Amber Sallahuddin.

Marya Siraj.
Sana Saleem.
ABSTRACT: 4

LITERATURE REVIEW: 4

RESEARCH OBECTIVES: 7

METHODOLOGY: 7

ON-SITE FIELD SURVEY: 7

INTERVIEWS: 7

INTRODUCTION: 7

OVERVIEW: 8

FISHERIES INFRASTRUCTURE: 10

FISH PROCESSING 11

PROCESSING PLANTS: 11

TRANSPORTATION 12

WITHIN THE COUNTRY: 12

INTERNATIONAL: 12

EU BAN 12

WHAT CAUSED THE EU BAN? 13

HARBOR CONDITIONS: 13
TEMPERATURE ABUSE: 14
TRANSPORTATION AND WICKER BASKETS: 14
WOODEN FISH STORAGE COMPARTMENTS ON BOATS 15

EU BAN ON PAKISTAN’S SEAFOOD EXPORTS 15

RECOMMENDATIONS: 18

2|Page
ASSURANCES GIVEN BY THE COMPETENT AUTHORITY: 18
DEFICIENCIES: 19

STEPS TAKEN BY THE GOVERNMENT AND DEPARTMENTS: 20

SAFETY AND HAZARD STANDARDS 23

CARE AND CLEANLINESS 23

PROTECTIVE CLOTHING 23

TRANSPORTATION OF IDEAL FISH 23

RIGHT PALLETING FOR TRANSPORT 23

PACKAGING OF THE FISH 23

PRIMARY PACKAGING: 24
SECONDARY PACKAGING: 24
TERTIARY PACKAGING: 24

CONCLUSION 24

SUGGESTED FURTHER WORK 24

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Abstract:
Pakistan’s coastline does not only provide as a strategic commercial gateway for global trade but also
serves as a sanctuary to some of the most admired species of fish and shrimps in the world. The coastal
belt which measures approximately 700 miles, covering the territorial waters of the two southern
provinces, provides a source of livelihood for millions of people in the region. Despite the fact that
Pakistan’s aquaculture produce has proven demand in various parts of the world, the industry is not able
to fully realize its potential in terms of contribution to the country’s GDP, export earnings through
international trade and domestic employment opportunities. Non-conformance to international quality and
safety standards, absence of a strategic direction for sustainable development of the sector and
environmental issues associated with the contamination of the ocean habitat and depleting aquaculture
resources, all jeopardize the future of an industry crucial to the bread & butter of millions.

This study attempts to investigate the problems which have plagued the industry for decades, by focusing
on their root cause, which can be traced back to various loopholes in maintaining standards. A critical
and methodical analysis of the network will be carried out, with special emphasis on pre-processing and
harvesting activities. Feasible remedial measures will be suggested in order to transform the non-value
adding activities into sustainable advantage for the future. Furthermore, the research will highlight the
post EU-ban initiatives taken by the government & the MFD to enforce the standardization &
documentation of procedures as well as reduce compliance lapses with respect to the quality of the catch,
appropriate storage, hygiene & safety.

Literature Review:
This segment explains the concept of sustainable development in the context of the aquaculture industry.
Furthermore, the structural lapses in the supply network and the commercial and environmental aspects of
the mismanagement and negligence surrounding the seafood value chain in Pakistan, leading to export
bans from the EU.

According to a FAO report on the challenges of global seafood industry, by Grimur Valdimarsson,
approximately 50 million people worldwide depend on fishing for all or most of their family earnings,
while another 150 million depend on fish processing and the fleet servicing industry. More than 10
million work on 2.5 million small-scale fishing vehicles and account for 50 per cent of the world’s catch.
An increase in the number of artisanal fishermen and industrial vessel activity in coastal waters are the
main causes of fish stock depletion, since coastal over-fishing is a leading problem in developing
countries (FAO 2001).

Another report pertaining to the findings of the Food and Agriculture Organization of the United Nations
(FAO), “An estimated 25 per cent of major marine fish stocks are under-exploited or moderately
exploited. About 47 per cent of the main stocks or species groups are fully exploited and are producing
catches that have reached, or are very close to, their maximum sustainable limits. Another 18 per cent of
stocks or species groups are reported as over-exploited. The remaining ten per cent of stocks have become
significantly depleted, or are recovering from depletion and are far less productive than they used to be.

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Catches of commercially-valuable fish species may be surpassing permitted levels by over 300 per cent
due to illegal and unregulated fishing (FAO 2005).

