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INDUSTRY ASSESSMENT – PAKISTAN Philip Randall and Prof. Faqir Anjum
(August – September 2014)
STUDY COMMISSIONED BY
GLOBAL ALLIANCE FOR IMPROVED NUTRITION PAKISTAN
Final 291214 – Wheat and Oil Industry Pakistan Page 1 of 80
Table of Contents Acknowledgements ......................................................................................................................... 5
Acronyms ......................................................................................................................................... 6
Background ...................................................................................................................................... 7
Overview of Assessment ................................................................................................................. 8
General ........................................................................................................................................ 8
Specific ......................................................................................................................................... 8
Methodology ................................................................................................................................... 9
Training .......................................................................................................................................... 10
Table 1 – Local Investigation team ............................................................................................ 10
Results ........................................................................................................................................... 10
Wheat ........................................................................................................................................ 10
Figure 1 – Punjab Mills .............................................................................................................. 11
Figure 2 - Balochistan Mills ........................................................................................................ 11
Figure 3 – KPK Mills ................................................................................................................... 12
Figure 4 – Sindh Mills ................................................................................................................ 13
Membership discepancies ..................................................................................................... 13
Oil and Vanaspati/Banaspati ..................................................................................................... 13
Figure 5 – Punjab Refineries ...................................................................................................... 14
Figure 6 - Balochistan Refineries ............................................................................................... 14
Figure 7 – KPK Refineries ........................................................................................................... 15
Figure 8 – Sindh Refineries ........................................................................................................ 16
Production and Consumption – Wheat Flour and Vegetable oils ................................................. 16
Table 2 – Food Balance Sheet 2011 ........................................................................................... 17
Wheat Consumption Variability ................................................................................................ 18
Table 3 – Imports and Exports of wheat and wheat flour ......................................................... 18
Table 4 – Food Balance Sheet Wheat ........................................................................................ 18
‘Ghee’ .................................................................................................................................... 19
Stakeholder Inputs ........................................................................................................................ 19
Table 5 – Synopsis of Stakeholder Inputs .................................................................................. 20
Industry Assessment Problems ..................................................................................................... 21
Wheat Industry Assessment .......................................................................................................... 22
Final 291214 – Wheat and Oil Industry Pakistan Page 2 of 80
Table 6 – Summary of local team mill visits .............................................................................. 24
Oil Industry Assessment ................................................................................................................ 25
Technical Capacity ......................................................................................................................... 27
Wheat ........................................................................................................................................ 27
Oil .............................................................................................................................................. 27
Human Resource Requirements ................................................................................................ 28
QA/QC Protocols ........................................................................................................................... 29
Wheat ........................................................................................................................................ 29
Oil .............................................................................................................................................. 29
Wheat and Oil ............................................................................................................................ 30
Requirement .............................................................................................................................. 30
Production – Installed and Actual ................................................................................................. 31
Premix Requirements .................................................................................................................... 31
WHO Recommendations ....................................................................................................... 32
Equipment Requirements ............................................................................................................. 33
Synopsis ..................................................................................................................................... 33
Requirements ............................................................................................................................ 33
Small Scale Processors ................................................................................................................... 34
Vitamin A Fortification Compliance and Oil Quality ...................................................................... 36
Table 7 - Punjab Pure Food Rules 2011 – Fortification Requirement ....................................... 37
Previous Studies .................................................................................................................... 37
Table 8 – Analytical results – market samples; oil and ghee ..................................................... 38
Iron and Phytic acid levels ............................................................................................................. 40
Table 9 – Mean values and Z stat for grain by total, mill type and region ................................ 41
Table 10 – Mean values and Z stat for Atta by total, mill type and region ............................... 42
Table 11 – Mean values and Z stat for Maida by total, mill type and region ............................ 43
Graph 1 – Intrinsic iron variation in Grain ................................................................................. 44
Graph 2 – Intrinsic iron variation in Atta Flour .......................................................................... 45
Graph 3 – Intrinsic iron variation in Miada Flour ...................................................................... 45
Wheat Price Commentary ............................................................................................................. 46
Zinc ................................................................................................................................................ 46
Conclusions and Recommendations ............................................................................................. 47
Final 291214 – Wheat and Oil Industry Pakistan Page 3 of 80
General ...................................................................................................................................... 47
Wheat ........................................................................................................................................ 47
Recommendation 1 ................................................................................................................... 47
Recommendation 2 ................................................................................................................... 47
Recommendation 3 ................................................................................................................... 47
Recommendation 4 ................................................................................................................... 47
Recommendation 5 ................................................................................................................... 47
Recommendation 6 ................................................................................................................... 48
Oil .............................................................................................................................................. 48
Recommendation 1 ................................................................................................................... 48
Recommendation 2 ................................................................................................................... 49
Recommendation 3 ................................................................................................................... 49
Monitoring ................................................................................................................................. 49
Recommendation 1 ................................................................................................................... 49
Recommendation 2 ................................................................................................................... 49
Recommendation 3 ................................................................................................................... 49
Recommendation 4 ................................................................................................................... 49
Recommendation 5 ................................................................................................................... 49
Recommendation 6 ................................................................................................................... 49
Annex 1 A TOR International consultant ....................................................................................... 51
Wheat Flour Industry................................................................................................................. 51
Oil and Ghee Industry ................................................................................................................ 52
Annex 1 B TOR Local consultant .................................................................................................... 53
Annex 2A Wheat ............................................................................................................................ 55
Annex 2B Oil .................................................................................................................................. 60
Annex 3 – Stakeholder Inputs ....................................................................................................... 65
Pakistan Flour Millers Association (PFMA) – Punjab Zone ........................................................ 65
Pakistan Flour Millers Association – Sindh Circle ...................................................................... 66
Pakistan Vanaspati Manufacturers’ Association (PVMA) .......................................................... 67
Food Department – Punjab ....................................................................................................... 68
Food Department - Karachi ....................................................................................................... 70
Policy and Strategic Planning Unit (PSPU) – Lahore .................................................................. 70
Final 291214 – Wheat and Oil Industry Pakistan Page 4 of 80
Planning & Development Department (PND) – Government of Punjab ................................... 71
Nutrition Planning Commission NPC – Islamabad ..................................................................... 72
Pakistan Standards and Quality Control Authority (PSQCA) - Karachi ...................................... 73
Pakistan Standards and Quality Control Authority (PSQCA) – Lahore ...................................... 74
Standing Committee Commerce & Investment – Punjab Assembly ......................................... 74
Pakistan Council for Scientific and Industrial Research – PCSIR................................................ 74
METRO Superstore ........................................................................................................................ 75
Current Prices Consumer Groceries Pakistan ............................................................................ 75
Jamia Tur Rashaid ...................................................................................................................... 75
TechnoMight Engineers – Faisalabad ........................................................................................ 76
Annex 4 – Mean Squares Statistics ................................................................................................ 77
Final 291214 – Wheat and Oil Industry Pakistan Page 5 of 80
Acknowledgements Consultant Philip Randall and Prof. Faqir Anjum would like to express its gratitude to Wheat
Milling (Flour Mills) and Edible Oils and Fats Industry of Pakistan for provision of access to
Industry, products information and sampling to complete this assessment survey. We have also
genuine pleasure to thanks for overwhelming support of Pakistan Flour Mills Association (PFMA)
and Pakistan Vanaspati Manufacturers Association (PVMA) for their facilitation to reach out to
their mills.
We are highly indebted for the support of the Stakeholders from the National and Provincial
Governments including Ministry of National Health Services, Regulation and Coordination,
Planning Commission of Pakistan, Pakistan Standards and Quality Control Authority, Punjab
Food Department, Planning and Development Department of Punjab. We also acknowledge
profusely the contribution of Pakistan Council for Scientific Research (PCSIR) for sample analysis
of Wheat Flour (Atta, Maida, Wheat Grain, Oil and Ghee) collected from different regions of
Pakistan.
It is privileged to record the contribution of Institute of Home and Food Science, Government
College University, Faisalabad through the Vice Chancellor Prof. Zakir Hussain (PhD). We are
extremely thankful to the team of Government College, Faisalabad University who travelled
throughout the country for data collection.
Last but not least, we would like to thank especially GAIN team, Ms. Dora Panagides, Mr. David
Morgan, Mr. Munawar Hussain, Project Manager, Large Scale Food Fortification and Mr. Syed
Sajjad Imran, Country Manager for the extensive support and persistent help during the course
of assessment.
