Draft

Data collection Analysis of Small-scale Salt Iodization in Bangladesh

MI Contract No. 10-1521-UDDIN M-03

Prepared By
Dr. M. Burhan Uddin
Professor
Department of Food Technology & Rural Industries
BAU, Mymensingh

Micronutrient Initiative

July 2014
Table of Contents

Contents
Table of Contents...................................................................................................................................ii
Abbreviations........................................................................................................................................iii
1. Executive Summary............................................................................................................................1
A. Regulatory environment.............................................................................................................2
B. Business environment................................................................................................................3
C. Social/Cultural Environment –....................................................................................................3
D. Financing –..................................................................................................................................4
E. External Support –......................................................................................................................4
F. Production –...............................................................................................................................4
G. Trade..........................................................................................................................................5
H. Conclusions and recommendations............................................................................................5
2. Introduction........................................................................................................................................7
3. Salt processing in Bangladesh...........................................................................................................10
3.1 Solar salt...........................................................................................................................10
3.2 Iodization by Small-scale Salt Industries (Salt crushing mills)...........................................11
3.3 Classification of salt industries..........................................................................................13
4. Objective, activities and methodology of the study.........................................................................13
4.1 Objective:...............................................................................................................................13
4.2 Main activities:.......................................................................................................................13
4.2 Methodology....................................................................................................................14
5. Summary of observation, findings and discussions..........................................................................14
5.1. Regulatory environment...................................................................................................14
5.2 Business environment......................................................................................................16
5.3. Social/Cultural Environment............................................................................................18
5.4. Financing...........................................................................................................................18
5.5. External Support...............................................................................................................19
5.6. Production (focus on small-scale segment)......................................................................19
5.7. Trade.................................................................................................................................19
6. Conclusions and recommendations..................................................................................................20
Appendix- I - List of the respondents....................................................................................................22
Appendix 2 – Bangladesh Standard......................................................................................................25
Abbreviations
BSCIC Bangladesh Small and Cottage industries Corporation

BSTI Bangladesh Standard and Testing Institute

BUET Bangladesh University of Engineering and Technology

CIDD Control of Iodine Deficiency Disorders

GAIN Global Alliance for Improved Nutrition

GoB Government of Bangladesh

IDD Iodine Deficiency Disorders

IFST Institute of Food Science and Technology

INFS Institute of Nutrition and Food Science

IPHN Institute of Public Health Nutrition

MI Micronutrient Initiative

MoI Ministry of Industries

BITAC Bangladesh Industrial Technical Assistance Centre

SIP Salt Iodization Plant

RTK Rapid Testing Kit

1. Executive Summary
Bangladesh is one of the countries in the world most affected by iodine deficiency disorders (IDD). To
address the problem, in 1989 the Government of Bangladesh enacted the IDD Salt Law, the Iodine
Deficiency Diseases Prevention Act., 1989, stating mandatory iodization of all salt for human
consumption in the country, i.e. adopting the policy of Universal Salt Iodization (USI). The Law came
into effect in 1994 through a By-Law, stipulating a/o the iodine content in iodised salt at production
level (45-50ppm) and at retail/household level (min. 20ppm).

Household coverage of iodised salt increased from 20% in 1990 up to 84 % in 2005 (Third USI Survey).
However the share of adequately iodised salt remained static at 51-55% since 1996. This may be due
to the structure and quality of the major part of the private sector, both salt growers and iodised salt
producers. Most of the traditionally operating small growers, producing very poor quality crude salt
at a relatively high price and a major part of the many small salt produces with their rudimentary
processing facilities not being able to produce a good quality adequately iodised salt. Addressing this
situation, also threatening the long term future of the salt industry in the country, requires a
structured approach of exploring and investigating options to improve the situation.

Since external donors have per definition a finite role in supporting financially and technically the
activities of GoB and private sector to achieve the goal, a major objective of this consultancy was to
provide information to the Micronutrient Initiative in the small scale salt iodisation in Bangladesh
through conducting interviews on different data sources/ stakeholders like Small Scale Salt
Producers, government (could be different levels) and development partners.

The activities performed by the consultant to achieve the above stated objective were i) initial
meeting with the MI Country Director to get a detailed briefing about the consultancy and discussing
the time line and schedule of activities; ii) within three days of the above mentioned meeting, the
consultant submitted to the MI an outline of the approach and methodology for task completion; iii)
The outline would include: the proposed plan and an indicative timeline within the prescribed
schedule; iv) conducted the interviews with different data sources using a predestined questionnaire
with open ended questions ; v) Compilation of the data gathered as a result of the interviews and vi)
report preparation explaining/ detailing interviews’ findings in all seven thematic areas and
submitted to MI.

The structured questionnaire survey was conducted in:

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Salt Industry: Titanic Salt Industries, Sonargaon Salt Industries Limited, Molla Salt (Triple Refined)
Industry Ltd., Ali Salt Industries, Garibe Newaj Salt Industries, Surabi Salt Iodization Plant, Pubali Salt
Industries, M/S New Ouality Salt Industries in Narayangonj, Sama Salt Pakaging Industries in Dhaka,
M/S. Five Star Salt Trading, Arafat Salt Industry Limited, Confidence Salt Ltd., Dhiman Salt Industry,
Malik Salt Industry, (U-2), Teximco Iodised Salt Industry in Chittagong and Karim Salt Industry, M/s.
Allai Salt Crushing & Refinery Industries, J.K Salt Crushign Industies in Potya and Salt Association of
Bangladesh, Motijheel.
Government including research and academia: Bangladesh Standard and Testing Institution,
Tejgaon, Institute of Public Health, Mohakhali, Bangladesh, Industrial Technical Assistance Center,
Tejgaon, Bangladesh Small and Cottage Industries Corporation, Motijheel, Institute of Food Science
and Technology (BCSIR), Dhanmondi, Institute of Nutrition and Food Science, Dhaka University, and
Development partners: Global Alliance for Improved Nutrition, Gulshan, Micronutrient Initiative,
Gulshan. The consultant requested UNICEF and WFP for giving him time for the interview for this
purpose. The WFP responded saying that since they are not working with salt iodization program in
the country, the interview will not be useful. However the UNICEF representative could not afford us
time for interview due her busy schedule.