Parashar Kulkarni (International Institute for sustainable development- 2005) in her research on the
“marine seafood export supply chain analysis” argues that sustainability of marine fish stocks is a global
concern. Fishing methods such as bottom-trawling uproot the ecosystem at the bottom of the sea. Drift
nets covering miles of ocean result in catches of diverse fish varieties. Some of these methods are banned
in many countries. Sustainability in the seafood industry depends on the conservation of fish stocks so
they are not depleted and continue to be a part of the common man’s diet.

She continues to add that sustainability of fisheries is distinct from sustainability of the fishery sector.
While the former deals mostly with environmental & resource management, the latter is also concerned
with the sustainability of the supply chain, such as fisherman livelihood issues, employment issues,
growth of the industry and income adequacy. Sustainability is, therefore, not only restricted to resources,
but also to people and governance processes. Understanding the sustainability of the fishing industry must
also include the study of each component of the supply chain, of problems at the bottom levels in the
supply chain, and of the viability of supply chain certifications in promoting sustainability.

Based on the University of Hawaii research in 2007 on global seafood supply chains, in contrast to the
integrated chains in developed countries, the chains in developing south Asian countries are fragmented
and loosely organized.

A typical seafood supply chain in a third world country involves the fisherman, commission agent,
supplier and the exporter. The fishermen in third world countries are not professionally educated. Thus
the ice on which they stock the fish, to keep it fresh, is made from unclean water. Proper sanitation is not
used while handling the ice. The commission agent assesses the catch and sells it to the supplier. Even at
this stage the sanitation is very poor. The exporter is the final stage in this supply chain. The fishermen
are highly disorganized and in need of proper sanitation facilities. They must also be able to handle future
developments in the fishing sector, especially technical developments so that the quality of their catch is
improved. They must also be provided basic hygiene training so that proper sanitation is maintained
(Parashar Kulkarni, 2005). The cold chain is largely inefficient, as a result of which marine fish sold in
the domestic market is quite limited. Also as you go further inland, the price of the fish increases
(Pawanesh Kohli, 2008).

In the developed world, practices are being adopted to make cold chains more effective. However this is
not the case in Pakistan. According to a European Union survey carried out in 2007, there were two main
deficiencies in the Pakistani fishing industry:

1. Lack of traceability record

2. A deficient cold chain

These were the reasons that led to the ban by EU in 2007, which has not been lifted till date. As a result of
this ban, Pakistan is losing out on export earnings of $50 million per year (Shahid Shah, 2010). According
to the Marine Fisheries Department, Pakistan exported shrimps to Netherlands and squid and cuttlefish to
Italy and Spain. The EU team was supposed to visit Pakistan for inspection but due to the law and order
situation, this didn’t happen. Also the EU excluded Pakistan from its inspection list, thus making the ban

5|Page
more permanent. The EU however, before putting the ban had urged the Pakistani government to
maintain its cold chain, but that did not happen. This eventually led to the ban.

According to the Competitiveness Support Fund report, one of the two hazards facing the Pakistani
Fishing industry is poor quality. This leads to low competitiveness in the world market since the
international standards are not met. The Action Plan provided in this report focuses on providing
infrastructure and equipment so that the quality of the fish is retained throughout the cold chain. This
report also highlighted the fact that rules and regulations are widely disregarded, thus leading to a supply
chain which is not hygienic as it should be. This report also stated that poor management, unjust
allocation of resources and failures in the cold chain leading to unacceptable products may lead to the
unemployment of many from the estimated 1,000,000 that rely on Marine Fisheries. The corrective
measures which will be taken involve reduction of losses by upgrading the fish holds of existing boats,
installing ice flake making machines and refrigeration systems on fishing boats. It also recognizes that
quality of the fish is not maintained from the vessel to the end consumer, which has led to low
competitiveness in the world market.

Aroosa Masroor, in her article published in a private newspaper in Karachi claimed that Marine fish
landings in Pakistan are approximately a total of 0.4 million MT per year, out of which 30,000 MT are of
shrimps that not only constitute to the backbone of the local marine fishing industry but are also an
important source of foreign exchange for Pakistan as a whole. But this loss of shrimp due to the heavy
pollution, particularly arising from excessive leather tannery discharge from industries is having a
devastating effect on the fishing industry.

