Concerns about the health and safety of consumers are the driving force for the enforcement of traceability systems for aquaculture products by importing countries such as the USA and EU. Thailand is one of the largest exporters of aquaculture and fisheries products, and has responded to these food safety concerns over the entire chain of production. The Thai Department of Fisheries (DOF) is the competent authority for inspection and certification of all fish and fishery products and requires processing plants to implement GMP and HACCP in their production.
The requirements also include establishing a coding system for product recall purposes. Since the detection by the EU of antibiotics and other prohibited chemical treatments and contaminants in frozen shrimp from several Asian countries, this has had a significant effect on food safety control in Thailand. Controls on the use of prohibited substances were extended to farm, feed production, fishery imports, and processing and finished product levels.
The strategy of the DOF in order to improve food safety related to shrimp production is the “Farm-to-Table” approach. The Code of Conduct (CoC) program for the marine shrimp industry, which began in 1998, emphasises traceability from retailers or consumers to the farm as a means of ensuring that products are safe and of good quality, and are produced under environmentally friendly and industrially sustainable conditions.
DOF has developed fundamental guidelines - Good Aquaculture Practices (GAP) - for hygienic shrimp production, which are easy to practice by farmers and can be used as a basis for further development of the CoC. The similarity between CoC and GAP lies in the record keeping process which covers farms, hatcheries, feed and chemicals used, control processes, feeding, health status, supplies, buyers and distributors.
Traceability means “the ability to follow the movement of a food through specified stage(s) of production, processing and distribution” (The Codex Alimentarius Commission, 2004). Traceability is used as a tool to deal with issues or problems associated with food safety and quality assurance, preventing risk in the business and improving consumer trust.
DOF introduced Movement Documents (MD) as a paper-based tool to accomplish traceability of the control and monitoring programme on the use of drugs and other chemical agents. Since 2002, the use of MD has enabled fishery commodities derived from aquaculture to be traced back to their origin. In 2005, with assistance from the French Government, DOF developed a computerised traceability system known as “Traceshrimp” to provide a reliable traceability management tool not only for Thai stakeholders in shrimp aquaculture but also for the local and foreign shrimp buyers to track back all the way to production and broodstock origin.
DOF is still in the process of perfecting its traceability system by implementing the paper-based Aquatic Animal Purchasing Document (APD) and computerised APD (E-APD) application after the enforcement of the Royal Ordinance on Fisheries B.E. 2558 (2015). Nevertheless, implementation of APD or E-APD enables the tracing back of fishery commodities derived from aquaculture to the origin only. The traceability system particularly, for feed and feed ingredients is a part of the Animal Feed Quality Control Act B.E 2558 (2015). DOF (through its Aquatic Animal Feed Research and Development Division) has been responsible for aquatic feed quality control since 1992 and requires the feed manufacturers to implement GMP and HACCP system in their production so that this can be traced back to the feed ingredient supplies. However, there is no obviously enforcement on tracking of feed ingredients through aquaculture farm until the aquaculture production.
According to the implementation of GMP by Thai feed manufacturers, the feed mill must record information at least three stages as follows:
- Reception of raw materials: the feed mill shall identify the supplier and identify the received raw materials.
- Aquaculture Feed Production: the feed mill shall specify which raw materials are being used and each produced unit is assigned a unique ID which must contain information compliance with the Animal Feed Quality Control Act B.E. 2558 (2015). Unique identification of traceable completed feed produced in Thailand usually occurred at the packaging label as “Lot number” for each batch of the feed production. Lot Number of completed feed are designed by individual company which related to useful information e.g. feed name, feed brand, pellet size, date of manufactured, feed formulation code, packaging number, packing time, etc. The packing time is the key for tracing backward to the previous process such as pelleting time, drying time, conditioning time, ingredient mixing time and mixer number, ingredient grinder or ingredient intake number then through the raw material information.
- Delivery: the feed mill shall record which completed feeds go to which customers e.g. feed sellers (both whole seller and retailer), famers, etc.
Feed manufacturers licensed by DOF are required to implement the GMP system despite the Feed Quality Control Act enforcement.
At aquaculture sites or farms, DOF requires farmers to submit a Movement Document (MD) or an Aquatic Animal Purchasing Document-Aquaculture (APD) or electronic-APD. DOF requires fish processors to establish a coding system for traceability purpose. The system must be able to trace back from finished products to the farm of origin, harvesting date and harvesting pond. The code must be printed on each package. Records on traceability must be made available to DOF during plant inspection or audit. During plant inspection, DOF inspectors will check on the system efficiency by tracing from a randomly selected sample to its origin. MD/APD/E-APD has been found to be a very useful tool for traceability.
Although feed and feed ingredients related to aquaculture products can already be tracked by MD/APD/E-APD, there is still a lack of an easy-to-follow approach to associate feed and feed ingredients with harvested aquaculture products. The seafood association in cooperation with the feed manufacturers and finfish and shrimp farmers association has launched a “feed information form” for farmers to record information about the feed used in each farm. The feed information form must be filled with the details as follows:
- Farm Registration No.
- Pond no.
- Farm name.
- Movement Document/Aquatic Animal Purchasing Document No.
- Date of feed received.
- Feed manufacturer.
- Feed brand.
- Feed type/feed no.
- Feed lot number.
Although utilisation of MD/APD/E-APD is enforced by DOF, and the feed information form is filled in voluntarily, there have been problems encountered in the implementation of this traceability system. The following are some of the shortcomings identified:
- Lack of resources: It is not an easy task to change the habits of farmers where record keeping used to be outside their interest and can add more cost to maintain records for their products.
- Lack of awareness: Lack of knowledge about the benefits and advantages of having a traceability system.
However, traceability is becoming the norm and cannot be avoided in the supply chain. Close collaboration between the government and private sector will help to develop a traceability system that is acceptable and meets the requirements of international trading partners.
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