By Patrick J. Wood
The main culprits currently seem to be SE Asian and Indian sub-continent producer countries, and the problem is directly a consequence of the way the industry is set up in that region. The industry is fragmented but that also means that change can be rapid. In these regions complete vertical integration in the supplier chain is not the norm – where it is and where supplemental long term third parties suppliers are used if processing facility lacks raw material, then incidence rates are low.
Vertically integrated companies also tend to have long term contracts with their customers/end users and spend more on implementing controls at the bequest of their more discerning clients. Antibiotics testing and updates every six months tend to be the norm. These businesses know the value of their products and their futures are not linked to market perceptions but to actually testing products and inputs along the supply chain. They also tend to use independent certification bodies that help make it harder, but not impossible to “cheat.”
That said, many farmers in the these regions, though, are small scale and not vertically integrated. They need to get their survivals up and costs down to get maximum benefits. Some feed manufacturers and intermediary distributors (who can adulterate primary products) and who service a local market, are not worried about downstream effects or what is happening in Europe or the USA six months later. They are after market share, and antibiotics plus word of mouth are powerful tools.
Antibiotic testing: a shared
Antibiotic testing by processors on each and every lot of shrimp would be a very costly exercise – especially from multiple smaller suppliers. Antibiotic testing time – which can be quite long - is also a factor as shrimp need to be processed. Farmers tend to get paid immediately for their products and so have no risks and tend to walk away happy. That leaves the export processor holding the baby because, basically, WYSIWYB (what you see is what you buy) from the farmer. BUT under HACCP each and every purchase (should be) logged into the received materials log (and volume consolidators need to breakdown their suppliers) so after the fact traceability should be “built in” to the supply chain. Some exporters may outsource peeling and primary processing but the same HACCP standards should be implemented.
This can only mean that the producers and exporters both or separately are (1) either in on the business or (2) are totally unaware of how antibiotics got into their products. A few bad apples also on the processing/exporter side might also be gaming the system as they offer lower prices on potentially adulterated products or knowingly use dodgy third party suppliers (precisely because they are cheaper) and then do a chance export. Only when tests are done on 100 % of shipments do they become more cautious. Short term traders looking for discount prices do not help.
So it is of some surprise that the source farmers of antibiotic shrimp found on US/EU borders are not named, shamed or suspended subject to investigation. It seems only the export facilities are – but does the buck stop there?
Importance of HACCP and
Some markets do not even undertake antibiotic testing on imports and shrimp failing entry into certain markets like US/EU/Japan can be re-routed back to other markets. While the exporter is black-listed or put under the microscope and so, hopefully can tighten up its act, business can continue. Loss is not total but reputation may be affected at least until passing through or conforming to all stages of coming out of the FDA/EU alerts.
So to re-iterate - a container that is detained for detected antibiotics surely should be able to be traced back to the exact aquaculture farmer where the product was purchased. It follows therefore that appropriate investigation can be carried out. That farmer should have logged details of feed suppliers and any husbandry carried out. BUT tracing back is curative and not preventative – it is wasteful and an added headache for all involved.
Regardless of independent certification organizations (that do not cover the majority of the industry) taking a HACCP type system back to aquaculture farmers whereby there are records and traceability possibilities should be mandatory for obtaining operating licenses from regulatory bodies. This should also cover feed and feed/suppliers. Those that do not comply do not get licenses, get fined or get sanctioned.
Preventive actions instead of corrective actions
A condition for exporting to USA/EU is the requirement of homologous organizations to undertake testing prior to shipping. Current food safety regulations do not include antibiotic testing, though, as mandatory. When product arrives in an importing country it is too late – which means the HACCP system failed. Again, all curative and not preventative.
Perhaps a preventative method would be for farmers to be obliged to send a small sample of their feed used (50g per lot perhaps) to a homologized regulatory body that can cross reference with feed companies, test feed and/or hold for future testing. Also regulatory bodies can do surprise visits to feed manufacturers and also obtain details of where antibiotics are moved within the country.
So whom does all this affect – well really only the export/processing facilities but also by association the exporting country reputation. Importers/distributors who have sales and replenishment orders can also be affected – especially if they have opened up lines of credit or otherwise financed a purchase. Shrimp farmers are not pulled over the hot coals. They have received their money and can sell to someone else. They can also wash their hands and say they did not know what exactly was in that feed or fertilizer or “pro-biotic” used.
Regulatory bodies’ and authorities’ role
Which brings around an argument about the regulatory bodies’ and the export authorities’ roles in all this and how they can pro-actively stop this. Definitely putting the fear of God up a farmer that their business will be closed down if there is any monkey business will have an affect.
But in the end it is down to implementing appropriate regulations, monitoring the whole supply chain, implementing a HACCP type system back upstream and covering all inputs.
Of course the gatekeepers are those National bodies authorizing the export and licencing the local operations, and exports should only be approved if testing is done to levels required in destination markets. Which may mean, currently, a similar escalation in after-the-fact testing to show willingness while combined with a preventative strategy.
Really this is a symptom of a fragmented industry that has grown faster than the (non-existent) rules and therefore is taking advantage.
The Case of Ecuador
Take the example of Ecuador. That country went through a similar phase and it was part of the evolution of the industry in that country. Pressure was on to increase production. Diseases hit. Antibiotics offered a way out but not 100 %. No regulation to address these issues, but markets pushed back also. Supply became less but prices increased. Cowboys meanwhile left the industry. Densities were lowered. Sustainability and balance resulted. Aquaculture producers realized that their very survival depended on having an open, transparent and (self) monitored system for their clients. Without that the industry could not carry on.
As in Ecuador, exporters in the Eastern Hemisphere need to work more with farmers and integrate them more into the export process. It is also the responsibility of exporters to educate and make suppliers understand the risks. They are stakeholders after all. This may mean better prices to farmers in exchange for more serious engagement and understanding of the risks to all. It may mean lower stocking densities for the same returns. This will throttle supply but increase prices as well. Shrimp farmers need to look at their long term survivals over short term gains.
There is also an aspect to be found in certain parts of the globe about trying to get away with as much as possible on many technical aspects in the seafood industry. While an aside from the direct antibiotic issue in shrimp it does reflect on the general delivery of an adulterated product below standard. Non conforming products-underweights, non uniformity, over glazing and gross weight issues as well as deformity percentages from these regions are much higher than from Latin America for example. This results in more time and money spent on checking, monitoring and testing – regardless of where in the supply chain. Rebate claims are often made on product quality. This is because while HACCP may be similar, certain processing techniques used in the Eastern hemisphere are not exactly the same as in the Western hemisphere with resultant perceived quality issues.
What all this points to is that all stakeholders at the country level need to get together and be guided on an implemented strategy. All are rowing in the same direction for the industry to mature correctly and be taken seriously. In marketing speak – the customer is always right and in the case of shrimp the gold rush is over.
Patrick Wood holds a B.Sc. in Soil Science and Oceanography from the University College of North Wales and an MBA in International Business and Strategy from the CASS Business School in London. He has been involved in the international shrimp industry since the early 1980’s, with experience in hatcheries, farming operations, processing, marketing and distribution. He currently works at iRaishrimp S.L.
Note: The views expressed in the Perspective and Opinion column do not necessarily reflect those of the staff or Publisher of Aquaculture Magazine. They are presented as food for thought and to promote the advancement of the industry. Please contact us if you have a viewpoint you would like to share.