Final 291214 – Wheat and Oil Industry Pakistan Page 6 of 80
Acronyms APLAC Asia Pacific Laboratory Accreditation Cooperation EMS European Metrological Service
FAO United Nations Food and Agriculture Organisation FAQ Fair Average Quality FFA Free Fatty Acid(s)
g Gram GAIN Global Alliance for Improved Nutrition
HDI Human Development Index IEC International Electrotechnical Commission ILAC International Laboratory Accreditation Cooperation
ISO International Organisation for Standardisation IU International Units
Kg Kilogram Kg Kilogram (1000 g) MI Micronutrient Initiative
MRA Mutual Recognition Arrangement MT Metric ton (1000 Kg)
NGO Non-Governmental Organisation NNS National Nutrition Survey NPC Nutrition Planning Commission - Islamabad
PASSCO Pakistan Agricultural Storage and Services Cooperative PCSIR Pakistan Council for Scientific and Industrial Research
PFMA Pakistan Flour Millers Association – Punjab PNAC Pakistan National Accreditation Council
PND Planning and Development Department - Punjab PS Pakistan Standard PSPU Policy and Strategic Planning Unit (Lahore)
PSQCA Pakistan Standards Quality Control Authority PV Peroxide Value
PVMA Pakistan Vanaspati Mills Association RDI Recommended Daily Intake QMS Quality Management System
RBDO Refined Bleached Deodorised Oil RDI Recommended Daily Intake
Rs Rupee (Pakistan) SUN Stepping Up Nutrition TOR Terms of Reference
VSD Variable Speed Drive WFF Wheat Flour Fortification
WFP World Food program of the United Nations
Final 291214 – Wheat and Oil Industry Pakistan Page 7 of 80
Background Pakistan is the sixth biggest country in the world, with an estimated population of more than 180 million people. Ranking 141 out of 182 countries
in the Human Development Index (HDI), Pakistan is an impoverished, underdeveloped and disaster-prone country. The National Nutrition Survey 2011 indicates that stunting, wasting and micronutrient malnutrition are
endemic in Pakistan.
Results from the 2011 National Nutrition Survey (NNS) indicated little change over the last decade in terms of core maternal and childhood nutrition indicators. The survey showed that micronutrient deficiencies were
widespread in children, and specifically in children under 5 years of age (Anemia 61.9%, iron deficiency 43.8%, vitamin A deficiency 54%, zinc
deficiency 39.2% and vitamin D deficiency 40%), and amongst mothers (anemia 50.4%, Vitamin A deficiency 17.2%, Zinc deficiency 42.1%, Vitamin D deficiency 23.2%, Calcium deficiency 52.9%).
Over the recent years, the Government of Pakistan has demonstrated a
strong commitment to prioritize the fight against malnutrition. A multi-sectoral nutrition policy guidance notes has been prepared by all provinces under the umbrella of Planning and Development Department. Pakistan has
recently joined the SUN movement as well. In order to control the micronutrient malnutrition food fortification has been identified as main
strategy.
Wheat Flour Fortification (WFF) with iron and folic acid is an effective and
sustainable intervention to reduce the prevalence of iron deficiency anemia among the population. It is estimated that 50-55% of the population in the
country consumes commercially roller-milled flour on a daily basis. There are around 1200 flour mills in the country with geographic spread of 2/3rd in Punjab and remaining in other provinces and regions.
In order to combat Vitamin A dDeficiency the sustainable methods approach is fortification of edible oil and ghee which are considered appropriate
vehicles as these are widely consumed in Pakistan, with annual consumption estimated at 2,700 million kg with average of 15-16 Kg per person per year
(roughly 90% ghee, 10% oil). Legislation currently exists on mandating fortification of edible oil and ghee with vitamin A (33,000 IU per kg) and D (The original legislation goes back to 1933, and was revised and updated in
the Pure Food Rules of 1965 and then in 2000).
However, there are significant gaps that affect the fortification efforts in the country. In order to support fortification effort, it is important to undertake an in-depth assessment of the industry in the country which includes an
inventory and capacity of the flour/ edible oil & ghee mills, availability of equipment and technical capacity etc. GAIN will support this assessment to
guide future programming.
Final 291214 – Wheat and Oil Industry Pakistan Page 8 of 80
General and Specific tasks where provided in the TOR which is given in Annex 1
Overview of Assessment
General
To conduct a detailed assessment to determine industry equipment and premix requirements, recommend protocols that can be adopted within the
current manufacturing process that can ensure fortification requirements can be consistently fulfilled and determine the training requirement for
production personnel if applicable at each of the selected:
Flour mills
Chakki mills Oil refineries
Vanaspati/Banaspati producers
Generate evidence for level of Vitamin A and D in the oil and ghee available
in different parts of the country.
The Terms of References for the international and local consultant are
provided in Annex 1A and 1B respectively.
Specific
Develop a checklist and questionnaire and assessment methodology. Conduct meetings with Pakistan Flour Mills Association, Pakistan
Vanaspati Mills Association, Pakistan Standards and Quality Control
Authority, Food Department, Health Department, Punjab Food Authority, Planning Commission, development partners and any other
important stake holders to seek their inputs. Stratify industry based on the production and geography.
Visit all industry and meet with the designated production personnel and management staff. Estimated 7% of milling industry and 15% of oil industry.
Estimate the production capacity and actual production achieved by each of the producers and based on this provide projections for premix
requirements Based on the plant layout, design and capacity, develop a detailed
equipment list and/or process changes that would be required to
fortify at an appropriate quality. The specifications should be detailed enough to enable procurement of appropriate micro-feeders and/or
dosers. The consultant should also provide a list of potential suppliers of such equipment and estimated costs of process upgrades that are proposed.
Document production protocols in place at each of the manufacturing plants and provide recommendations of appropriate QA/QC protocols
Final 291214 – Wheat and Oil Industry Pakistan Page 9 of 80
that would have to be adopted to produce fortified products in accordance with National standards.
Observe technical capacity of production personnel and in consultation with plant managers provide an objective brief on extent and type of
training that would be beneficial/required. Identify wheat flour consumption pattern and variations among
different provinces, which could impact on required level of
fortification. Collect sample and provide analysis of level of Vitamin A in Oil and
Ghee from different sources and parts of country by having a representative sample.
Methodology Questionnaires (these where field tested by the lead consultants during the
early stages of the assessment) and mill/refinery stratification (based on size and locality) where developed. The questionnaires, as used by the local assessment teams, are provided in Annex 2A and 2B.
Mill data was obtained through the membership rolls of the Pakistan Flour
Millers Associations (PFMA) [Punjab 843, KPK, 153, Suindh 139 and Balochistan 36; total mills on membership rolls 1171] and from this list the spatial mapping was carried out by District, number of mills and the range of
installed capacity per day. Islamabad was dealt with as a separate entity as it is a Federal District in its own right (others are Provincial Districts).
A similar list of oil refineries (100 in total) was obtained through the Pakistan
Vanaspati Mills Association (PVMA). From this list the spatial mapping was
carried out by District, number of refineries and the range of installed
capacities (,000 MT per annum). Islamabad was dealt with as a separate
entity as it is a Federal District in its own right (others are Provincial
Districts.
From the supplied database a cross section of mills was suggested to the
Pakistan team for consideration based on spatial difficulties (logistics etc.).
The security situation, however, indicated that mill and refinery selection
would have to take into account the security situation first.
The target of 90 mills plus 48 Chakkis (both the stone mill and metal bladed
or China type) and 16 refineries plus 10 unregulated 1 refineries required that
local resources be used to visit the facilities. These resources were identified
and recruited from the Department of Food Science, Nutrition and
Economics, Government College University, Faisalabad, Pakistan (see Table 1
below).
1 It remains unclear what exactly is meant by ‘unregulated’
Final 291214 – Wheat and Oil Industry Pakistan Page 10 of 80
Training
A half day training course was run for the investigative team in which the
following was presented and discussed:
Why fortify
Fortification technologies for wheat flour and vegetable oil
Situations to watch for onsite that would indicate special attention
o Flow path of finished product
o Possible errors in the fortification process and/or placement of a
micro feeder
o How fortification was carried out at participating wheat mills
2008 – 2011
Refinery production – batch or continuous
Sampling protocols for wheat flour (on site) and vegetable oil (market
retail/sector)
The two questionnaires (Annex 2A wheat and Annex 2B Oil) and the
major task was using the questions as a guideline and understanding
the underlying purpose of the questions
The team were left with electronic copies of the training materials.
Prof Anjum identified target mills, Chakkis and oil refineries; and the
questionnaires were based on the interviews already carried out by the
consultants.
Table 1 – Local Investigation team
Team Areas
Dr.Ali Imran Faisalabad ,Lahore, Gujrwala
Dr.Frhan Saeed/ Dr.Tahir Sargodha, Dera Ismail khan, Sahiwal, Multan
Dr.Azmat Bhwalpur /DGk/,Sukhar
Mr. Afzaal Karachi, Hydeabad
Dr.Sajid Arshad Quetta
Dr.Nazir and Mr.Haroon Rawalpindi, Peshawar
Results
Wheat
Spatial mapping was carried out by District, number of mills and range of
installed capacities. Islamabad is dealt with as a separate entity and has 40 mills ranging from 40 to 360 MT per day installed capacity.