Through this purposive survey the consultant assessed the following:

A. Regulatory environment
Salt Iodization is Mandatory in Bangladesh. The Government of Bangladesh enacted the Iodine
Disease Prevention Act, 1989 (Act No. 10, of 1989) providing for compulsory iodisation of all edible
salt in the country and established a National Committee to monitor the program. Later the
Government framed a detail order under the Act, in 1994. A total ban on production and trade in
non-iodised salt for edible use imposed with effect from February 1, 1995. A regulatory monitoring
system has been developed to control the iodisation in salt industries in the country. There are
National level Salt Committee – Chaired by Secretary, M/O Health and Family Welfare, District
Level Salt Committee – Chaired by Deputy Commissioner and Upazila level Salt Committee -
Chaired by Upazila Nirbahi Officer for effective monitoring and controlling the iodisation. The
appointed inspectors BSCIC visiting the mills twice a month to check the production, packaging of
iodised salt, collection of samples and monitoring submission of reports by the millers. The official
also monitor the supply of Potassium Iodate to the millers having SIP. The overall report of analysis
iodised salt is maintained by the chemist. The submission of periodical report and returns to BSCIC,

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Dhaka office is mandatory. In addition, Mobile Court goes in action to assess the overall condition
of iodised salts at industry as well consumer levels. When the iodised salt producers violet the salt
law, the matter is discussed in the regional review meeting, warning notice is served to them for
rectification. If they fail to rectify, punishment imposed and the renewal of registration is
prohibited. The registration of 14 Small-scale Salt Industries cancelled last year (2013). The
consultant observes internal quality control protocol in limited number of the small scale iodised
salt industries. Though some SSI has iodine testing labs, these were found inoperative.

B. Business environment
Small-scale Salt Industries (SSIs) mainly structured in the land owned by families. The ownership
mostly is inherited from father/grand-father. Few owners have rented proprietorships. No
cooperative exists yet in small-scale salt industry. Once the small-scale salt industries in Bangladesh
shared the major portion of salt production (more than 50%) in the country. Now the SSI’s salt
production is gradually decreasing because these are unable to compete with the medium and
large scale industries in producing quality salts having adequate quantity of iodine. The recent
share (2013) of total salt supply from small mills 25%, medium mills 15% and large mills 60%. There
is a deficit production of 331,064 MT iodised in the country which is covered by non-iodised salt. It
may be noted that maximum quantity of non-iodised salt is processed by small-scale industries.
Mainly the poor people living in rural areas are the major consumer of the salt produced by SSI. It
may be noted that poor people living in urban areas are not consuming salt produced in SSI. The
iodised salt produced by SSI is cheaper than that of medium or large mills. The average price of SSI
salt at mill gate is Tk8.00/kg and that medium/ large mill is Tk22.50/kg. So the price difference
between iodised salt produced by small-scale and medium/large industries is about 64%.

There is association of salt producers at national and district levels. The millers are not satisfied
with activities of the association leaders. Most of the millers opined to the consultant that the
association is very week, ineffective and lacks in professionalism, have little idea to improve the salt
industries and not helpful for the salt industries. The SSI does not have any experience with
fortification of other food vehicles. There is no commonality of fortification of other foods with that
of salt industries.

C. Social/Cultural Environment –
The view of the Government is very much positive about the development and sustainability of SSI
in Bangladesh. Government is providing all out efforts to improve the condition of the SSI mills

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through BSCIC and other development partners. Even then the member of SSI and their production
is gradually decreasing and situation is becoming alarming day by day for the sustainability of these
industries. About 40,000 to 50,000 labourers are engaged in crude salt harvesting and more than
5000 employees working in salt production industries. If these industries fail to exist, good number
labourers will become unemployed, the consequences of which will not be good for the labour
market as well as the government. However, few respondents assume that the labourers
unemployed due to closure the SSI will be absorbed elsewhere and there will be no problem.

D. Financing –
The salt farming business is mainly finance by the rich farmers/land holders of the salt growing
areas. They also take loans from the banks. The equity fund though profitable, the salt growers
don’t enjoy it as they need to go a long bureaucratic channel. Few farmers have their own land for
cultivation of crude salt and others take lease of land from the government on nominal lease
money for different lease periods (1 to 5 years). Some influential persons take lease of government
lands for a period of 99 years and claim themselves as land owners. Poor salt farmers take sub-
lease from the land owners, sometimes taking bank loans. Farmers also pay a major share of their
production to the land owners as par contract. As the quality of salt deteriorates with the
fragmentation of land, the government may consider ways and means of insisting on the land
owners /lessees of larger pieces of land, to work the land for salt production without sub-leasing to
several persons.

E. External Support –
The plastic films, plastic bags, LDPE, HDPE, laminated foil and other packaging materials are
available in local market. The SSI may also import the packaging materials as and when needed.
The potassium iodate is imported by BSCIC and sold to the millers. One SIP unit per mill was
supplied by MI. The SSI gets technical assistance from MI and BITAC as and when required. The aid
agencies provide training for the employees of salt industries on overall salt processing, training on
salt testing methods and conduct analysis of salt samples in their labs. The aid agencies also
provide training module and training manuals in SSIs to assist in salt processing and analysis..

F. Production –
The consultant observed that the quality of crude salt used by SSI is not satisfactory. The crude salt
is highly contaminated with mud and other impurities (25 – 30%), contain high moistue, colour is
poor (even black), crystals of NaCl are small in size, crystals are immature and breaks when pinch
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and overall quality is poor. The crude salt is further washed (also double wash), dried, iodised and
packed in Small-scale Salt Industries. The SIP is used to iodize the salt using dozing system. The
efficiency of iodization depends on the regular flow of the salt through the hopper and well-
maintained nozzle delivering the spray. The MI representative cooperate the millers in operating
and maintaining iodizing process. Though selling of non-iodised salt is prohibited by law, about 15%
non-iodised salt is sold in the market. The poor people in rural areas are the buyer and consumer of
non-iodised salt. In urban area, even the poor people consume the iodised salt. The potassium
iodate required for salt iodisation is imported by BSCIC and sold to the salt millers receiving
advance payment. Potassium iodate is available in 1kg, 5kg and 5kgX 5 packages. The mill owners
receive the potassium iodate from BSCIC office (both from Head office and Zonal office) submitting
the payment vouchers. The existing price of potassium iodate : Tk. 4700/kg (US$60/kg).

