Introduction

The importance of aquaculture as a protein source for human consumption is increasingly recognized, but with it comes a growing concern about antibiotic residues in cultured fish and shrimp. To mitigate the potential risk of diseases, fish farmers often use antimicrobial agents during production. However, the misuse, overuse, and inadequate withdrawal periods of these agents can result in the harvested products containing certain chemicals above the maximum residue levels (MRL) allowed. These products pose a health risk to consumers and are not permitted on the market, particularly in the European Union (EU) including the UK, which still follows EU regulations in this regard even after BREXIT. This results in disposal of the products, contributing to food loss and waste (FLW), and a loss in economic value for the producers.

The main factors contributing to food safety concerns among cohabiting species are environmental chemical contaminants, food safety, and traceability. Failure to comply with these standards often results in market rejection, especially in EU countries. For instance, pesticide residues can still be detected in farmed fish, which may originate from underground water sources used for aquaculture. Additionally, certain farmed fish have been found to contain high levels of contaminants like dioxins due to the use of contaminated aquaculture feeds.Top of Form

The primary chemical hazards of concern in farmed seafood are intentionally added chemicals, such as veterinary drugs used in aquaculture production, and unintentional contaminants, such as persistent environmental contaminants that may be present in the production areas. While certain marine fish may contain naturally occurring toxins, these toxins are generally not hazards of concern in the predominant species used in aquaculture. Nonetheless, some farmed fish are intrinsically susceptible to contamination with these naturally occurring toxins.

The Codex Alimentarius Commission provides information on the permitted levels or maximum residue levels (MRL) of various veterinary drugs and other substances. These standards are internationally recognized and aim to protect the health of consumers and ensure fair practices in the food trade. The Commission is a joint initiative of the Food and Agriculture Organization (FAO) and the World Health Organization (WHO), and its standards are based on scientific research and risk assessments. The MRLs set by Codex Alimentarius Commission are used by regulatory authorities worldwide as a reference for monitoring food safety and ensuring compliance with international trade standards.

The Government of Pakistan has recognized the problems related to the use of antimicrobials, contaminated feed, and pesticide residue in water, which can result in high levels of contaminants in harvested fish. This can ultimately lead to food safety concerns and the rejection of harvested products, especially in potential export markets such as the EU countries. The government is fully aware that the rejected product represents a significant loss, as it is usually destroyed. Therefore, efforts are being made to promote the responsible use of these chemicals and to ensure that fish farmers comply with the established safety standards to avoid the rejection of their products in the market.

The Government of Pakistan is committed to ensuring the safety of seafood for both domestic and overseas markets. To achieve this goal, the National Residue Control Plan (NRCP) for Aquaculture products has been formulated. This plan aims to monitor the presence of residues of veterinary medicinal products (VMPs), including antibacterial and other veterinary/aquaculture medicinal substances, as well as environmental contaminants such as organochlorine compounds, pesticides, PCBs, dioxins/furans & dioxin-like PCBs, heavy metals, anti-helminthics, growth promoters, and substances like dyes and aflatoxins. By monitoring the presence of these contaminants, the government can ensure that aquaculture products comply with safety standards and are fit for consumption.

Scope and Implementation of NRCP

All aquaculture farms, processing establishments, feed-mills and hatcheries linked to and / or intended for export-oriented production of aquaculture products and the testing and certifying laboratories are covered under the NRCP, to ensure an overall monitoring of the aquaculture products at different stages of production to guarantee safe products from farm to table.

Under the provisions of the Pakistan Fish Inspection and Quality Control Act, 1997, and the rules made thereunder, the Marine Fisheries Department (MFD) of the Federal Ministry of Maritime Affairs (formerly known as the Ministry of Ports and Shipping) is vested with the power to regulate the export of all seafood, including aquaculture products. The MFD is Pakistan’s competent authority and has offices in Karachi, Gwadar, and Peshawar. Along with its current regulatory role for the export of captured marine fisheries products, the MFD is also responsible for regulating aquaculture products. In this capacity, it is responsible for controlling the maximum limits of residues in fish and shrimp products destined for export. However, the authority may need to strengthen its regulatory staff, traceability system, and inspection services through legislation and financial support. In coordination with Provincial Fisheries Departments and the Fisheries Development Board (FDB), a system is being established to implement the National Residue Control Plan (NRCP) effectively.

The proposed plan includes the following measures:

1. The Marine Fisheries Department will register fish farms, hatcheries, feed mills, and processing plants through Provincial Fisheries Departments.
2. Notified labs will collect samples from these registered facilities for testing. Initially two labs will be notified, one for KP and Punjab, and one for Sindh and Balochistan.
3. The Fisheries Development Board will coordinate among public and private sector entities to help them meet compliance requirements and enable export out of Pakistan. They will also assist with registration and re-registration with the Marine Fisheries Department, as well as developing a traceability system and other necessary documentation for export.
4. Farmers, hatchery operators, and feed millers will establish an internal control and check system to implement Good Aquaculture Practices (GAP), Good Manufacturing Practices (GMP), and farm biosecurity systems to ensure compliance with regulations.