She adds to it that Marine life forms do not die out due to consumptions of heavy metals. In fact, she
says that these toxic metals stored in their fats are consumed by the bigger marine animals which mean
transferring the pollution load to their predators. The level of contamination increases, and when these
contaminated marine species are consumed by humans, it creates serious health problems, sometimes
proving fatal. These heavy and toxic metals have carcinogenic qualities and can cause genetic
deformation, besides affecting other vital organs like brain, heart, kidney, lungs and bones of the human
body.
           
Aroosa Masroor, further claims that wastewater flows are about 1,000 million liters per day at present,
and this figure is projected to increase to over 3,000 million liters/day by 2025, resulting in low level of
dissolved oxygen for marine life. Based on an average Biological Oxygen Demand (BOD) strength of
400 tons per day, the total BOD load is expected to rise at about a level of 1200 t/d by 2025, as most of
this waste water is discharged into the rivers without treatment. Fish becomes scarce if there is a
reduction in oxygen amount and results in anaerobic bacteria.
           
According to a report of Karachi Water and Sewerage Board (KWSB) published in 2005, the official
sewerage system in Karachi serves only 40% of the city population. Of the 350mgd (million gallons
daily) of the waste water is produced every day, only 40mgd is treated by the official systems. The rest
goes untreated into the open sea through drains.

6|Page
RESEARCH OBECTIVES:
The objectives of the study are:

• To analyze the structure of the industry, its commercial importance and potential.

• To investigate the existing loopholes in the quality standards related to environmental issues,
productivity lapses, hygiene and safety.

• To study the repercussions of the supply chain problems leading to the EU ban.

METHODOLOGY:
The information for this study was gathered employing the following techniques:

 On-site field survey

 Interviews

On-Site Field Survey:

The on-site field survey was conducted by visiting the Karachi Fish Harbor. During the visit, small
discussions were held with local fishermen regarding the fishing process, post-harvest issues, economic
concerns and their complaints against the Harbor authorities and government policies etc.

Processing plants within the harbor vicinity were also visited in order to gain insight about the magnitude
of technology being employed in the process of value addition and maintaining conformance with
international standards and buyer specifications.

Interviews:
Apart from on-site observational surveys, one-on-one interview sessions were also held which involved
stakeholders associated with the fishing industry, including the Karachi Fish Harbor Authority, Marine
Fisheries Department and Pakistan Seafood Industries Association.

Introduction:
Generally speaking, a seafood supply chain is comprised of the seafood source (through fishing or
aquaculture, or imports), collecting, processing (primary or subsequent), wholesale/export,
import/distribution, and retailing before reaching the consumer. The chain may be longer or shorter, but
the value-adding elements generally fall into one of these generic segments. In reality, each segment
could represent an entire chain or competing distribution channels. The source, for example, could also
represent multiple import sources, harvesters, or a complex aquaculture system that can further consist of
maturation, hatchery, nursery, and grow out value-added processes.

7|Page
Overview:
Pakistan’s fisheries sector is a USD 1.2 billion industry, with over a million people directly or indirectly
attached to it for their livelihood. Majority of the communities that rely on this industry for their survival,
reside in the coastal areas of Sind & Baluchistan. A government estimate shows that the sector constitutes
of approximately 185,000 fishermen and another 650,000 people indirectly linked with this industry in
the form of government personnel, employees, exporters, traders & brokers, suppliers, fleet servicemen
etc.

Based on FAO country forecasts, Pakistan’s fisheries production witnessed a boom during the period
from 1997 to 1999, when the total production (inland & marine) reached the level of 654,530 MT. Since
then, the trend has experienced a steady downward slope with the production levels stagnant between
525,000 to 575,000 MT per annum. While the marine catch has substantially decreased from a record
474,665 MT in 1999 to approximately 342,556 MT in 2008 and increased marginally to 344,648 MT in
2009. The inland fisheries production has shown a continuous upward trend till date. The new National
Fisheries Policy, announced in early 2008, aims at increased fishery production of about 53,000 MT per
year and higher seafood exports. The key to increasing fishery exports will be the achievement of a

8|Page
substantial reduction in the waste catch which, along with over-fishing, has held back fisheries
development in recent years.

Latest statistics illustrate that about 21% of the marine catch is exported annually. Although the
percentage of sea food export has been steadily increasing, the reduction in the volume of the marine
catch maintains export levels to considerably lower quantity than what used to be in the past. Shrimp is
the main export item in terms of value while fish are the largest item in tonnage terms, but usually lower
than shrimp in value. At present, Pakistani sea food exports have brought export earnings worth USD 250
million (FY09-10), which is the highest recorded level of export income generated from this sector up till
now. This is because Pakistani aquaculture produce has been able to fetch better prices as compared to
previous years.