G. Trade
The salt trading is open for all the producers. There is no fixed price for the salt and government is
not controlling the price. The price is going up and down depending on supply and demand. All
millers have fair market access for their produced salt. The millers are attracting the consumers
through advertisement and personal contact. Every mill has own marketing strategy and also
different prices fixed on competitive basis and targeted profit. But there is a demand for price
banding from the consumers of salts. The consumers prefer the salt produced in their own region.
They have common preference for the very fine grain, bright white colourand attractive packages.
The poor people in rural area prefer medium grain salt because of low price and less volume
requirement for cooking compared to the fine grain salt. The Small-scale Salt industries sell salt
directly to traders. Usually they process the salt after getting demand orders from the traders. The
salts are available in 500g and 1kg flexible packages and 50kg and 75kf plastic bags.Salt processed
by SSI is not exported from the country though there is export potential.

H. Conclusions and recommendations

 The SSI owners should be motivated to produce only adequately iodisd salt under proper
monitoring, adding right proportion of potassium iodate and packaging the salt with proper
labeling.
 The consumer should procure and consume only adequately iodised salt.
 The GoB should recognize the crude salt growing and small-scale salt processing as an
industrial effort and extend credit support to them to protect them from the exploitation of

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 the money lenders and middlemen for the sake of promotion of this activity of national
importance.
 The highly labour intensive washing process adopted in Bangladesh could be modernised by
installing series of three inclined screw-conveyor washeries with a batch type bottom-
discharging centrifuge.
 The GoB activities should be more focused on quality control in salt processing and
monitoring adequate iodisation supported by strict and effective law enforcement.
 To sustain production and supply of Bangladesh’ salt as basis of adequately iodised salt in an
open competitive market environment, GoB and private sector need to consider the
structural improvement of the production of crude salt and create conditions to better utilize
the available capacity of small-scale salt processors.
 Achieving the objective of sustainable optimal iodine nutrition through production and
supply of adequately iodised salt, affordable for all consumers requires the better technical
skills, utmost sincerity, changing mindset and attitude of the small-scale salt processors.
 The wholesalers and the retailers should deal in only adequately iodised salt and no loose
salt (unpack) should be available/sold in the market.
 Last but not the least, external donors and private sector should continue to support GoB
effort to improve the salt processing and iodisation by SSI to control the supply as well as
price of the iodised salt in the country.

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1. Introduction
Iodine is one of the essential elements for human survival; it is needed in only small amounts to
prevent deficiencies that can cause a variety of disorders. Goiter is often the only visible
manifestation of iodine deficiency. However, even without visible goiter, iodine deficiency in
pregnant women can still cause miscarriages, stillbirths and irreversible intellectual and motor
abnormalities in the body. Very severe iodine deficiency causes severe brain damage, often
combined with deafness, dwarfism and cretinism. Iodine deficiency is the most significant cause of
preventable brain damages and mental retardation.
In an endemic iodine deficient population, the intellectual quotient decreases by an average of about
13.5 points. Out of every 100 children born to iodine deficient mothers, three percent will become
cretins, 10% will suffer from severe mental retardation and 87% will present will mild intellectual
deficit. Iodine deficiency greatly reduces individual productivity and, consequently, has a negative
impact on socio-economic development. By ensuring that each person, especially women of child-
bearing age and young children, consumes an adequate amount of iodine, the irreversible
consequences of iodine deficiency disorders (IDD) can be prevented. The best, easiest and cheapest
way to meet the daily iodine requirements is to consume iodised salt.
Bangladesh is a riverine country. Heavy rain falls and floods in very year is a common feature for
Bangladesh. Due to heavy rain falls and floods many essential nutrient like iodine are washed away
from soil. Due to shortage of iodine in the soil, required Iodine contents is always absent in the food
grains and vegetables produced in the country causing iodine deficiency disorders for vast number of
Bangladeshi people.
In 1989 the Government of Bangladesh (GoB) formally embraced Universal Salt Iodization (USI) as
the safe, cost effective and sustainable strategy to ensure adequate iodine nutrition for the
population and so to prevent and eradicate iodine deficiency disorders (IDD), through enacting the
Protection Law of Disease Caused by Lack of Iodine also called “Act on the Control of Iodine
Deficiency Disorders (CIDD)”. The Law came into effect through a Government Gazette Notification,
describing how iodised salt should be packed, the registration of iodised salt factories, inspection and
the role of the Salt Committee.
The Law stipulates that all salt for human consumption must contain 45-50 ppm (parts per million)
iodine at time of the production, corresponding with a level of about 75-85 ppm Potassium Iodate
(KIO3), and not less than 20 ppm at the time of retail, to ensure a minimum of 15 ppm iodine at the

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household level. At the same time Bangladesh Standard and Testing Institute (BSTI) has developed
the country standard of keeping the range of iodine at 20 – 50 ppm.

Iodine deficiency is a problem of public health significance in Bangladesh as according to the National
Micronutrient Status Survey 2011 – 12 (NMSS 2011 – 12) 1 around 40% and 42.1% school age children
and Non Pregnant and Non Lactating (NPNL) women respectively suffer from iodine deficiency. The
same survey revealed that Bangladesh as a whole on the total population basis was iodine sufficient
according to median urinary iodine concentration, which was above the cut-off for defining the
deficiency (100 µg/l), The median urinary iodine concentration in the school age children and the
NPNL women were 145.7 µg/l and 122.6 µg/l respectively. The iodine deficiency in 2004-05 among
the school age children and NPNL women was around 39% and 38% respectively. Apparently it seems
there is an upward trend of iodine deficiency in 2012 compared with the 2004-05 data 2.

The third National IDD Survey undertaken in 2004-05 revealed that the total Goitre rate was 6%
among children and 12% among women. It also showed that while only 51% households were using
adequately iodised salt; 81% of them were using iodised salt; in 2011-12 NMS survey showed that
household consumption of adequately iodised salt (≥15 ppm) has slightly increased to 57.6% while
the use of iodised salt (≥5 ppm) has decreased to 80.3%. Urban coverage of adequately iodised salt is
76% but Iodine Deficiency is 39%.