Final 291214 – Wheat and Oil Industry Pakistan Page 11 of 80
NOTE: The Food Department based in Rawalpindi advised they have on record 70 mills in Rawalpindi and 41 mills in Islamabad.
Provincial data is for Punjab (Figure 1) – which was further sub divided into
North, Central and South, Balochistan (Figure 2), KPK Figure 3 and Sindh
Figure 4
Figure 1 – Punjab Mills
Figure 2 - Balochistan Mills
Final 291214 – Wheat and Oil Industry Pakistan Page 12 of 80
Figure 3 – KPK Mills
Final 291214 – Wheat and Oil Industry Pakistan Page 13 of 80
Figure 4 – Sindh Mills
NOTE: The Chairman of the Sindh Flour Millers Association advised the
Association had 198 members mostly in the range 200 to 280 MT. This
number is significantly higher than the 139 the consultants had on their list
of millers in the Sindh region.
Membership discepancies
Differences in the number of mills throughout Pakistan were noted with no
clear reason as to why. Differences could have come about due to:
Registers not being updated in all of the sources i.e. PFMA not having
the latest version of the SFMA register (none of the registers had
dates).
If the market is over supplied then the liklihood of mills closing and/or
changing hands is high
Ghost mills (mills that exist but do not mill but sell on their quota
allocation, or mill only their quota allocation) are known to exist
Oil and Vanaspati/Banaspati
Spatial mapping was carried out by District, number of refineries and range
of installed capacities (,000 MT per annum). Islamabad was dealt with as a separate entity as it is a Federal District in its own right (others are Provincial
Districts) and has 4 refineries ranging from 28,000 to 45,000 MT per annum
Provincial data is for Punjab (Figure 5), Balochistan (Figure 6), KPK (Figure
7) and Sindh (Figure 8).
Final 291214 – Wheat and Oil Industry Pakistan Page 14 of 80
Figure 5 – Punjab Refineries
Figure 6 - Balochistan Refineries
Attock 2; 18-20
RYK 1; 44
Sialkot 2;
Faisalabad 7; 22-72
Lahore 12; 18-110
Gujranwala 4; 15-34
Jhang 2;
18
Bahawalpur 2; 45-54
Okara 1; 55
Sahiwal 1; 60 Muzaffargarh 1; 22
DGK 1; 18
Burewala 1; 36
Multan 5; 24-48
Quetta 2; 22-54
Final 291214 – Wheat and Oil Industry Pakistan Page 15 of 80
Figure 7 – KPK Refineries
DI Khan 1; 12
Peshawar 3; 43-65
Dargai 2, 22-36
Hattar 6; 18-82
Haripur 1; 55
Malakland 2; 44-72
Nowshera 1; 48
Final 291214 – Wheat and Oil Industry Pakistan Page 16 of 80
Figure 8 – Sindh Refineries
GAIN Pakistan were to be kept advised through all stages of the project and
this was carried out through three formal debriefs, daily meeting when
possible and almost daily telephone calls.
Production and Consumption – Wheat Flour and Vegetable oils As indicated below (Table 2) Pakistan has a high consumption of wheat and
vegetable oil products according to the United Nations Food and Agriculture
Organisation.
Wheat flour is not subject to mandatory fortification but is subject to
voluntary fortification parameters under Punjab Food Authority Act 2011 and
Pakistan Standard PS 4782: 2008
Vegetable oils have mixed fortification status:
Fortified when sold as an identified oil
Fortified when sold as part of a blend of oils
Fortified when sold as part of vegetable ghee
No fortification requirement
Final 291214 – Wheat and Oil Industry Pakistan Page 17 of 80
The primary vegetable oils are Palm oil, Cottonseed oil, Rapeseed (Canola)
oil and Sunflower oil and constitute >95% over total vegetable oil
consumption.
Table 2 – Food Balance Sheet 2011
Production Imports Food Use Kg/Yr/Capita
,000 MT
Wheat and products 25214 63 20050 114
Soybean Oil # 0 56 37 0.2
Groundnut Oil * # 23 0 23 0.1
Sunflower seed Oil 185 27 115 0.7
Rape and Mustard Oil ##
350 0 249 1.4
Cottonseed Oil * 420 0 356 2
Palm kernel Oil *** 10 10 0.1
Palm Oil # 2140 1296 7.4
Coconut Oil * 7 8 13 0.1
Sesame seed Oil * 6 0 6 0
Olive Oil * 1 1 0
Rice bran Oil ** 5 5 0
Maize Germ Oil 0 0 0
Oil crops Oil, Other 59 2 0 0
Vegetable Oils 1055 2244 2111 12
Source: FAOSTAT July 2014
* Not required to be fortified
** Unknown status – PS 1681:1985 refers to „Rice Bran (solvent extracted); presumably
refering to the oil
*** Not mentioned in Punjab Food Authority Act 2011 but does have a Pakistan Standard (PS
3404:2003)
# Fortified if used in Vanaspati/Banaspati, blended vegetable oil or sold separately.
## Members of the family Brasicaceae Rapeseed is a generic term and, in this case, is
typically (but necessarily entirely) referring to Canola. Mustard seed oil is not mentioned in
Punjab Food Authority Act 2011 but does have a Pakistan Standard (PS 25:2003)
Table 3 below indicates Pakistan has a checkered history on wheat and wheat
flour imports and exports but the trend towards increasingly being a net
exporter is apparent (the drought in 2008 created unusual imports) and from
Final 291214 – Wheat and Oil Industry Pakistan Page 18 of 80
Table 4 the average 2 consumption pattern is flat at around 250g per person
per day.
Wheat Consumption Variability
The 2011 NNS indicates there is some variability in wheat consumption in
different parts of Pakistan with 8.2.2 indicating that mean consumption of
mothers (only other group reported was infants) was 298 g/day with urban
consumers at 280 g/day and rural consumers at 306 g/day. Sindh Province
was highlighted as being “low” without any numerical value.
Divergent opinions were given on whether wheat flour products were moving
towards higher extraction flours or more refined flours.
Table 3 – Imports and Exports of wheat and wheat flour
Flour MT Wheat MT
Import Export Import Export
2007 36 517 135960 458882
2008 9336 256060 1820225 29691
2009 25 0 3102634 142506
2010 78177 5179 94058 4950
2011 24606 1239102 21841 2087422
Source: FAO TRADE on FAOSTAT July 2014
Table 4 – Food Balance Sheet Wheat
Wheat Equivalent ,000 MT Flour Equivalent 80%
Production Import Export Food Kg/Yr g/cap/day Kg/Yr g/cap/day
2007 23295 139 1079 17853 108.9 298 87.1 238.7
2008 20959 1835 346 18694 111.9 307 89.5 245.3
2009 24033 3104 160 19388 114 312 91.2 249.9
2010 23311 203 28 19681 113.7 312 91.0 249.2
2011 25214 63 3577 20050 113.8 312 91.0 249.4
Source: FAOSTAT July 2014
The full situation in the oil market is less clear in the FAO data bases. FAO
FBS and Trade do not agree on import and export data – probably because
FAO does not distinguish between refined oil, crude oil and oilseed only
between oil and seed. The use of Tables to explain the situation concisely is,
therefore, difficult.
Palm oil is not grown locally and is being totally imported, according to the oil
refineries, mainly from Malaysia and in the form of Refined Bleached
2 It is important to note this is AVERAGE consumption data. Using an average consumption of 250 g per
person per day and 90% of the population consuming then P5, P50 and P95 are 76, 228 and 456 g respectively
Final 291214 – Wheat and Oil Industry Pakistan Page 19 of 80
Deodorised Oil (RBDO) 3 4 - exports of Crude Palm Oil (CPO) being subjected
to an export tariff 5 to protect the local consumer and industry in Malaysia
and Singapore. Imports have been flat to slightly increasing and are
currently running at circa 2.1m MT
Cottonseed oil, however, is all local production and production of seed has
been steadily increasing to almost 5m MT. Cottonseed is, however,
approximately 20% oil but FAO indicates Pakistan oil production from the
seed is closer to 10%
Canola seed is produced locally and imported (circa 25:75) but again oil from
the seed is below the theoretical expectations of 40% at circa 30-35%
Sunflower seed oil is produced from an increasing proportion of locally
produced sunflower seed (circa 67:33) and extraction rates are closer, but
still lower, too theoretical. Exports of sunflower oil are increasing accounted
for over 60% of total production in 2011
Soybean seed is not locally produced and is imported 6 as crude oil. The
imports are, however, extremely volatile presumably due to market forces.