EU countries traditionally provide the largest market for Pakistan's fishery exports, taking about half of
total exports by value. Apart from EU countries, Japan and the United States also make up the customer
portfolio for Pakistani fisheries. However, following the EU export ban, a number of countries have
emerged as potential markets for Pakistani aquaculture products which now import approximately 73 %
of the annual export marine output. They include China (18%), South Korea (7%), Thailand (17%),
Malaysia (5%), Indonesia (4%), Saudi Arabia (5%) & the UAE (17%). [Source: Govt. of Pakistan,
Marine Fisheries Department]

Almost 60% of Pakistan's non-exported marine fishery catch, corresponding to about 170,000 MT of fish,
is used to produce about 37,000 MT of fishmeal, most of which is used locally in poultry feed. As a
result, only about 160,000 MT of marine fishery production is consumed domestically in fish form each
year. Local fish consumption also includes freshwater species with about 170,000mt of fish produced
from inland waters also being consumed each year, mostly in northern parts of the country.

10%
21%

Export Domestic Consumption

29%
Fishmeal Subsistence

40%

Source: Enhancing Fish Exports Handicaps & Remedial Measures. September 2009

9|Page
Pakistan’s total seafood exports can be seen in the graph below. Notice how quantity and value in terms
of dollar has been increasing over the years. Even with the EU ban in place the exports kept on increasing
mainly because Pakistan found some new markets.

Unfortunately, the per capita consumption of fish in Pakistan is near to the lowest in the world. Based on
the findings of FAO, Pakistan’s per capita consumption of fish is 1.6 kg’s as compared to the world’s
average per capita consumption, estimated to be approximately 16.5 kg’s. The reason behind such low
levels of domestic consumption of fish is mainly because of limited consumption of fish during the warm
summer months which extend from March to October. Furthermore, fishery products are consumed
mainly in the coastal region where about 20 million of the country's 144 million population live. Other
causes can be attributed to high price of fish, insufficient availability and inefficient marketing system to
stimulate local demand. Moreover, High transportation costs and limited cold storage services mean that
the inland market price of fish is high compared to the coastal region and less affordable than animal meat
and other products.

Fisheries Infrastructure:
Although the national coastline hosts a number of fishing harbors, the most modern in terms of facilities
and widely used is the Karachi Fish Harbor making it the centre of the fishing industry with about 6,000
of Pakistan's estimated 13,000 fishing vessels using it. The total marine fishing fleet includes about 2,600

10 | P a g e
shrimp trawlers and about 3,600 gill netters. Other fishing boats are mainly motor-cum-sail boats with
outboard engines. Other important fish harbors include the Korangi Fish Harbor in Sind, and Gwadar &
Pasni in Baluchistan. Apart from these permanent fishing ports, a numerous small jetties and fish landing
sites are located in various fishing villages throughout the coastal region.

The figure below shows the names of the locations of fish harbors, jetties and auction halls:

Table 5: Fishing Village/Landing Points

Sindh Kharo Chaan
Karachi Jatthi
Korangi Jhangi Sir
Ibrahim Hyderi Badeen
Shams Peer Baluchistan
Lath Basti Gwadar
Hawks Bay Coast Pasni
Manjhar Ormara
Sonari Gaddani
Mubarik Village Bhunda Wari
Ketee Bandar Beroo
Shah Bandar Somiani Daam
Surbandar  
Source: SDPI Survey, July 2005

Fishing vessels of various sizes, ranging from small to medium-sized boats, large launches and trawlers
engage in fishing. The season extends from October to June for fishes and August to November for
shrimps. Boat and shore fishing is done in creeks and within the 12 miles territorial limit which falls
under provincial jurisdiction. The larger launches go further off shore into deeper waters on extended
fishing excursions which can last up to 2 months, some reaching as far as the middle of the Indian Ocean.

Fish Processing:
Processing Plants:

A great portion of the total catch is purchased by the processing plants. These plants are mostly located
near the harbor like Ibrahim Haideri, Korangi and Karachi Fish harbor. If the plant is located within the
harbor vicinity then the fish is transported through trolleys. If not, then it is transported via processor’s
own vehicle which carries small quantity of ice. A typical processing procedure flowchart is shown on the
next page.