Still 24.2% of households use “open or non-iodised salt” the proportion is higher in the rural areas
(29.2%).

In the low-technology setting of most developing countries, it is difficult to maintain accurate iodine
level in iodised salt. Potassium iodide is less stable than potassium iodate, as it can be oxidized to
elemental iodine by oxygen or other oxidizing agents, especially in the presence of impurities, such as
metal ions and moisture, which catalyze the reaction. At the same time Potassium iodate may be
reduced to the elemental iodine by a variety of reducing agents in the salt, such as ferrous ions.
Moisture is naturally present in the salt, or is absorbed from the air by hygroscopic impurities such as
magnesium chloride. The pH of the condensed moisture on the salt is very much influenced by the
type and quantity of impurities present and affects the stability of the iodine compound.

1
National Micronutrient Status Survey 2011-12, Conducted by Institute of Public Health Nutrition (IPHN), icddr,b, UNICEF,
Bangladesh and GAIN, January 2013
2
National Survey on Iodine deficiency Disorders and Universal Salt Iodization in
Bangladesh 2004-05 conducted by Dhaka University , Bangladesh Small and Cottage Industries Corporation (BSCIC), IPHN,
UNICEF, ICCIDD
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The salts are reaching to end users or consumers via salt industries/factories, wholesalers and
retailers from salt beds / ghonas (cluster of salt beds). The salt factories are situated in clustered way
in eight monitoring zones of Bangladesh and these zones are also distributed in scattered way. The
crude salts are washed, crushed, refined, iodised and packaged in the salt factories. Iodised salt
processors in Bangladesh adopt two approaches for marketing their edible salt. Usually, the medium
and small producers sell their product at the factory gate at whole sale price to agents from different
parts of the country and sometimes they received order directly from their known whole seller for
supplying iodised salt. The big producers use their own marketing chain as presented in the flow-
chart below:

Selling Centre/Depot
Factory Distributor Wholesaler

Retailer

End Consumer

Fig. Mode of distribution of Iodized salt (s) processed by large industry.

In case of traditional factories who manufacture washed and crushed salt, they have been in the
business for many years and have already developed their own networks. Some possess their own
transport, while others depend on those of the distributors. Modern larger companies those who
manufacture refined salt already have their own network, because many of them deal in many other
commodities. The consumers buy their salt from the retailer in ½ kg or 1 Kg packet based on their
monthly consumption. In the house usually they preserve it in airtight jars or packets in the kitchen.
It is assumed that it takes maximum 6 months from iodizing at factory to finally consume by its end
users.

In most developing countries like Bangladesh salt is sold in retail packet or in bulk. Packaging
materials include high and low density polyethylene and woven bags made of jute, or high density
polyethylene. The price of KIO 3 is a major concern for the salt millers. Different researches have
demonstrated that KIO3 is a stable compound. After mixing it with edible salt loss of iodine losses is
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minimum, several millers and other related stakeholders have suggested investigating the effect of
use of low doses of iodine instead of existing 45 – 50 ppm iodine at production level. In recent years
some large private millers have invested a huge amount of money in this sector to introduce new
technology for production of high grade refined salt laminated packaging etc. Furthermore, as per
existing salt law it appears millers are adding high amount of KIO 3 at production level despite the
WHO standard at maximum level of 40 ppm.

2. Salt processing in Bangladesh

3.1 Solar salt
Solar evaporated salt forms the bulk of the common salt produced in Bangladesh. It is estimated
(BSCIC) that an extent of about 51,000 acres of land is cultivated for salt in Chittagong and Cox’s
Bazaar districts. A major portion of this land (about 48,000 acres) is reported to be owned by about
5,000 to 6,000 persons. The remaining land is taken on lease from the government on a nominal
lease money of Tk. 350 per acre per year, with lease periods varying from 1 to 5 years, Some of the
persons said to “own” the lands have actually been holding government lands on a 99 year lease.
Together, all these persons are known as “land owners”; as distinct from “salt growers” who actually
produce salt. Although the Land Revenue department of the government might be having full details
of the tenure of the lands under salt manufacture, it is advisable that the BSCIC which is mainly
responsible for the development of salt industry in Bangladesh, also maintains such data on its books.
The land owners, in turn lease out the lands to a number of persons for salt manufacture. Such leases
last for the duration of the salt manufacturing season, which is about 5 months. The consideration for
the lease is collected by the land owner either in cash (i.e., and annual rental) or on the basis of
“share-croping” i.e., in place of lease money, the land owner extracts 50% of the salt produced by the
grower in the land.
Salt manufactured by solar evaporation in Bangladesh makes use, entirely, of sea-brine, whose
density is about 3° Brix. The preliminary operations commence around the middle of November and
the manufacturing season lasts up to the middle of May, unless there is an early onset of monsoon.
Sea brine is taken into the reservoirs by a foot-operated contraption called the “tonk” The following is
the write up (verbatim) prepared by the BSCIS describes the method of salt manufacture in
Bangladesh.
“Firstly, a field is divided in to the plot of 30 decimal. Then very plot is divided into further six. From
the 1st, the others are gradually lower. Each plot is dried up first after ploughing well. After drying the
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lands, saline water (salted water) from the sea are supplied there by pump. The 1 st, the 2nd, the 3rd
and 4th plot are called condenser. In these sections, the salinity of water is increased by the heat of
the sun. The 5th and the 6th plot are called semi-crystallizing and crystallizing section (bed)
respectively. These two sections are compacted by roller. The salinity of the water is brought up to
200 ppt by supplying water to increase the salinity of the water gradually from the 1 st to the 4th bed.
200 ppt saline water is supplied to the 5 th and then to the 6th bed. The 200 ppt saline water rises up to
270 ppt in the 5th and the 6th bed and forms Na Cl crystal and salt is collected from these beds”.
Sea brine is a mixture of several dissolved salts like Calcium Carbonate, Sodium Chloride, Calcium
Sulphate, Magnesium Chloride and Magnesium Sulphate, Sodium Bromide, Potassium Chloride etc.
Manufacture of salt by solar evaporation of sea brine involves separation of these salts by fractional
crystallization. As the aim is to separately precipitate and collect these salts in their purest form, the
salt works are to be constructed with a scientific lay out, maintaining a proper ratio between the
evaporating-cum-condensing areas and crystallizing areas. Such ratio depends on the initial density of
brine. It is however, observed that the salt producers of Bangladesh are unaware of the need and the
basis of scientific layout of salt works. Any given area is straightaway divided into six blocks and the
last two are called the semi-crystallizes and crystallizes; with the plot allotted to crystallizes being
sub-divided into smaller compartments.