Estimates for the relative production of Vanaspati/Banaspati (deliberately not
using the terminology ghee – see below) and vegetable oil range from 90:10
to 60:40 (some newer players in the market are more oil biased)
‘Ghee’
The terminology „Ghee‟, according to the Punjab Pure Food Rules 2011 Part
IV (5) and (6) states:
(5) “Any food which resembles ghee but not solely derived from milk fat
shall not be described on any label, invoice, voucher, advertisement, price or
trade list by any expression combining the word ghee therewith”.
(6) “The use of such expressions as “vegetable ghee”, “khalis banaspati
ghee”, “artificial ghee”, natural/pure banaspati” or “velayati” ghee is
prohibited”.
Stakeholder Inputs The following is a synopsis of stakeholder inputs – further detail is provide in
Annex 3 – and are not provided in order of interview.
3 RBDO is a not technically correct. Imports should be defined as either RBDPO or RBDPL (Palm oil and
Palm Olein respectively) 4 Refineries indicate they bring in Olein not Oil
5
http://www.researchgate.net/profile/Amzul_Rifin/publication/235980339_The_Effect_of_Export_Tax_on_Indonesia's_Crude_Palm_Oil_(CPO)_Export_Competitiveness/links/0deec515250ff48273000000 6 There is some suggestion that local extraction of imported soybean seed is taking place.
Final 291214 – Wheat and Oil Industry Pakistan Page 20 of 80
Table 5 – Synopsis of Stakeholder Inputs
Stakeholder Comments
Pakistan Flour Millers Association
(PFMA) – Punjab Zone
Estimate number of mills in Pakistan
to be 1,200 Provided membership list (843)
Positive to fortification Engaged in self checking during the 2007 – 2010 fortification initiative
Prices are fixed and strictly controlled so fortification must be
included in the pricing model Wheat quality of concern Consultant is of the opinion micro
feeder selection was sub optimal
Pakistan Flour Millers Association –
Sindh Circle
Provided membership list (139)
Positive to fortification Engaged in self checking during the
2007 – 2010 fortification initiative Prices are fixed and strictly controlled so fortification must be
included in the pricing model Cocerned about Chakki mills as they
account for circa 50% of wheat milled but did recognise the problems with bringing these mills
into fortification
Pakistan Vanaspati Manufacturers‟
Association (PVMA)
Supportive but gave indications
influential members may try to block PVMA from actively participating.
Despite legislation compliance is low Adulteration of vegetable oil and ghee is known to be a problem
Food Department – Punjab and
Karachi
Very supportive Responsible for wheat pricing and
monitoring market price Storage capacity inadequate
Policy and Strategic Planning Unit (PSPU) – Lahore
Supportive Have main planning role but admit
they would need to be guided Consumer awareness is low
Final 291214 – Wheat and Oil Industry Pakistan Page 21 of 80
Stakeholder Comments
Supply chain largely unknown
Planning & Development
Department (PND) – Government of
Punjab
Not fully aware about fortification Have several misconceptions
including sensory changes, in flour, being caused by fortification
Do have the power to demand compliance
Nutrition Planning Commission NPC – Islamabad
Oil noncompliance due to inadequate monitoring Cost would be a significant barrier
Consumer does have some nutrition label awareness
Pakistan Standards and Quality
Control Authority (PSQCA) – Karachi
and Lahore
Federal agency 565 Food Standards of which 42 are
mandatory Karachi analysed 800 food samples last year
Vitamin A tested using the semi-quantitative test method with “very
few failures” in Karachi and all 70 passed in Lahore
Standing Committee Commerce & Investment – Punjab Assembly
Highly supportive – asked what they could do to help
Pakistan Council for Scientific and Industrial Research – PCSIR
ISO 17025 laboratory – but not for vitamins and minerals; but willing to implement that as soon as possible.
Possible site for fortification training
METRO Superstore Typical major superstore – have
own laboratory Conduct audits on suppliers
No problems with vitamin A in own label products
Jamia Tur Rashaid Supportive Would be highly influential in consumer awareness
Has its own publications that target women and children
TechnoMight Engineers – Faisalabad Also millers who had been involved in previous fortification
Have designed their own and reverse engineered micro feeders
Industry Assessment Problems Difficulties where encountered, especially by the local team, in gaining access
to processing facilities and to obtaining interviews.
Final 291214 – Wheat and Oil Industry Pakistan Page 22 of 80
Future missions should take cognisance of this fact as it will create significant
difficulties regarding data acquisition and will require high level advocacy.
Wheat Industry Assessment This assessment is based on overall findings and not on a specific
individual mill observations.
Unlike their milling colleagues animal feed operations (with highly
modernised systems) the flour mills are locally manufactured and/or so
called „Russian Mills‟ which are actually Miag (Buhler) mills made under
license in the Ukraine. Most mills are from circa 1960‟s. Parts are locally
sourced except for the rolls which are imported from Russia, Ukraine etc.
(the name „Russian mills‟ has stuck despite local components) Some of the
larger mills are now looking to expand operations and imported milling
equipment is being favoured. Companies such as Alapala 7 have a large
footprint mainly due to their turn-key capability; Turkey is also infiltrating
the market.
The flour milling sector appears to have no significant foreign investment and
all of the mills are privately owned.
The wheat quota system has had a significant impact on the shape and
structure of the Pakistan milling sector. The quota mechanism is based on a
quaint standardised concept of the number of „bodies‟ linked to „daily milling
capacity‟. In the Government system each „body‟ is capable of milling 20
MT/day – another terminology for „body‟ is „roller stand‟. In this Government
system the quota is up to 8 „bodies‟ which has, therefore, tended to limit the
size of mills to 8 bodies (though several mills have installed more than 8
„bodies‟).
The 8 „body‟ quota system maximum has not only constrained the size of the
mills but it has also permitted inefficient mills to continue operations despite
factors such as indicated below:
The Food Department can be relied upon to store grain so mills do not
have to establish large scale storage systems
Wheat price is subsidised (as discussed earlier) and is below market
price.
The quota system is not adequately monitored so mills can actually be
not operating (ghost mills) but still receive a quota which is sold on to
other millers.
In a good year (high crop) at harvest time the wheat price can be lower than
the Food Department price so mills with adequate funds, and storage, can
7 http://www.alapala.com/en
Final 291214 – Wheat and Oil Industry Pakistan Page 23 of 80
procure significant quantities of quality wheat and then „top up‟ with Food
Department wheat of poor quality.
Several mills used terminology such as „400 times more supply than demand‟
but this could not be substantiated at all. In fact despite many mills not
working much more than 16 hours/day due to load shedding several were
expanding operations through upgrades and at least one through the
purchase of a 360 MT/day new mill and, like in the interview mentioned
above, if power was not an issue they would be constrained more by wheat
supply than demand.
Power was of great concern to the millers and ranged from „no problems‟
(mills on a new industrial estate in Karachi) to „we receive a schedule of load
shedding but do experience some non-scheduled events‟ to „no load shedding
schedules provided‟. As a rule of thumb industrial areas could expect 10
hours without power whereas in residential areas unscheduled load shedding
could happen at any time and 6 times a day was not unusual. The
consequences of an unscheduled load shedding event on a mill in full
operation are significant:
Time lost manually emptying the mill streams as a mill cannot be
restarted from a „load on‟ position
Significant energy usage to restart the mill – this energy usage drops
once the mill is stable.
The quality of the flour noticeably decreases
The short term extraction rate significantly decreases, in an
unpredictable manner, which would
impact on fortification unless the
mills were fitted with gravimetric
micro feeders
The most common pack size was 20 Kg though smaller packs are becoming
more popular (indicating possible financial pressure in the marketplace)
despite the higher cost per Kg overall.
The wheat industry produces several types of flour ranging from highly
refined to high extraction:
Suji
Fine Maida
Maida
Special Atta
Atta
Suji was sometimes also called semolina but this product was very fine
(unlike wheat semolina used in pasta production). Maida flours are
predominantly used in commercial baking operations with Atta flours being
Identified risk factor –variable premix
addition to be resolved
Final 291214 – Wheat and Oil Industry Pakistan Page 24 of 80
the most common. Opinion was divided on whether the market was moving
towards more refined flours like Maida or almost wholemeal Atta.
Bran varied from 2% in commercial Chakki operations to 15-22% in
commercial mills. Similarly the price of bran varied dramatically from Rs
5.2/Kg from the Chakki mill to Rs 21/Kg from commercial mills.
As mentioned earlier the local team also visited mills – commercial and
Chakki – with the same questionnaire and for the purposes of collecting
samples of grain, atta and maida for analysis of total iron content and phytic
acid.