These plants process the catch according to different market requirements. There are over 300 species fish
caught in Pakistan and each has its own different market. Even the different size of the shrimp can mean

11 | P a g e
a different market all together; for instance Pakistan’s Kiddi shrimps are only sold to European countries
as they don’t have a market elsewhere.

Once the fish is taken to the processing plant it is sorted and weighted according to different market
requirements and buyer specifications after which the processing starts. First the internal organs are
removed and the catch is cleaned with water. Than an inspection is done to ensure that everything is
according to the standards, as any short comings can cancel the export order. After making sure that
everything is in place the seafood is frozen, than packed and later dispatched.

Transportation:
Within the Country:
Sea food is transported via 40ft containers because the freight charge per kg of it is lower than that of a
20ft container. These containers are specially designed with freezers to ensure that contamination doest
spoil the fish. Besides, some seafood is transported without freezing to upper country making the fish
unhealthy for human consumption.

Supermarkets transport the fish with the help of their personal transportation but they hire a middleman or
an agent who ensures that quality is not compromised. On the other hand, fish bought by the hawkers
hardly get to see ice, until they are on the stalls where very little ice is placed around the fish which is
insufficient to keep its temperature down.

International:
For export orders, processed seafood, whether salted or chilled, is sent by air. Since major markets for
Pakistani seafood are the far-eastern and European countries, transporting seafood via sea cargo is also
done and the seafood is packed in the containers with freezers in it. But transportation through sea is done
very rarely because it takes a lot of time for the seafood to be transported and the cost of the containers
with freezers is higher.

EU ban:
As part of the quality assurance EU held inspections in different countries. The reason for these
inspections is to ensure that seafood entering an EU country is according to the EU standards. As Pakistan
also exports its products to the EU countries; EU held inspection in December 97 and found out that
Pakistan fisheries industry is not performing according to its standards. As a result EU put Pakistan in list
2 as part of the warning which is like a green card in hockey terms. In order to see whether Pakistan has
taken steps towards improving its fisheries practices; EU held its second inspection in March 1999. This
time again Pakistan’s Fisheries fell short of expectations and as a result Pakistan was included on list 1, a
yellow card. In its third inspection in January 2005 Pakistan was again short of the mark and as a result
before the EU could take any actions Pakistan Fisheries placed a self imposed ban for 6 months. In April
2007 visit the EU inspectors delisted 10 processing establishments for exporting seafood to EU resulting
in a Defacto ban which is still in place.

12 | P a g e
What caused the EU ban?
Harbor conditions:

The catch was dumped outside the auction halls for convenience, so that they can be loaded on the trucks
and transported quickly. The catch was not kept in ice and put on the floor it was subject to temperature
abuse. The image above shows how shrimps are kept in sewerage water on road making them unhealthy
for human consumption.

The image above again shows the conditions at the harbor, again the catch is placed without ice and under
sewerage water. If you look closely, you can even see a pan spit in the sting ray.

13 | P a g e
Temperature abuse:

Temperature abuse happens when the seafood is kept without ice which results in contamination from
bacteria. Fish is kept in ice in the boats but when they arrive on the harbor for auction they are kept
without it. The above image taken in 2005, i.e. before the Defacto ban was in place shows fish being
unloaded at the harbor, notice how it is placed on the floor without ice resulting in not just temperature
abuse but different bacteria.

Transportation and wicker baskets:

14 | P a g e
 The means of transportation used to transfer the catch at the harbor were unhygienic as it can be seen
from the picture above. Not only that the use of wicker baskets were very common throughout the cold
chain because they were cheaper alternatives of plastic crates. These wicker baskets are very unhygienic
as they get contaminated with bacteria very easily and they can act as a carrier of harmful germs and
bacteria with repeated use.

Wooden fish storage compartments on boats:

The fish when caught was placed in the wooden compartments on the boats. These compartments just
like the wicker baskets are home to different bacterial and germs and they also don’t provide proper
insulation and it was difficult to maintain the temperature resulting in temperature abuse.

EU Ban on Pakistan’s Seafood Exports:

This is a summary on a follow up mission that was carried out in Pakistan in January 2007. This mission
was carried out to evaluate the control systems that govern the production of fishery products intended for
export to the European Union (EU).

The main objective of this mission was to verify that to what extent the assurances and corrective actions
submitted by the CA in response to the previous mission report were actually implemented and enforced.