3.2 Iodization by Small-scale Salt Industries (Salt crushing mills)

As already stated, the crude salt produced in Bangladesh by solar evaporation of seabrine is very
highly contaminated with mud. This salt, obviously, cannot be directly used for human consumption.
Consequently, a large number of washeries have been in existence in Bangladesh, where, the crude
salt is upgraded in quality by a laborious multiple washing system. These facilities are called the salt
crushing mills.
From the stores, the crude salt is fed into a hopper in to which concentrated brine is also pumped in
simultaneously. The slurry collects in shallow brick-masonry tank. After this initial wash, workers
scoop out the salt from the tank by bamboo baskets and feed another hopper. From the hopper, the
salt and a stream of brine flows down into what is called a “fenner”. The fenner is a horizontally
placed compartment, in which a rotating agitator fitted with baffles breaks down the salt and mud.
The slurry flows out into a second tank, from which the salt is scooped out and fed into a second
hopper linked to a fenner. The process is repeated with a third fenner before the salt receives a final
wash. After this cycle, called that first wash, the crude salt loses part of its insoluble impurities. This

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salt is dumped over bamboo matting laid over a chamber and allowed to lie in store during which
period the excess moisture drains out into the chamber. The salt is now better looking.
The above salt undergoes two more such cycle of washes before it is finally crushed by roller
crushers; once or twice, depending on the crystal size of the washed salt. After the third wash and
crushing, the salt is again dumped on a bamboo mat for draining for at least 12 hrs. After this, the salt
is taken to Salt Iodisation Plant for iodisation.
The finished product from the washery still contains 6% to 10% moisture, for it is neither sun-dried
nor machine dried. Secondly, as the brine used for washing the salt is not Magnesium-free, the salt is
contaminated with Magnesium.
The washed salt is iodised in the salt iodisation plants (SIP) and packed manually either in 75 kg HDPE
bags or in consumer packs of 1kg and 500g units. It is reported that while the villagers prefer to by
iodised salt in loose (packed in bulk bags), consumer packs are preferred in urban areas.

3.3 Classification of salt industries

3.3.1. Classification on the basis of production technology
 Vacuum evaporated salt mills
 Mechanical salt mills
 Traditional upgraded salt mills
 Traditional non-refined salt mills

3.3.2. Classification on the basis of production capacity

 Small-scale Salt Industry: Production capacity less than 4000MT per year (<20MT/D).
 Medium-scale Salt Industry: Production capacity 4000 to 10,000 MT per year

(20 – 50 MT/D).

 Large-scale Salt Industry: Production capacity greater than 10,000MT per year (>50 MT/D).

3. Objective, activities and methodology of the study

4.1 Objective:
 The objective of this consultancy is to provide information to the Micronutrient Initiative in
the small scale salt iodisation in Bangladesh through conducting interviews on different data
sources/ stakeholders like Small Scale Salt Producers, government (could be different levels)
and development partners.

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4.2 Main activities:
 Initial meeting with the MI Country Director and or USI program officer to get a detailed
briefing about the consultancy and discussing the time line and schedule of activities for
completion of this consultancy.
 Within three days of the above mentioned meeting, the consultant will submit to the MI an
outline of the approach and methodology for task completion. The outline would include:
the proposed plan and an indicative timeline within the prescribed schedule.
 Conducting the interviews with different data sources using a predestined questionnaire with
open ended questions keeping in mind to conduct 3 – 5 interviews from each of data source
(industries, development partners, GoB) with a total of around 15 interviews.
 Compilation of the data gathered as a result of the interviews.
 Writing the report explaining/ detailing interviews’ findings in all seven thematic areas.
 Conducting 3- 4 follow-up in-depth interview if at a later stage advised by the

4.2 Methodology
The structured questionnaire survey was conducted in Titanic Salt Industries, Sonargaon Salt
Industries Limited, Molla Salt (Triple Refined) Industry Ltd., Ali Salt Industries, Garibe Newaj Salt
Industries, Surabi Salt Iodization Plant, Pubali Salt Industries, M/S New Ouality Salt Industries in
Narayangonj, Sama Salt Pakaging Industries in Dhaka, M/S. Five Star Salt Trading, Arafat Salt Industry
Limited, Confidence Salt Ltd., Dhiman Salt Industry, Malik Salt Industry, (U-2), Teximco Iodised Salt
Industry in Chittagong and Karim Salt Industry, M/s. Allai Salt Crushing & Refinery Industries, J.K Salt
Crushign Industies in Potya, Bangladesh Standard and Testing Institution, Tejgaon, Institute of Public
Health, Mohakhali, Bangladesh, Industrial Technical Assistance Center, Tejgaon, Bangladesh Small
and Cottage Industries Corporation, Motijheel, Institute of Food Science and Technology (BCSIR),
Dhanmondi, Institute of Nutrition and Food Science, Dhaka University, Group of Alliance for
Improved Nutrition, Gulshan, Micronutrient Initiative, Gulshan and Salt Association of Bangladesh,
Motijheel.. The consultant requested UNICEF and WFP for giving him time for the interview for this
purpose. The WFP responded saying that since they are not working with salt iodization program in
the country, the interview will not be useful. However the UNICEF representative could not afford us
time for interview due her busy schedule.

Through this purposive survey the consultant assessed the regulatory Environment, business
Environment/Industry Structure, Social Cultural Environment, Financing, External support,

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Production (focus on small-scale segment) and trade of small-scale Salt industries in Bangladesh. The
consultant made in-depth discussions with relevant representatives of the salt industries,
development partners and government officials and recorded their interpretations, comments and
suggestions. The respondents were also requested to contact the consultant over phone if they feel
to provide any important information that they might have missed during the spontaneous interview.

