74042.67
0
20000
40000
60000
80000
100000
120000
Import & Export Volume (MT) of Fish of Bangladesh
Import (MT) Export (MT)

12. Risks in Import of Fish and Fishery Products in
Bangladesh
• Mainly Marine Fish from Gulf Countries:
B3 (c) particularly Cr and As if fish caught from marine mining
zone,
According to ADI/Exposure, the risk is negligible,
• Inland Open-water Fin Fish Myanmar & India:
(MB, B3(c)- exposure negligible,
• Freshwater Aquaculture (India & Myanmar): exposure negligible
• Ready to cook (Vietnam) Filleted Pangasius, Seabass: (All groups if fish
from aquaculture),
• Live Fish Seed (Thailand, India, USA): risk mainly pathogen- Strict
quarantine measure necessary,

13. Legal Provisions on SPS Requirements of Import of Fish & Fishery
Products in Bangladesh
Relevant National Regulations:
1) Fisheries Quarantine Act 2018
2) Fish and Fishery Products (Inspection and Quality Control) Acts 2020:
Sections implied- Section- 22 ( import bars), 23 (NOC for import), 24 (terms
and conditions for import), 25 (Inspection of imported fish) and 26 (Cancellation
NOC).
3) Import Policy Order 2021-2024:
Chapter-5, Para 23 (human food import), sub-para-3,4,5 &7 (radiation), 31& 32
(formalin test);
Para 24 (Fish feed), sub-para 2ka(CAP, NF harmful medicine, steroid, hormone free),
Sub para 3 (radiation free)
4) Proposed Rules on Fish and Fishery Products (Inspection and Quality Control) Acts 2020;
Rule 29 (1) refers to schedule 15 (details on sampling & testing), 16 (Permissible
limits of diff. food additives, preservatives and anti- oxidants), 17 (List of
prohibited and MRL substances).
Rule 30-36 (stated import procedures)

14. Fish and Fisheries Products Exported from Bangladesh:-
1. Shrimp/Prawn (processed, frozen, cooked, etc.)
2. Finfish (whole, dressed, degutted, fillets; live, chilled,
frozen)
3. Dried fish
4. Salted dehydrated fish
5. Eels (live)
6. Crabs (live and frozen)
7. Shark fins
8. Scales of finfish
9. Shell of shrimp/prawn
Risks in Export of Fish and Fishery Products in Bangladesh

15. Different Chemical Hazards in FP of BD impact Trade
• Group A1- Stilbenes (Diethylstilbestrol, Hexes-sterol, etc.)
• Group A3 - Steroids (Methyl Testosterone, Estradiol/Estrogen/17-α Estradiol)
• Group A6 - Chloramphenicol, Nitrofuran metabolites (AOZ, AMOZ, AHD,
SEM), Metronidazole, Dimetridazole)
• Group B1- TC, OTC, CTC, Amoxycillin, Gentamycin, Tylosin,
Sulfonamide,
• Group B2(a)- Flubendazole, Mebendazole, Fenbendazole,
• Group B3(a)- Organochloride pesticides (DDT, Heptachlor, Endrin, Aldrin,
Di-eldrin)
• Group B3(c)- Chemical elements (As, Pb, Hg, Cr, Cd), PCBs
• Group B3(d)- Micotoxins (Aflatoxin B1,B2,G1,G2)
• Group B3(e)- Dyes (CV, LCV, MG, LMG)

16. Routes of chemical hazards as in fishery products in
Bangladesh impact Trade
Chemical contamination :
• The environmental chemical contaminants such as pesticides, heavy
metals and industrial pollutants found in the aquatic environment;
• improper use of veterinary drugs such as antibiotics and growth
hormones used in aquaculture;
• Self producing toxins and naturally occurring toxins;
• use of unapproved food additives, flavourings and enzymes, or
unregulated use of approved additives;
• accidental contamination from oil, cleaning, pest control and other
chemicals.

17. Risks in fishery products for Export Trade of
Bangladesh
Pathogenic bacteria
Pathogenic bacteria can be introduced to
fish through many ways:
 the aquatic environment;
 Water used for washing cleaning;
 humans and animals;
 Dirty tools;
 Poor handling and hygiene practices
 Vibrio spp.
 Salmonella and Shigella species.
 Pathogenic Escherichia coli
 Staphylococcus aureus
 Viruses
Physical hazards:
Filth,
Adulterant
Fraudulent Practices

18. Major Challenges to Import of Fish and its products
Releasing imported Fish in to Bangladesh
1) Fisheries Quarantine Act 2018, Fish & Fishery Product (inspection &
Quality Control) Act 2020 (with Proposed Rules) and IPO-2021-24
apparently look supportive to Import of Fish & Fishery Products.
2) However, some bottle neck at forward chain of import are concern-
• Quarantine procedure yet to ready
• Testing facilities of diversified pathogens yet to install
• Lack of suitable storage facilities for detained container with proper cool chain,

19. • Dependency on a solo products (Black Tiger Shrimp); Inequal competition
with Vannamei shrimp
• BT Raw Materials deficit
• Dependence on the narrow range of products
• Brand image of export product is a concern for access to global market
• Deficiency of third party certification for Farms and products
• Lack of research and development (R & D) to enhance export of fisheries
products
• Require Increased capacity of the CA to co-up with increasing standards
of food safety of importing countries,
Major Challenges to Export of Fish and its products

20. • Deficiency of automation of CA’s Health Certificate and Lab report
• Non equivalence to the importing country’s regulatory requirements
• Increasing Stringent Food Safety Requirements and Standards
• New laws and conditions imposed/set by importing countries
• Lack of competitiveness of Food Business Operators
• Poor backward linkages of the exporters
• Lack of business integrity and transparency of the exporters
• Country’s self imposed Ban on the Hilsa export
• Low No. of complaint fishing vessels for marine catch
Challenges to Export of Fish and its products

21. WAY OUT
Import:
• Bangladesh CA needs to Sign MoU with exporting country’s CA on SPS & trade requirements,
• Need separate SOP for risk management of imported fish and fisheries products based on its source
and products types considering consequent risk factors of such products,
• Learning program on the risk management approaches for all stakeholders like DoF, Importer, feed
manufacturers, and aqua inputs importers including value chain actors,
Export:
• Dissemination of GAP & BAP principles among primary production actors,
• Learning program for exporters on product diversification,
• Increase productivity of the raw materials of diversified fish and shrimp species,
• Widening the scope of the National Residue Monitoring Program;
• Install process of automation of HC and Lab reports,
• Ensure local production and supply of quality feed and seed of mass traded shrimp species,
• Adoption of Third party certification scheme,
• Capacity building of exporters through developing composite entrepreneurship, etc.