This mission was a follow up to the FVO mission carried out in 2005. In that mission shortcomings were
identified in the effective working of Competent Authority, Marine Fisheries Dept, in imposing the
Community requirements. Deficiencies were identified in the official control system and the sanitary
conditions in all the steps of production. As a result, fishery products (FP) from Pakistan posed a public
health risk. Owing to this, the Pakistani CA suspended exports from February 2005.

As stated in this report, in 2007, 13 establishments were authorized to export. The export volume over the
years was as follows:

15 | P a g e
 exports (in tonnes)
18000
16000
14000
12000
exports (in tonnes)
10000
8000
6000
4000
2000
0
2003 2004 2005 2006

Source: MARINE FISHERIES DEPARTMENT, GOVT. OF PAKISTAN

The following table shows the value of exports from 2004 to 2009. Even though the ban was in place
Pakistan exports kept on growing; this was mainly because Pakistan managed to find new markets just in
time to cushion the ban.

16 | P a g e
The graph below shows percentage of Pakistan’s fisheries exports to countries other than the EU.

The export composition over the years was as follows:

70%
60% 2005
50%
2006
40%
30%
20%
10%
0%
shrimps cephalopods fish preserved fish
and shrimps

Source: MARINE FISHERIES DEPARTMENT, GOVT. OF PAKISTAN

Jeddah Ban on Pakistan Seafood Export:

The Saudi Arabia’s main city Jeddah imposed a ban on fresh seafood from Pakistan because the
authorities found undesized fish with poor quality. In the Middle East, Jeddah and Riyadh are considered
the two major markets of the Saudi Kingdom for Pakistan's export of fresh seafood, including fish and

17 | P a g e
shrimp. The country is already facing a ban on its frozen seafood export in the EU on quality grounds
since 2007. The primary reason behind the ban,Anwer Khan, a person from a news channel said, was that
the exporters had been using a great amount of ice (instead dry ice) to save the cost which had damaged
the quality of seafood during air transportation. The issue of undersized fish export had also contributed
to the ban. "Dubai is a big market for Pakistan but there importers buy seafood on credit account,
whereas, Jeddah's buyers do the business on cash," they said, adding the country's many exporters were in
debt of at least Rs 10 million each to mole holders after rejection of their export consignments in the
kingdom.

[Source :http://www.pakissan.com/english/news/newsDetail.php?newsid=23837]

This report states the recommendations which were made by the 2005 mission, DG(SANCO)/7557/2005.
It then states the assurances which were given by the CA. The object of this mission was to verify to what
extent these assurances are implemented, thus this report also states the findings of the mission.

Assurances given by the Competent Authority:

In response to the above given recommendations, the competent authority gave the following assurances.
These were investigated in the 2007 mission.

1. An emergency program will be launched for the improvement of fishing boats. This will include
improvement of fish holds, provision of insulated boxes for storing fish so that it avoids bruising,
improvement of the deck, provision of potable water, wash basin and soap, isolation of generators
to avoid contamination with fuel, pest control, implementation of cleaning program and educating
the fishermen. Only those vessels which meet the requirements of Pakistan Fish Inspection and
Quality Control and the European Council Directive will be approved. Such an inspection
program involves regular monitoring.
2. An auction hall will be made at the Karachi Fish Harbor. Several modifications will be made to
the existing auction hall, which include
a. Improving floors and walls
b. Repairing ceilings and doors
c. Installing protected lights
d. Weighing machines
e. Auctioning or sorting tables
f. Fish crates
g. Wash basins
3. Some establishments have arranged for direct transport of FP. In such cases the inspection will be
done at the approved establishment. No establishment will be allowed to procure fish from an
unapproved landing site.
4. All establishments are inspected at regular intervals using a checklist which is prepared by the
Marine Fisheries Department. If any deficiencies are found, the establishment will be given time
to rectify it. If this is not done within the specified time period, the establishment will be banned
from exporting

18 | P a g e
 5. Freshness criteria for fishery products will be established. Arrangement for inspection will be
made at the Karachi Fish Harbor, where each batch will be inspected. No FP will be allowed to be
exported until each batch is inspected by Marine Fisheries Department (MFD)
6. Program for improvement of flake ice plant to be launched. A flake ice plant would be
operational by 31st December 2005. Till this plant is operational, sites and auction halls will be
provided by flake ice from approved establishments.
7. Ice supply will be monitored by the MFD to make sure that ice comply with provisions of
Pakistan Fish Inspection and Quality Control rules.
8. To avoid contamination during handling of the FP, a systematic arrangement for offloading will
be prepared
9. Fish will be brought to auction area and sorted on tables with adequate amount of ice. This will
make sure that the temperature does not drop below melting ice at any point.
10. Until there’s a chill room, no fish product will be retained for more than half an hour at the
auction site.
11. A proper disposal system will be prepared, where all the fish which is unfit for human
consumption will be disposed off during inspection.