4. Summary of observation, findings and discussions

5.1. Regulatory environment
Salt Iodization is Mandatory in Bangladesh. The Government of Bangladesh enacted the Iodine
Disease Prevention Act, 1989 (Act No. 10, of 1989) providing for compulsory iodisation of all edible
salt in the country and established a National Committee to monitor the program. Later the
Government framed a detail order under the Act, in 1994. A total ban on production and trade in
non-iodized salt for edible use imposed with effect from February 1, 1995. The salt producers require
License for salt production for which they need to apply using prescribed form “A” provided by CIDD
project. The other necessary documents that need to be attached with the application are
photocopies of the original document of the land and the National Identity Card, three passport
size photograph of the owner, layout of the plant, up-to-date Trade License, Memorandum of
certificate (if limited company), TIN certificate and list of equipment in the industry. These are the
common requirement for Small, Medium and Large Salt Industries without discrimination. The
requirements are very much fundamental and not difficult to fulfill by the small-scale produces.

A regulatory monitoring system has been developed to control the iodisation in salt industries in the
country. There are National level Salt Committee – Chaired by Secretary, M/O Health and Family
Welfare, District Level Salt Committee – Chaired by Deputy Commissioner and Upazila level Salt
Committee - Chaired by Upazila Nirbahi Officer for effective monitoring and controlling the
iodisation. The BSCIC has appointed 8 Monitoring and Quality Control Officers, 8 Extension Officers,
11 Inspectors, 8 Lab Assistants and one Chemist for regular monitoring and assessing the iodisation in
the salt industries. The inspectors visiting the mills twice a month to check the production, packaging
of iodised salt, collection of samples and monitoring submission of reports by the millers. The Lab
assistant analyzes the samples collected by the inspectors. The QCO survey the market prior to the
district committee meeting. They also monitor the supply of Potassium Iodate to the millers having
SIP. The overall report of analysis iodised salt is maintained by the chemist. The submission of
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periodical report and returns to BSCIC, Dhaka office is mandatory. In addition, Mobile Court goes in
action to assess the overall condition of iodised salts at industry as well consumer levels. When the
iodised salt producers violet the salt law, the matter is discussed in the regional review meeting,
warning notice is served to them for rectification. If they fail to rectify, punishment imposed and the
renewal of registration is prohibited. The registration of 14 Small-scale Salt Industries cancelled last
year (2013) due to failure to produce adequately iodised salt.

The USI program in Bangladesh is centralized. However, the monitoring system, renewal of license,
sale of potassium iodate has been decentralized. There are 8 zones having 7 offices in the country for
this purpose. There is a central lab in each zone for analysis of salt samples collected from the mills.
The more reliable titration method is used to assess iodine in iodised salt at factory (production)
level. The iodine testing solution which commonly termed as RTK checker, sometimes used at
consumer level for rapid detection of iodine. However the use of RTK, which is a qualitative test, has
been discouraged, because, producers may misuse it for testing the iodine at factory level. The WYD
checkers supplied by donor has been simplified by the MI experts using locally available less costly
chemicals and are in restricted use at consumer level. Medium and large Salt industries have better
labs to analysis the samples whereas most of the SSI lacking this facilities.

The consultant observes internal quality control protocol in limited number of the small scale iodised
salt industries. Where available this protocol includes buy/ensure good crude salt, follow standard
process procedure for production of iodised salt, qualified chemist/chemical lab exists, analyses
moisture and impurities in crude salt, remove mud regularly from the salt, observe physical quality of
(especially colour. grain size) crude and finished products, net screening and double washing the
crude salts, test iodine 3/4 times (one hr. interval) every day, reprocess/readjust the iodine if test
fails, keep samples from each batch of production for test, maintain records of test results and
validate the test results in BSCIC and other labs. The reality is that though some SSI has iodine
testing labs, these were found inoperative.

5.2 Business environment

Small-scale Salt Industries mainly structured in the land owned by families. The ownership mostly is
inherited from father/grand-father. Few owners have rented proprietorships. No cooperative exists
yet in small-scale salt industry. Once the small-scale salt industries in Bangladesh shared the major
portion of salt production ( more than 50%) in the country. Now the SSI’s salt production is gradually
decreasing because these are unable to compete with the medium and large scale industries in

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producing quality salts having adequate quantity of iodine. The recent share (2013) of total salt
supply from small mills 25%, medium mills 15% and large mills 60%. However, the production of salt
by the small mill sector is still bigger than that of medium mill sector. The trends of decreasing the
numbers of SSI s are given in table 1. The total annual production of iodised and non-iodised salt in
2013 is given in table 2.

Table 1. Trends of the SSI decrease with corresponding market share loss

Year No. SSI mills Market share %

2013 130 25.86
2012 136 31.09
2011 172 34.88
2010 178 43.48

Table 2. Total annual iodised and non-iodised salt production (Jan-Dec: 2013)

Type mills Nos. of Iodised salt Non-iodised salt Approximate Annual

Mills production production salt requirement
Small mills 130 121,280 MT
Medium mills 10 110,556 MT 658,520 MT 800,000 MT
Large mills 8 237,100 MT
Total production 468,936 MT 658,520 MT

It is evident from the table 2 that there is a deficit production of 331,064 MT iodised in the country
which is covered by non-iodised salt. It may be noted that maximum quantity of non-iodised salt is
processed by small-scale industries. Mainly the poor people living in rural areas are the major
consumer of the salt produced by SSI. It may be noted that poor people living in urban areas are not
consuming salt produced in SSI.

The iodised salt produced by SSI is cheaper than that of medium or large mills. The average price of
SSI salt at mill gate is Tk8.00/kg and that medium/ large mill is Tk22.50/kg. So the price difference
between iodised salt produced by small-scale and medium/large industries is about 64%.