Analysis of their reports was collated by Prof Anjum summarised per Table 6
below:
Table 6 – Summary of local team mill visits
Regions No. of Flour
Mills Visited
Capacity (MT/24hr)
0-100 101-200 201-400
Baluchistan 5 0 4 1
Central Punjab 32 1 8 23
KPK 7 0 4 3
North Punjab 12 1 5 6
Sindh 13 0 10 3
South Punjab 17 1 9 7
Total Flour Mills Visited 86 3 40 43
From the questionnaires the team identified:
Knowledge/awareness of fortification 56 (65%)
Willing to participate in fortification 56 (65%) with 10% undecided
Already have micro feeders 22 (26%)
Production vs Theoretical capacity is discussed later but generally the
smaller the facility the percentage utilisation decreased.
Inspection by the Food Department varied considerably from „daily‟ to
„annual‟ with the majority being visited 2-4 times per month. Not
specifically noted by the team but these visits probably only occur
during the issuance of the quota.
Final 291214 – Wheat and Oil Industry Pakistan Page 25 of 80
Support required varied from a broad statement of „financial‟ to more
detailed responses of micro feeders, specific fortification training and
premix supply (millers generally felt the cost could not be passed on to
the consumer but they were not aware Food Department was willing to
include fortification in the flour price calculation)
Laboratory facilities were extremely limited (moisture with a few doing
other checks or using (abusing) electronic facilities at PFMA and a few
other mills – note the use of such equipment is providing a false sense
of security)
Vast majority of mills did not have ISO status or a HACCP plan (some
had not even heard of the terms) and GMP status was in the main
considered „satisfactory‟ by the team. Note very few of the mills would
pass inspection in Europe and many would not pass a WFP inspection
Storage facilities were often limited with the predominant storage
mechanism being bags under cover – silos were becoming increasingly
popular with larger mills but the concept/capacity of gristing was
largely unknown.
The file embedded below contains the detailed responses.
Final Report 1.xlsx
Oil Industry Assessment This assessment is based on overall findings and not on a specific
individual refinery observations.
Unlike the wheat (and rice, cotton and sugarcane) the oilseed supply is
totally neglected. The Pakistan Oilseed Development Board was established
in 1995 but was dissolved following the 2011 devolution amendment to the
Constitution. As a result the oilseeds industry has no lobbying body and
oilseeds have no support price structure and no Government procurement
strategy to back it up.
As a result of the above local industry has focussed on importing oilseeds
though the local sunflower production is expanding.
Equipment wise the refineries are also circa 1960 – 1970‟s, invariably
physical refineries operating on a batch process (with positive release
systems) with no automated systems (though a couple of smaller refineries
are investigating the option but are currently turned off by the cost).
Final 291214 – Wheat and Oil Industry Pakistan Page 26 of 80
All of the refineries visited had generators using diesel, wood or oil as fuel
(some refineries had 2 different fuel types of generators). As a result the
gap between installed capacity and actual production was 20% or less
(though smaller refineries had higher differentials up to 50%).
Being well established in the market i.e. high Brand exposure, was a
significant factor. Lesser known brands were often constrained in expanding
operations as they had so much capital tied up in what was either a credit
sale or product being in the market on a sale or return basis. The potential
market for vegetable oil was buoyant with some players indicating expansion
of 10 to 15% per annum. Sales are highest in the winter months.
Village level processing was widely considered to be a minor portion of the
market and whilst output did fluctuate, mainly due to speculation by traders,
the overall trend was downwards.
Pack sizes were very varied from 100 g pouches to 16 L buckets with the
most popular sizes being the smaller packs 1 L and less.
Drums (175 Kg) are used in for commercial operations but the sale of loose
oil is prohibited and loose Vanaspati/banaspati is only permitted under
special license.
Market forces are moving from Vanaspati/banaspati towards vegetable oils,
apparently at the behest of the media and medical opinion but the market
remains heavily in favour of Vanaspati/banaspati at 60- 80% of the total
market. Newer players in the market have significantly higher proportionate
vegetable oils sales due to branding (so finding it difficult to enter the
market).
Premix was found in the refineries visited - all from BASF with most refineries
advising they procured from local agents (deliberate multiple) rather than
imported directly. Monitoring purchases of premix from local agents would
be a useful monitoring tool and an early indicator of potential non-compliance
issues.
Inspection from the authorities – PSQCA and more recently from the Ministry
of Health, Food Authority - was intense with visits sometimes being on a
monthly basis.
All the refineries use Nickel formate as a catalyst in the production of
Vanasapti/banaspati and PSQCA test the presence of Nickel (maximum 0.25
ppm) as part of quality monitoring – this does not, however, prevent the
refineries from adding Nickel so imitating a hydrogenated oil product (at least
in part).
Final 291214 – Wheat and Oil Industry Pakistan Page 27 of 80
Technical Capacity
Wheat
Technical capacity is the wheat sector is very weak, even by developing
world standards, and there is little to encourage a quality focussed culture.
Whilst it is true some high technology quality parameter instrumentation is
available at PFMA Lahore and at a few (very few) of the mills – such as the
Chopin Infraneo 8 9 the equipment is a) not subjected to adequate validation
(being checked against official analytical methods) and b) being used outside
the scope even Chopin claim 10 (testing flours from different mills without
bias adjustments).
The most common analysis performed by the mills is on moisture:
Grain on intake
Grain to 1st Break
Finished flour
The most common moisture meters in use are the Gann 11 and the Wile 12
though some Perten 13 Inframatic NIR instruments (older and more basic
version of the Infraneo).
Few mills have laboratories and whilst some mills (and PFMA) will use the
Infraneo to measure gluten, Zeleny etc. the same problems of validation etc.
prevail; though the presence of a qualified technician may mitigate that
problem if the „laboratory‟ is provided with some analytical equipment to
maintain the calibrations. Some mills have equipment designed to measure
damaged starch and falling number (indicator of enzymatic activity).
Oil
The oil sector is better equipped, has at least basic laboratory equipment and
does monitor quality of the oil at all stages from raw material intake to
finished product. Tests carried out by the refineries include (but may not be
an exclusive list; not all oil products require all of the following tests and not
all refineries carry out tests on all of the quality parameters mentioned in the
Standards and Food Law):
8 http://www.chopin.fr/en/produits/45-infraneo.html
9 http://www.chopin.fr/media/produits/pdf/infraneo-documentation.pdf
10 The instrument works on the basis of interactions in infrared wavelength part of the spectrum – the
instrument claims to be measuring “minerals” – but minerals do not have chemical bonds so they cannot interact. 11
http://www.gann.de/Produkte/ElektronischeFeuchtigkeitsmessger%C3%A4te/ClassicSerie/HydrometteG86/tabid/109/language/en-US/Default.aspx 12
http://www.farmcomp.fi/en/wile/products/wile-for-wood/wile-bio-moisture-meter 13
http://www.perten.com/Products/
Final 291214 – Wheat and Oil Industry Pakistan Page 28 of 80
1. Bleachability
2. Cloud point
3. Colour
4. Free fatty acids or Acid value
5. Impurities
6. Iodine value
7. Melting point
8. Mineral oil
9. Moisture
10.Nickel
11.Peroxide value
12.Refractive index
13.Sulphite
Peroxide value (PV) and free fatty acids/acid value (FFA) are the most
significant in oil fortification and all refineries visited perform such tests.
Additionally all of the refineries carry out qualitative testing for vitamin A
(simplified Carr Price reaction). Results of samples taken from the
marketplace are discussed later (Table 8).
Refineries may benefit from using more modern technologies to determine
PV and FFA such as FoodLabFat14.
Human Resource Requirements
Almost without exception the technical staff are „qualified by experience‟ and
have had no formal training in any of the aspects of wheat milling and/or oil
refining. Whilst having practical experience they have little to no theoretical
knowledge and/or understanding of what they are doing. This was most
apparent in the wheat industry were millers were conditioning their wheat
prior to milling at significantly different moisture contents and for
significantly different times (one miller was even blending wet wheat‟s with
drier wheat‟s to control his moisture content) – factors such as this have a
direct impact of fortification in that if the flow of raw material through the
mill is a variable the ability to consistently fortify is compromised. A milling
course is not being suggested but in fortification training the consistency of
the product to be fortified does need to be addressed.
In the laboratories a similar situation appears to exist. Solutions with
inadequate identification, chipped glassware, no control samples, instruments
being switched on and off etc. all indicate to sub-optimal control of quality
due to lack of some basic skills and understanding.
14
http://www.cdr-mediared.com/food-diagnostics/foodlabfat/control-quality-edible-oils-fats
Final 291214 – Wheat and Oil Industry Pakistan Page 29 of 80
QA/QC Protocols
Wheat
In the wheat industry circa 135 mills (unknown if and how many Chakki mills
were in this initiative) had participated and most of those commercial mills
visited by the consultant and Prof Anjum had been part of that initiative.