Deficiencies:
Even though the CA gave numerous assurances that they will do their best to follow the recommendations
given by the previous mission, this follow up report stated many deficiencies which existed in the system.

 K1 section of Karachi Fish Harbor is the only approved auction site. Thus all FP, which is to be
exported to EU should be auctioned at this site. However this was not the case. Some shrimp
were received at times which were different from the receipt time of the K1 section.
 The mission also received information about other auction sites like K2 and Gwadar providing
product to EU. These sites were not approved by CA; however this information could not be
verified.
 Inspections were carried out at establishments and deficiencies were identified. However
subsequent reports show that certain deficiencies were repeated. Even with this non compliance,
establishments were allowed to export.
 Deficiencies identified by the mission regarding cold chain, hygiene and HACCP were not
identified by the CA and thus weren’t included in the inspection report.
 The mission also found that FP, which was unfit for human consumption, was auctioned and
supplied to, and processed by the EU, approved establishments.
 The insulated plastic boxes in some vessels had no ice, while in others the boxes had insufficient
amount of ice. The ice that was used was of poor quality as well. In some vessels, the amount of
ice used was small when compared to fish. This proves that the FP is not kept at the required low
temperature.
 The icing method was deficient. Ice was mainly put on top of the products and not in layers, as is
required to ensure maintenance of low temperatures. As a result of the icing method used the
products at the bottom did not have the adequate temperature.
 The drain pipes of the insulated boxes were closed. This did not allow the melt water to flow out.
Thus the produce came in direct contact with the melt water as well.

19 | P a g e
  The temperatures of the products auctioned ranged from 17,6 0C to 0,80C. such temperatures are
too high for fish.
 The vessels were not designed to minimize contamination, there were some in which the FP came
in direct contact with wood, thus contaminating the produce.
 The processing facilities did not guarantee protection from pests and dust. The reception area was
not closed form external environment. The walls and ceilings of the establishments were not
clean as well. All of this led to high chances of contamination.
 The cold stores were extremely poorly maintained. Not only were they overloaded, but their
doors, floors and ceilings were also damaged.
 Low quality and obsolete equipment was used. It did not reach the required temperature, as stated
in the HACCP plan, (-350C to -400C). Also there was a presence of intense ammonia smell, which
had leaked from the cold storage equipment.
 Hygiene conditions were very poor. Waste water was not properly drained out. The ice used was
contaminated. The place was not free of insects and flies. The packaging and storage areas were
quite dirty too.
 The cold chain was clearly deficient with high temperatures – 6 0C for fresh fish and -12 0C for
frozen items.

Steps taken by the Government and departments:

As a result of this ban the competent department assured that a program will be launched to upgrade and
improve the boats. Simultaneously other important things will be improved like weighing scales, crates
and installation of wash basins. The transportation was also promised to be improved and it was made
assure that ice supply is monitored and a freshness criterion is established. It was also stressed that proper
actions will be taken to avoid contamination at every stage of the supply chain and a proper disposal
system will be established.

As a first step, Karachi Fish Harbor was renovated with the help of Rs20million from the provincial and
the federal governments. Karachi Shipyard and Engineering Works Ltd was contracted to create model
boats that will be according to the international standards. Testing and research labs were created to
ensure that contamination is controlled and that random tests can be performed at every stage of the
chain. To ensure that all these steps are implemented to perfection regular training programs for the
fishermen, processors and government officials were done. Processing plants were given technical
assistance to help them come up to the expectation of the EU and other countries.

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The Government of Sindh allocated Rs558million to upgrade and improve the boats. This was done as
public private partnership; with 75% of the cost bared by the government while the remaining 25% by the
owner of the boats. In the first stage 218 big boats were improved and refurnished while 104 small boats
were provided with insulated storage boxes and ice flake machines.