There is no model in Bangladesh where the SSI works in association with others. No SSI sharing their
equipment, market channel with other business. In fact their marketing channel is not well

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developed and each mill is having their contract markets in different areas close to them. In other
words, the consumers of each small-scale mills produce are almost fixed.
The consultant discussed with the millers and asks their opinion about the establishment of SSI
forming cooperative societies. The opinion of the respondents is discouraging. Most of them believe
that running salt mills forming cooperative societies will be difficult and small scale iodised salt
production under cooperative societies will not be satisfactory.
There is association of salt producers at national and district levels. The millers are not satisfied with
activities of the association leaders. Most of the millers opined to the consultant that the association
is very week, ineffective and lacks in professionalism, have little idea to improve the salt industries
and not helpful for the salt industries. Leaders divided into two groups each having their own agenda
beyond the interest of the millers and active only before the election. They went to Court to solve
the disputes among them. Association needs to strengthen and leaders dedicated to serve the
purpose the millers.
The SSI does not have any experience with fortification of other food vehicles. There is no
commonality of fortification of other foods with that of salt industries. They are not only interested
but also not capable of doing this. Their mill environment, equipment, manpower and skill seems to
the consultant not appropriate to serve this purpose

5.3. Social/Cultural Environment

The view of the Government is very much positive about the development and sustainability of SSI in
Bangladesh. Government is providing all out efforts to improve the condition of the SSI mills through
BSCIC and other development partners. Even then the member of SSI and their production is
gradually decreasing and situation is becoming alarming day by day for the sustainability of these
industries. About 40,000 to 50,000 labourers are engaged in crude salt harvesting and more than
5000 employees working in salt production industries. If these industries fail to exist, good number
labourers will become unemployed, the consequences of which will not be good for the labour a
market as well as the government. However, few respondents assume that the labourers
unemployed due to closure the SSI will be absorbed elsewhere and there will be no problem.

5.4. Financing
The salt farming business is mainly finance by the rich farmers/land holders of the salt growing areas.
They also take loans from the banks. The equity fund though profitable, the salt growers don’t enjoy
it as they need to go a long bureaucratic channel.

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Few farmers have their own land for cultivation of crude salt and others take lease of land from the
government on nominal lease money for different lease periods (1 to 5 years). Some influential
persons take lease of government lands for a period of 99 years and claim themselves as land
owners. Poor salt farmers take sub-lease from the land owners, sometimes taking bank loans.
Farmers also pay a lion share of their production to the land owners as par contract.

The BSCIC has a total area of 47.13 hec. at Lamshikali (taken as lease from Government). The total
area owned by the farmers is 20,631 hec. for crude salt production. At Tek Naf, for instance, the area
666.94 hec. is owned by 71 persons i.e., an average of 9.31 hec. a person. But the land is leased out
as many as 282 persons, resulting in total fragmentation of the land. In fact, the smallest holding at
Tek Naf is said to be 0.16 hec. and the largest being 16.18 hec. As the quality of salt deteriorates with
the fragmentation of land, the government may consider ways and means of insisting on the land
owners /lessees of larger pieces of land, to work the land for salt production without sub-leasing to
several persons.

5.5. External Support

The plastic films, plastic bags, LDPE, HDPE, laminated foil and other packaging materials are available
in local market. The SSI may also import the packaging materials as and when needed. The potassium
iodate is imported by BSCIC and sold to the millers. One SIP unit per mill was supplied by UNICEF
through a grant from CIDA in early 1990’s which was later upgraded by MI. The SSI gets technical
assistance from MI and BITAC as and when required. The aid agencies provide training for the
employees of salt industries on overall salt processing, training on salt testing methods and conduct
analysis of salt samples in their labs. The aid agencies also provide training module and training
manuals in SSIs to assist in salt processing and analysis.

5.6. Production (focus on small-scale segment)

The consultant observed that the quality of crude salt used by SSI is not satisfactory. The crude salt is
highly contaminated with mud and other impurities (25 – 30%), contain high moistue, colour is poor
(even black), crystals of NaCl are small in size, crystals are immature and breaks when pinch and
overall quality is poor. The crude salt is further washed (also double wash), dried, iodised and packed
in Small-scale Salt Industries.
SIP is used to iodize the salt using dozing system. The efficiency of iodization depends on the regular
flow of the salt through the hopper and well-maintained nozzle delivering the spray. The MI
representative cooperate the millers in operating and maintaining iodizing process. Though selling of
non-iodised salt is prohibited by law, about 15% non-iodised salt is sold in the market. The poor

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people in rural areas are the buyer and consumer of non-iodised salt. In urban area, even the poor
people consume the iodised salt.
The salt is stored in the SSIs for a short period before sale. The small-scale industries sell the salt
directly to the traders. After receiving invoice/delivery order from the traders, the salt is processed
(washed, dried, iodised and packed) and delivered by their own transport (mainly truck) to the
traders.
The potassium iodate required for salt iodisation is imported by BSCIC and sold to the salt millers
receiving advance payment. Potassium iodate is available in 1kg, 5kg and 5kgX 5 packages. The mill
owners receive the potassium iodate from BSCIC office (both from Head office and Zonal office)
submitting the payment vouchers. The existing price of potassium iodate Tk. 4700/kg (US$60/kg).

5.7. Trade
The salt trading is open for all the producers. There is no fixed price for the salt and government is
not controlling the price. The price is going up and down depending on supply and demand. All
millers have fair market access for their produced salt. The millers are attracting the consumers
through advertisement and personal contact. Every mill has own marketing strategy and also
different prices fixed on competitive basis and targeted profit. But there is a demand for price
banding from the consumers of salts.
The consumers prefer the salt produced in their own region. They have common preference for very
fine grain, bright white colour and attractive packages.
The poor people in rural area prefer medium grain salt because of low price and less volume
requirement for cooking compared to the fine grain salt. The Small-scale Salt industries sell salt
directly to traders. Usually they process the salt after getting demand orders from the traders. The
salts are available in 500g and 1kg flexible packages and 50kg and 75kg plastic bags. Salt processed by
SSI is not exported from the country though there is export potential.

5. Conclusions and recommendations

 The SSI owners should be motivated to produce only adequately iodised salt under proper
monitoring, adding right proportion of potassium iodate and packaging the salt with proper
labeling.
 The consumer should procure and consume only adequately iodised salt.
 The GoB should recognize the crude salt growing and small-scale salt processing as an
industrial effort and extend credit support to them to protect them from the exploitation of
the money lenders and middlemen for the sake of promotion of this activity of national
importance.