Enrollment of aquaculture farms

The enrollment of aquaculture farms is an important step in ensuring the safety of seafood products. The Marine Fisheries Department (MFD) and Provincial Fisheries Departments will be the registering authorities for export and local production and supply, respectively.

1. To enroll in the program, aquaculture farms will need to comply with the rules made under the Pakistan Fish Inspection and Quality Control Act, 1997, and the National Residue Control Plan (NRCP). The NRCP is a plan developed to monitor and control the presence of residues of veterinary medicinal products, environmental contaminants, and other substances in aquaculture products.
2. The MFD, in collaboration with Provincial Fisheries Departments, will register farms for the export of farm-raised products, hatcheries for the supply of fish and shrimp seed, and feed mills for the supply of feed to target farms. Processing plants will also be registered for the processing of products for export. This registration process will ensure that all farms, hatcheries, feed mills, and processing plants meet the compliance requirements for export and have internal control and check systems in place to implement Good Aquaculture Practices (GAP), Good Manufacturing Practices (GMP), and farm biosecurity systems.

Proposed NRCP Laboratories

1. Fish Quality Control Laboratories (FQCL), Manawan Lahore
2. Marine Fisheries Department Karachi, Aquatic Diagnostic Research Centre (ADRC) 

Sampling Strategy

1. Shrimps: The number of samples are decided based on the aquaculture production. i.e., 1(one) sample per 100MT of production.
2. Finfishes: based on throughput in the approved export establishments (approved for export to EU) – at least one sample per every 100 M/T of export.
3. Feed samples: One sample per two registered feed-mills (50%).
4. Hatchery sample (seed/water): at least one sample from each hatchery under operation.

Collection and transportation of samples

Under the National Residue Monitoring and Control Plan, the sample collection and transportation process involve several steps to ensure that the collected samples are representative, accurately labeled, properly preserved, and transported in a way that minimizes any changes to the sample before it is analyzed.

The steps in the sample collection and transportation process include:

1. Identification of the sampling location: Sample will be collected from the selected certified farms under the NRCP program based on volume as defied under the NRCP plan.
2. Selection of sampling unit: A sampling unit is a defined portion of the product that is selected for analysis. The size of the sampling unit depends on the type of product, the level of contamination risk, and the analytical method.
3. Random sampling: The sampling unit is selected randomly to ensure that the sample is representative of the entire lot or batch.
4. Sample preparation: The sampling unit is properly prepared to ensure that the sample is homogeneous and can be analyzed accurately. The preparation methods may vary depending on the type of product being sampled.
5. Sample preservation: Samples are preserved using appropriate preservation methods to prevent any changes to the sample before it is analyzed.
6. Sample labeling: Each sample is labeled accurately and legibly with relevant information such as the date, time, location, sampling unit, and the name of the collector.
7. Sample transportation: The samples are transported to the laboratory in a timely manner using appropriate transportation methods such as insulated containers or refrigerated trucks to prevent any changes to the sample.
8. The samples are analyzed in a laboratory accredited by the Pakistan National Accreditation Council (PNAC) and notified by the MFD. The laboratory analyses include screening tests and confirmatory tests for various residues such as antibiotics, pesticides, and heavy metals. The results are used to determine compliance with maximum residue limits (MRLs) set by the Codex Alimentarius Commission and listed in the NRCP under implementation in Pakistan.

Measure to be taken in the event of infringement

In the event of infringement or non-compliance, the following measures will be taken:

1. The alert information, along with test results, will be communicated to the concerned field offices of MFD and provincial fisheries departments.
2. The MFD and provincial fisheries departments will carry out inspections at the facility.
3. If positive results are repeated, a show-cause notice will be issued to the facility.
4. Based on the reply received from the facility, appropriate action will be taken.
5. A monthly summary of the sample results will be prepared.
6. Farms that have been reported as positive will be subjected to more stringent checks and reported to FDB for assistance.
7. Follow-up actions will be taken by provincial fisheries departments to ensure that corrective measures have been implemented to address the identified issues.

Non-compliance with the National Residue Control Plan (NRCP) can have serious consequences, especially for the aquaculture industry and its potential export market. The government will act against the non-compliant farms, hatcheries, feed mills, and processing plants, and will cancel their registration and will not issue health and quality certificates. It is therefore crucial for all stakeholders to comply with the NRCP to ensure food safety of seafood products to maintain Pakistan’s reputation as a reliable supplier of seafood to the global market.

In conclusion, the Pakistan’s “National Residue Control Plan” for Aquaculture products has been formulated to ensure the safety of seafood for both domestic and overseas markets. The plan outlines a comprehensive strategy for monitoring the presence of residues of veterinary medicinal products, environmental contaminants, and other substances in aquaculture products, and outlines a system for sample collection, analysis, and reporting of results. With the active participation and coordination of Marine Fisheries Department, Provincial Fisheries Departments, and Fisheries Development Board, the plan can be effectively implemented, resulting in safer and higher-quality aquaculture products, ultimately benefiting both the consumers and the aquaculture industry in Pakistan.