None of the mills reported any problems with fortification and considered
themselves reasonably competent in the procedure.
Under more specific questioning, however, it was identified that almost every
single mill had found it necessary to dilute the premix so that the correct
dosage rate could be achieved – mills
interviewed advised that all of their milling
colleagues had encountered the same issue
and, therefore, thought this was „normal‟.
All mills allowed the consultant to visit the mill area where fortification was
taking place and to see the equipment that was used at that time and the
following key areas of weakness were identified:
The type of micro feeder was, in almost all the cases seen (may not
apply to the whole country), of Turkish manufacture (Milleral) and
had:
o Inadequate (consultants‟ opinion) agitation
o Single screw delivery (not a major issue)
o Volumetric delivery
o Difficult to calibrate variable speed drive (VSD)
o Gearing not conducive to required delivery rate
Incorrect positioning
Incorrect delivery flow
In adequate access to monitor flow rate on a routine basis
Training on the micro feeders appears to have come from PFMA.
Oil
The oil industry is required to add vitamin A at 33,000 IU/Kg to the oils and
oil products discussed earlier. Most mills were adding the industry standards
vitamin A and D3 – though this was not altruism but because it is cheaper –
and some were adding vitamin E as well.
In most of the refineries visited by the consultant the point of addition was
suitable i.e. after the final chiller but a couple appeared to be adding it during
the final deodorisation process which is under vacuum and at high
temperatures (though they did indicate this tank was also used as a final
chiller – a rather unusual plant configuration).
Identified risk factor – feeders not
suitable and incorrectly placed
Final 291214 – Wheat and Oil Industry Pakistan Page 30 of 80
All bar one of those visited were not diluting the oil, and the one that was
was not doing it to what is
generally considered „best
practice‟ of diluting at least
50 fold.
All of the refineries had recirculation systems which they ran for 15 to 30
minutes (probably adequate if diluted premix was used but would need
verification; and some had agitation systems as well). As the only data
available at the refinery is qualitative it could not be determined if the premix
was distributed in the oil or was actually lying at the bottom of the tank. The
refineries adding slowly is probably a mitigating factor but, without
verification, it could not be determined if the oil was adequately fortified.
Wheat and Oil
QA/QC protocols were uniformly weak though some facilities were slightly
better than others. In essence some level of QA/QC is being carried out but
the production facility would have a difficult time
proving that to an outsider as record keeping was
abysmal. Records such as they were where
focussed on what was happening at that particular
point in time i.e. essentially process control.
The use of computers for record keeping – except for sales and financial
records was limited to non-existent. Graphical representation of records was
not available – though once the concept was discussed with technical staff in
the refineries (wheat facilities had virtually no data to graph) they
immediately grasped the concept, saw the benefit of the approach and some
started to do so immediately.
A robust system of record keeping which would be an integral part of a
verifiable system audit is required. This system could be developed jointly
with the regulatory authorities so forming part of external auditing.
Requirement
Whilst there is some exposure to fortification this is not the same as a full
understanding of how to fortify and adequately control the process. It is
recommended that training be designed assuming no knowledge on the part
of the trainees and that the training programme targets a „training of the
trainers‟ approach and be both comprehensive and formally presented so
that it could be implemented within a formal training environment such as a
place of tertiary education and a formal training certificate issued.
Identified risk factor – incorrect addition method
Identified risk factor –
inadequate record keeping
Final 291214 – Wheat and Oil Industry Pakistan Page 31 of 80
Production – Installed and Actual Both the wheat and the oil industry were operating below their stated
installed capacity.
The wheat industry capacity being calculated on „bodies‟ may actually
overestimate the installed capacity but the power situation is the limiting
factor (except at the new Karachi Industrial Estate) and will remain the
limiting factor for several years to come (several millers stated “at least 4
years”).
Splitting the mills into groups based on installed capacity then the claimed
operational hours were:
Mills < 100 MT/Day - Only a few hours – indication were mill may be
operating solely on their wheat quota
Mills 100-200 MT/Day - Typically 12+ hours per day
Mills >200 MT/Day - Typically 15+ hours per day
It was also noted that geographical differences also existed with average
operational times being:
Baluchistan 5-6 hours,
Smaller cities 8-10 hours and
Larger cities 16 hours.
In terms of oil refined it is necessary to generalise and split the refineries
into 3 approximately equal
numbers per group based on
their installed capacity as
declared. The claimed actual production was:
Refineries <30,000 MT per annum claimed ± 50%
Refineries 30,000 to 50,000 MT per annum claimed ± 65%
Refineries >50,000 MT per annum claimed ± 80%
Premix Requirements To calculate premix requirements the information provided by FAOSTAT, the
Planning Commission, the Food Department and by industry was compared.
When adjusting industry data to take into account load shedding etc. and
extrapolating out to all of the production facilities of the membership lists the
total raw material processed exceed local production and imports by a
significant margin. As the FAOSTAT, Planning Commission and Food
NOTE – These are very broad generalisations and probably vary significantly according to
time of year
NOTE – These are very broad generalisations
Final 291214 – Wheat and Oil Industry Pakistan Page 32 of 80
Department data was very similar the industry data was excluded from the
premix requirement estimation.
The local assessment team repeatedly came across the comment that the
wheat quota allocation was significantly different in „their area‟ (always
negatively) compared to, for example, Lahore or Karachi. The implications of
this are that the installed capacity data is inherently flawed and probably
deliberately inflated to maximise their quota.
As mentioned earlier the wheat milling industry produce multiple type of
flours with some mills producing 2 types of Atta and 2 types of Maida plus
Suji which further complicates the premix requirement.
Suji can be excluded as it is a very small proportion of production but Maida
and Atta will need to be fortified.
Using data from FAOSTAT, Planning Commission, Food Department as well as
confirmatory data provided by GAIN consultant Kalim Ghauri the total
national flour production is circa 18.2 m MT of which Chakki mills account for
47% OR 8.5 m MT and Large mills 53% or 9.7 m MT
WHO Recommendations
Flour consumption averages at 96Kg/capita/annum or 263g/capita/day and
following the WHO Recommendations15 on wheat flour fortification we can
arrive at 2 basic premix formulations. Adding only iron (as NaFeEDTA) and
folic acid the addition rate would be 200g/MT but Pakistan has a zinc problem
(discussed later) and vitamin B12 is commonly added with folic acid and this
premix would have an addition rate of 275g/MT
Currently the thinking is only adding iron and folic acid.
For the wheat industry the premix could be linked into the quota system
(flawed as that is) but not directly. The Food Department, who handle wheat
equivalent to 38% of the large mills total production and about 20% of the
national production, would not handle the premix per se but their database
could be used to widen the scope of the identifiable mills – any mill that gets
a quota is required to fortify, and prove it or they do not get the next quota.
The usage of quota could also be centrally monitored and premix sales from
a „ghost‟ mill to another mill could be prohibited by requiring mills to procure
only from registered suppliers – and prove it.
Excluding Chakki mills the premix requirement would be 1,940 MT per
annum based primarily on Atta production.
A similar approach was used on the oil data and circa 2 m MT of oil and oil
products require fortifying at 33,000 IU/Kg which is 33.3g/MT of 1m IU/g
vitamin A. Total premix requirement would be circa 67 MT 15
http://www.who.int/nutrition/publications/micronutrients/wheat_maize_fortification/en/
Final 291214 – Wheat and Oil Industry Pakistan Page 33 of 80
Equipment Requirements
Synopsis
Each mill will require careful assessment as the flow rate of flours – assuming
both Atta and Maida are to be fortified – will range considerably. Whilst one
supplier will have equipment to suit all of the anticipated flow rates one
model of micro feeder will not be capable of covering the range of flow rates.
The alternative, especially for the smaller mills i.e. <100 MT/day (may also
be suitable for larger producers) is to use a proportional mixer like the Roff
3-in-1. This mixer can fortify and mix faster than the mill can produce the
flours so if the mill installs some extra bin space for flour storage then a
single unit can fortify multiple flours. The cost is equivalent to a single mid-
range micro feeder.
Requirements
World Grain supplier list 16 is possibly the biggest directory of equipment
suppliers but is heavily biased towards USA companies and companies exist
in Pakistan (TechnoMight discussed earlier) who could „reverse engineer‟ any
piece of equipment at very cost effective prices.
During the local team assessment an underlying theme was that the
equipment and the premix would have to be provided as the consumer would
not/ could not afford even the Rs 6/20Kg increase. This attitude will create
the market for copies of existing feeders and, possibly, inferior copies at that.