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 The highly labour intensive washing process adopted in Bangladesh could be modernised by
installing series of three inclined screw-conveyor washeries with a batch type bottom-
discharging centrifuge.
 The GoB activities should be more focused on quality control in salt processing and
monitoring adequate iodisation supported by strict and effective law enforcement.
 To sustain production and supply of Bangladesh’ salt as basis of adequately iodised salt in an
open competitive market environment, GoB and private sector need to consider the
structural improvement of the production of crude salt and create conditions to better utilize
the available capacity of small-scale salt processors.
 Achieving the objective of sustainable optimal iodine nutrition through production and
supply of adequately iodised salt, affordable for all consumers requires the better technical
skills, utmost sincerity, changing mindset and attitude of the small-scale salt processors.
 The wholesalers and the retailers should deal in only adequately iodised salt and no loose
salt (unpack) should be available/sold in the market.
 Last but not the least, external donors and private sector should continue to support GoB
effort to improve the salt processing and iodisation by SSI to control the supply as well as
price of the iodised salt in the country.

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Appendix- I - List of the respondents
List of the respondents
1. Md. Asharafuddin
GM (Customs & VAT)
Titanic Salt Industries
Modanpur, Bandar
Narayangonj.
3. Md. Jahangir Masud (Rana)
Senior Chemist
Molla Salt (Triple Refined) Industry
Ltd.
Dharmagonj, Enayetnagar
Fatulla, Narayangonj.
5. Alhaj Kamal Dewan
Proprietor
Garibe Newaj Salt Industries
26, Chhoto Bagbanganj
Nitayganj, Narayangonj.
7. Eng. Niranjan Kumar Das
Factory Manager
Pubali Salt Industries
23 Shahsuja Raod, Netaiganj
Narayangonj.
9. Hazi Md. Akther Alam
Proprietor
M/S. Five Star Salt Trading
755, trand Road Majirgat, Chittagong
11. Md. Maruf Hossain
2. Mohammad Anowar Hossain
Factory Manager
Sonargaon Salt Industries Limited
Meghnaghat, Sonargaon,
Narayangonj.
4. Rafiqul Islam
Proprietor
Ali Salt Industries
20, Old Bank Road, (Fire Ghat)
Narayangonj.
6. Alhaj Md. Assaduzzaman (Kabir)
Marketing Manager
Surabi Salt Iodization Plant
Kutubpur, Pagla Bazar
Narayangonj.
8. Kamal Saha
Proprietor
M/S New Ouality Salt Industries
House # 36, Road # 52
B. Das Road, Narayangonj-1400
10. Md. Nazerul Haque
Director
Arafat Salt Industry Limited
&
Nur Oil & Food Products Ltd.
26, Strand Road, Chittagong
12. Saifuddin Mohammad (Sumon)
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 List of the respondents
General Manager (Plant Operations)
Confidence Salt Ltd.
Admin Resort, (2nd Floor)
110 CDA Avenue, Sholoshahar
Chittagong
13. Uttam Kumar Shil
Factory In-charge
Malik Salt Industry, (U-2)
2334 Rajakhali, Bishwa Road,
Chittagong
15. Mr. Saiful Islam
Managing Director
Sama Salt Pakaging Industries
56/1, Raj narayan Dhar Road
Chawk Bazar, Dhaka
17. Mr. Fazlul Hoque
Proprietor
M/s. Allai Salt Crushing & Refinery
Industries
Hoque Fisheries & Agrovat
Indrapole, Patiya, Chittagong
19. Prof. Aleya Mowlah, Ph.D
Director
Institute of Nutrition and Food
Science
University of Dhaka-1000
21. Engr. Md. Mohsin
Director
Bangladesh Industrial Technical
Dhiman Salt Industry
1364/3 Rajakhali Road, Chaktai
Chittagong
14. Nadim Ahmed
Director
Teximco Iodized Salt Industry
M.H. Building 15 Strand Road
Chittagong-4000
16. Biplob Kanti Day
Manager
Karim Salt Industry
1088, New Pak Building (1st Floor)
Haji Amir Ali Chowdhury Road, Amir
Market, Khatungonj, Chittagong
18. Md. Jashim Uddin
Chairman
Fancy Properties Limited
J.K Salt Crushign Industies
Akram Tower, (2nd Floor)
28/33 Nobab Siraj Uddowla Road
Anderkilla, Chittagonj-4000
20. Mr. Md. MofidulIslam
Deputy Director (Agriculture and Food)
Bangladesh Standard and Testing
Institution
116-A, Tejgaon Industrial Area
Dhaka - 1208.
22. Engr. Md. Golam Hannan
Zonal Coordinator-USI< Chittagong
Zone
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 List of the respondents
Assistance Centre (BITAC)
Ministry of Industries
Govt. of the People’s Republic of
Bangladesh
23. Engr. Md. Sarwar Hussain
Zonal Coordinator-USI,
Dhaka Zone, Dhaka.
25. Dr. Taherul Islam Khan
MBBS (Dhaka), Fellow,
(Reproductive Health) Thaliland
M.Phil, Ph.D (Nutrition), Dhaka
University
Program Manager (PM)
National Nutrition Services (NNS)
Directorate General of Health
Services
Ministry of Health & Family Welfare
Gov. of the People’s Republic of
Bangladesh
Apartment 102, House 06
Road 104, Gulshan 2
Dhaka-1212
24. Mr. Md. Aktheruzzaman
Director (Standard wing)
Bangladesh Standard and Testing
Institution
116-A, Tejgaon Industrial Area
Dhaka - 1208.
26. Mr. Ashek Mahfuz
Project Manager, Nutrition
GAIN - Global Alliance for Improved
Nutrition
Flat No. A-3 (3rd Floor)
Suvastu Asmi Nazeela Manson
House # NE (B), 2/1 Road #71
North Gulshan-2, Dhaka 1212,
E-mail: amahfuz@gainhealth.org
Cell No. +88 017 3303204
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 Appendix-II

Appendix 2 – Bangladesh Standard

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