SAFETY AND HAZARD STANDARDS:

Care and cleanliness
Cleanliness is important in order to prevent the loss of quality of the product due to unhygienic
conditions. The personnel working inside the storage should be trained and educated about the
cleanliness inside the store.

Protective Clothing
The clothing should consist of the following layers:

 Inner layer: regulate the skin climate and provide insulation. This layer should also be
discounted for the evaporation and perspiration
 Middle layer: insulated and permeable for perspiration vapors.

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  Outer layer: should be watertight and winded. Adjustable at the neck and wrist.
The workers should also wear head cover all the time.

Proper arrangement should be made in terms of installing firefighting equipment at appropriate places
and an emergency escape should also be constructed to the people working inside the store.

Smoking should never be allowed in and outside the store and safety instruction should be made visible
at frequent visit places.

TRANSPORTATION OF IDEAL FISH:

Fish should be transported in a vehicle which is insulated and have refrigeration equipment able to
maintain the inside temperature around – 20 degree centigrade. Before loading the vehicle should be
pre cooled to the desired temperature. The platting of the product inside the vehicle affects the
temperature and so great care should be taken for doing it right.

Right palleting for transport

The figure above show that the palleting should be arranged and have sufficient space in between so
that the cold air is blown through all the products.

PACKAGING OF THE FISH:

The packing material ensures that the quality if fish remains constant and it
protects the products from any outside damage.

The fish could have as much as three packaging layers which are discussed as under:

Primary Packaging: it’s the packaging which is in contact with the fish.
The most preferable choice is Plastic wrapped around the product.

Secondary Packaging: it’s the carton which holds the primary

packages. It is usually made from carton.

Tertiary Packaging: It is used to store the multiple secondary packaging. The main purpose is to
make the handling easy.

Conclusion:

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It is quite evident that the supply chain in Pakistan has to do a lot in order to be on track according to
the international regulations and standards. The lack of planning, training and commitment has resulted
in depleting habitat and has affected the sustainability of the supply. Other factors like pollution, over
fishing and unorganized upstream sector have resulted in a considerable decrease in the landing volume
of the catch.

Sea food is a perishable commodity and in order to prevent it from decaying and contamination, the
catch has to be kept under ice. This way the bacterial reaction and decaying process slows down making
the fish fresh and healthy for consumption. Unfortunately the cold chain practices in Pakistan are not
according to the world standards. Although fish is kept in ice when it is caught but this facility is only
available with the medium and large boats and not with the smaller boats. Not only that the seafood has
to be kept in ice at all stages of the food chain to avoid contamination but this isn’t practiced in Pakistan.
As soon as the fish lands on the harbor the temperature abuse starts as it is removed from the ice and
placed on the floor. In auction area as well the fish is kept with little or no ice and the same practice is
done in transportation making the seafood unhealthy for human consumption.

SUGGESTED FURTHER WORK:

It our research we have tried our level best to gather the best quality data with latest update. The fact
that the fish spoilage of the fish is an irreversible process , and once spoils the fish is of no use if we
consider the strict EU standards. It is suggested further studies on the fishing practices should be done
together with the evaluation of government policies in this industry.

As the downstream sector is organized, proper measures are taken to ensure that the fish and other
seafood items are treated according to the international regulations and standards. But the upstream as
discussed above is a major concern for the industry. All these upstream activities plus lack of “bull-whip”
have resulted in the EU ban which was placed in 2007 and is still imposed. Although Pakistan has
managed to find new markets after the ban which has resulted in the increase in exports but the EU
market is still very important for the survival of the industry. EU is the only market for the Pakistani Kiddi
shrimps and some other seafood, and this ban has been affecting that area negatively.

Pakistan’s Marine and Fisheries Department and other related departments together with the Provincial
and Federal government has taken steps in order to save the industry from further bans and also to
help the industry cope with the requirements of the EU so that the ban can be removed. The efforts
include setting up labs, upgrading boats, training the fishermen and related personnel etc. All these
steps are a major leap forward, but we think more is to be done.

The fish spoils quickly if not taken care of effectively, the effect of temperature is quick significant in this
regard, and so the method of freezing , types of freezers used for this purpose should be addressed with
great thought and research. And since a great deal of investment is needed for these things , we have
recommended that the concepts of standards and specifications we learn in supply chain should be
applied to minimize the risk and get the right equipment.

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The processes and procedures after installing all the equipments , to maintain the environment is also as
important as the equipment itself. E.g transportation and packaging can play a pivotal role in keeping
the product fresh and safe.

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