If we make some assumptions that all mills are generating at least 2 types of
flour then mills doing less than 50 MT per day would be producing around 40
MT of flour per day of which Atta around 60% or 1 MT per hour maximum
and the other flour Maida at 660Kg per hour. The variation in the flow rate
may also be significant. Such mills would require very low speed feeders
though a more logical option would be
some type of proportional mixing
equipment such as the Roff 17 3-in-1.
This type of equipment has an inlet
hopper with a low level sensor which
stops the equipment if there is no product
to fortify. The equipment has a very
efficient mixing system (right) and this
concept can also be introduced into large
milling operations – replacing part of the
16
http://sosland.gcnpublishing.com/gmabg/index.cgi?final_cat1=7&final_cat2=145&cat1_2=7&cat2_2=145&search_type=&search=search 17
http://www.roff.co.za/
Final 291214 – Wheat and Oil Industry Pakistan Page 34 of 80
auger with the mixing paddles.
A major advantage of this equipment is that it can operate faster than the
mill can produce (speeds of 4 MT/hour can be achieved) meaning that the
mill would need only 1 piece of fortification equipment with multiple storage
bins for the flours to be fortified. Alternatively the flour could pass through
the equipment on the way to the packing station.
The only known supplier of this equipment is ROFF Industries (Pty) Ltd; Cnr.
Piet de Vries and 7th Avenue, Kroonstad, 9499, South Africa;
sales@roff.co.za, +27 (0) 56 212 2697, +27 (0) 56 212 2696,
http://www.roff.co.za This equipment was specifically designed by Roff to
capacitate South African small millers when fortification became mandatory
in 2003. Discussions with Roff should be opened to have the equipment
made locally under license.
Larger mills would require micro feeders though each mill would need to
supply some highly specific pieces of information so that the necessary
gearing can be incorporated in the feeder.
The information required would be the maximum and minimum flow rates
through each of the relevant flour collection augers.
Basic reagents for the modified AACC 40-40 iron spot test would be required
– Potassium thiocyanate and 2N Hydrochloric acid
For the oil industry the only requirement would be for the refineries to dilute
down at least 50 fold the vitamin A they are „currently‟ adding. Equipment –
such as that supplied to Afghanistan – could be utilised but that option is not
a priority and could be viewed as being not cost effective.
Semi qualitative test kits from BASF will be required along with the necessary
chemicals – embedded below
Small Scale Processors In the wheat industry, with very few exceptions, the Chakki mills are not
commercial operations (defined as selling their own wheat, procured in the
marketplace and/or self-grown, under their own brands).
Urban mills are typically capable of milling 240 to 320 Kg/hour and a few
even have their own cleaning equipment and operate 4 hours per day
servicing clients who bring in anything between 10 and 50Kg of wheat for
grinding.
Final 291214 – Wheat and Oil Industry Pakistan Page 35 of 80
Milling costs were typically Rs 3/Kg though some millers charged Rs 5/Kg;
cleaning costs were Rs 0.75/Kg
There was no difference in milling costs between the China Chakki
(hammer/pin mill type) and the Stone Chakki (rotating stone of local origin)
as the power requirements were similar.
Stone mills need to sharpen the grinding stone every week – most do it
themselves as the stone grind pattern is basic – and millers observed clients
could tell when a stone needed sharpening.
No small scale oil operations were identified – being mainly in the deep rural
areas.
Commercially operating Chakki mills do exist in urban areas but there
numbers appear to be small and produce around 2 MT during the 12+ hours
they operate per day.
Fortification is possible in such mills, with a little reconfiguration to the flow
line, but the fortification process would be clearly visible which may lead to
consumer resistance unless a strong advocacy campaign has convinced
consumers of the benefits. The mill itself, being open to the street, could be
used as an advocacy point in its own right. Equipment such as the Roff 3-in-
1 discussed above would be suitable.
Specifically designed for hammer mills, and now being extensively trialled in
Africa, is the SANKU18 (shown below) which fits over the inlet hopper to
hammer mill and can be
installed and commissioned in
15 minutes. The advantage of
the system is that it operates
on the basis of proportional
dosing so for every „X‟ g
(typical setting is 330g) of
grain that flows through the
hopper „Y‟ g of premix is
dispensed with the grain which
is then milled – which carries
out the mixing process (actually more efficiently than a roller mill can mix)
before discharge back into the clients receptacle. The „doser‟ also has an
inbuilt monitoring device that indicates how much grain has been milled and,
as it assumes the grain has been fortified, how much premix has been used
and, therefore, when the miller will need a fresh supply of premix. BASF has
reached an agreement with SANKU and supplies premix in 5Kg bags and
provides the SANKU at a discounted, or even gratis, price based on reaching
18
http://sanku.com/
Final 291214 – Wheat and Oil Industry Pakistan Page 36 of 80
a contractual agreement with the miller. The communication of grain milled
has obvious positive implications for food consumption surveys.
Whilst GAIN Pakistan has advised that provisions can be made in law to
require Chakki millers who are milling a client‟s own grain to add fortification
premix as per a law which requires salt crushers to add iodine to clients
bringing their own salt a brief look at the UNICEF/MI Vitamin and Mineral
Deficiency19 (VMD) Global Assessment report of 2004 indicates Pakistan has
an estimated 17% of households with access to iodised salt (and this is figure
will be considerably smaller if the criteria is adequately iodised) which clearly
indicates that compliance monitoring is extremely weak.
With Chakki mills it is also important to note that:
1. Fortification is essentially voluntary (having a law requiring the mills to
add will not prevent the consumer from finding a miller prepared to
flout the law)
2. The cost of fortification moves from <1% increase in commercially
fortified flour to possibly doubling the cost of milling the consumers
grain (fortification becomes a percentage of milling cost as the grain
has „no value‟)
Additionally:
1. Extensive consumer advocacy would be required
2. Monitoring resources would need massive expansion
3. Distribution of premix would be a significant logistical issue
Vitamin A Fortification Compliance and Oil Quality Samples submitted to PCSIR 3rd September 2014 for free fatty acid, peroxide
values and vitamin A. Samples to be tested against the Punjab fortification
requirements at per Table 7 below.
19
http://www.micronutrient.org/CMFiles/PubLib/Report-67-VMD-A-Global-Damage-Assessment-Report1KSB-3242008-9634.pdf
Final 291214 – Wheat and Oil Industry Pakistan Page 37 of 80
Table 7 - Punjab Pure Food Rules 2011 – Fortification Requirement
Fortify Minimum 33,000 IU/Kg No Fortification Required
Refined Blended vegetable oils Cottonseed Oil
Refined Canola Oil Groundnut Oil
Refined Sunflower Oil Sesame Oil
Refined Soybean Oil Olive Oil
Vanaspati/Banaspati Poppy seed Oil
Refined Palm Oil Coconut Oil
Refined Palm Olein Rapeseed/Mustard Oil *
Refined Maize Oil Linseed Oil
Table Margarine Sunflower Oil *
Margarine Spread Taramira Oil
Spread Almond Oil
Soybean Oil
Niger seed Oil
Safflower seed Oil
Maize Oil * * These are not typographical errors – „Refined‟ is deliberately specified on fortified products
Previous Studies
PSQCA – no (or very few) failures in past 12 months
Mehmood et al 2011 20 Oil - 28.6% vitamin A detected, FFA 0.03 to 0.80 with
68.6% compliant, PV 0.7 to 84 with 80% compliant, weight 48% compliant
Mehmood et al 2013 21 Ghee - 47.5% vitamin A detected, FFA 0.08 to 0.33
with 75% complaint
Methods used in this study:
AOCS 1998 official method Ca 5a-40 For FAA
AOCS 1998 tentative method Cd 8-53 for POV
AOAC 2007 for vit A
BP 2007 method for vit D
In Table 8 below 44 of the 45 samples could be tested for vitamin A. 31 of
the 44 (70.5%) samples indicated the presence of vitamin A but only 6
(13.6%) samples could be considered compliant; 4 of which did not even
20
http://jcsp.org.pk/ArticleUpload/4394-20718-1-CE.pdf 21
http://www.researchgate.net/publication/220027405_Quality_Evaluation_and_Safety_Assessment_of_Different_Cooking_Oils_Available_in_Pakistan
Final 291214 – Wheat and Oil Industry Pakistan Page 38 of 80
indicate the presence of added vitamins; and 6 inadequately fortified – all of
which did not indicate addition. No vitamin D was detected in any of the
samples.
On Free Fatty Acid (FFA) or just Acid value all of the 45 samples were
compliant ranging from 0.03 to 0.09 (average 0.04) mg KOH/kg. All of the
samples would pass either an oilor a Vanaspati/banaspati specification. This
levelof results would satisfy WFP specifications of 0.1% maximum (as
palmitic acid) for fortified palm olein.
On Peroxide Value (PV) the situation was much more disturbing. On oil –
maximum value of 10
milli equivalents
KOH/Kg all bar 1 of
the 14 oil samples
passed. The range (excluding the 12.6 analysis), however, was from 3.4 to
7.3 with an average of 5.5 which, whilst within the national standard, is
above the WFP specification of 2 milliequivalents for fortified palm olein. It is
also far higher than the assessment team was led to believe would be the
case as refineries indicated they worked to specifications close to, or below, 1
millequivalent for both oil and Vanaspati/banaspati. Increasing from 1 to 5
in the short period the oil industry indicated there product was in the
production to consumption chain – circa 2 months or less – is disturbing and
will influence vitamin A stability.
Table 8 – Analytical results – market samples; oil and ghee
ID Oil ‘Ghee’ Indicating fortification
Fortified FFA PV Vitamin A
1 √ Yes –A/D No 0.08 6.3 ND
2 √ Yes –A/D No 0.07 6.0 851
3 √ No No 0.04 4.3 ND
4 √ No No 0.04 4.3 726
5 √ No Sample problem
0.03 3.7
6 √ No Yes -
inadequate
0.08 7.3 21659
7 √ No Yes - non
compliant
0.03 3.4 11104
8 √ No Yes - non
compliant
0.04 6.0 19216
9 √ No Yes - non
compliant
0.03 4.3 9296
10 √ No Yes - non
compliant
0.04 4.0 15847
11 √ No Yes - non
compliant
0.03 4.1 11083
Identified risk factor – possible rapid increase, over a short
period, in PV with negative implications for vitamin A stability
Final 291214 – Wheat and Oil Industry Pakistan Page 39 of 80
ID Oil ‘Ghee’ Indicating
fortification
Fortified FFA PV Vitamin
A
12 √ No Yes - non
compliant
0.04 6.7 3448
13 √ No Yes - non
compliant
0.03 12.6 1259
14 √ No Yes - non
compliant
0.04 4.0 17761
15 √ Yes –A/D/E No 0.03 5.4 548
16 √ Yes –A/D/E No 0.04 5.7 665
17 √ Yes –A/D No 0.04 4.8 710
18 √ Yes –A/D No 0.07 5.8 ND
19 √ Yes –A/D No 0.09 5.3 690
20 √ Yes –A/D No 0.03 5.3 183
21 √ No No 0.03 3.6 ND
22 √ No No 0.03 7.0 328
23 √ No No 0.04 5.0 207
24 √ Yes –A/D No - dilution
error?
0.03 6.6 2343
25 √ Yes –A/D No -
dilution error?
0.03 7.0 3797
26 √ No Yes - compliant
0.03 5.0 32254
27 √ Yes –A/D Yes - compliant
0.04 6.2 35349
28 √ Yes –A/D/E Yes - compliant
0.04 6.3 31372
29 √ No Yes - compliant
0.04 5.0 31214
30 √ No Yes - compliant
0.04 5.6 28939
31 √ No Yes -
compliant
0.04 5.3 34064
32 √ No Yes -
inadequate
0.03 6.0 24340
33 √ No Yes -
inadequate
0.04 5.0 21775
34 √ No Yes -
inadequate
0.04 4.7 21730
35 √ No Yes -
inadequate
0.04 7.7 20603
36 √ No Yes -
inadequate
0.04 6.2 22987
Final 291214 – Wheat and Oil Industry Pakistan Page 40 of 80
ID Oil ‘Ghee’ Indicating
fortification
Fortified FFA PV Vitamin
A
37 √ Yes –A/D/E Yes - non
compliant
0.04 4.7 7790
38 √ No Yes - non
compliant
0.05 6.0 9680
39 √ No Yes - non
compliant
0.04 5.0 8756
40 √ No Yes - non compliant
0.04 6.7 10443
41 √ No Yes - non compliant
0.04 5.0 6480
42 √ No Yes - non compliant
0.04 5.3 3540
43 √ No Yes - non compliant
0.03 7.4 2542
44 √ No Yes - non compliant
0.04 7.0 2912
45 √ No Yes - non compliant
0.04 4.6 11415
On the Vanaspati/banaspati analysis all passed on FFA as indicated above but
19 of the 31 samples (61.3%) failed on PV. As with the oil industry the
range was similar 3.6 to 7.7 milliequivalents with an almost identical average
of 5.7 milliequivalents.
Iron and Phytic acid levels Methods used in this study were from AOAC 2012 for iron and phytic acid
A total of 368 samples were collected for total iron and phytic acid content
and comprised of Grain (132), Atta (160) and Maida (73). Additionally 3
samples of Atta 2 – a finer Atta flour were collected but left out of the
subsequent analysis as they were no different to the Atta samples.
Samples were placed into a matrix based on product type (grain, atta and
maida), region (Baluchistan, Central Punjab, KPK, North Punjab, Sindh,
South Punjab) and mill type (Chakki and commercial).
The samples were then tested using the Z statistic which compares the
means of the different populations:
Standardized score = Z = (X - μ) / σ
In the tables below the means for grain, atta and maida are compared by the
means for each region – the sample size dictates that it would be an over
extrapolation to compare the regions against one another.
Final 291214 – Wheat and Oil Industry Pakistan Page 41 of 80
Results below in Table 9 are considered to be extremely closely related.
Table 9 – Mean values and Z stat for grain by total, mill type and region
Fe
(PPM)
St
Dev
Phytic
acid (%) St Dev Z stat
TOTAL 50.00 8.06 0.94 0.09
CHAKKI 49.32 0.96 0.08 0.21
MILL 50.36 0.93 0.04 0.11
Baluchistan All
No Data
Central Punjab 50.78 0.93 0.10 0.12
KPK 43.41 0.97 0.82 0.40
North Punjab 47.85 0.96 0.27 0.23
Sindh 49.12 1.01 0.11 0.79
South Punjab 49.47 0.91 0.07 0.33
Baluchistan
Chakki
No Data
Central Punjab 52.86 0.97 0.35 0.36
KPK 45.57 0.95 0.55 0.13
North Punjab 46.42 0.97 0.44 0.39
Sindh 47.54 1.00 0.30 0.65
South Punjab 49.93 0.92 0.01 0.19
Baluchistan
Mill
48.19 1.03 0.22 1.06
Central Punjab 52.97 0.88 0.37 0.65
KPK 42.48 0.98 0.93 0.52
North Punjab 51.37 0.91 0.17 0.26
Sindh 50.02 1.02 0.00 0.86
South Punjab 49.01 0.90 0.12 0.48
Table 9 above indicates that the national mean total iron content was 50 ppm
and the phytic acid content 0.94 %. The mean values for grain at different
mill types and in different regions was no different to the national mean.
Table 10 below indicates the same conclusion – note that the iron and phytic
acid content have not significantly dropped and that the standard deviations
of both the iron and phytic acid data is not much different between the grain
and the atta.
Whilst the grain data was close to a normal distribution with the iron varying
from 32 to 70 the atta results ranged from 2 to 60 ppm. Whilst excluding
results around 2 and 12 could be justified their
were also some samples in the low 20‟s meaning
that atta flour, which is what will be subject to
compliance monitoring has a natural intrinsic
Identified risk factor – high
variation in intrinsic iron
Final 291214 – Wheat and Oil Industry Pakistan Page 42 of 80
content of anything from 20 to 60 ppm before the addition of 20 ppm of
NaFeEDTA making monitoring on iron content highly questionable.
Intrinsic iron is poorly absorbed and with high phytic acid levels in Atta flour
this will be even more prevalent. The WHO recommendations do not take
into account intrinsic iron as it is, nutritionally, of little significance regardless
of the level (up to 60 ppm) and consumption of fortified flour with highly
bioavailable iron dictates the level of fortification.
As analysis of fortified wheat flour measures total iron content i.e. intrinsic
plus added and prior knowledge of the intrinsic content before fortification
would be impractical the regulatory authorities would need to use more
complex chemical protocols i.e. measuring the content of EDTA and back
calculating even then system audits will need to support any analysis data.
The variation in intrinsic iron content could also cause problems in the
development of a fortified wheat standard as such a standard would have to
recognise that both environment and extraction significantly cause variation
in intrinsic nutrient content and that neither of these factors can be
controlled or predicted with adequate certainty for legal purposes.
See also Graphs 1 and 2 below.
Table 10 – Mean values and Z stat for Atta by total, mill type and region
Fe
(PPM)
St
Dev
Phytic
acid (%) St Dev Z stat
Final 291214 – Wheat and Oil Industry Pakistan Page 43 of 80
TOTAL 41.20 7.25 0.83 0.10
CHAKKI 39.66 0.85 0.21 0.18
MILL 42.02 0.82 0.11 0.10
Baluchistan
All
44.76 0.85 0.49 0.20
Central Punjab 42.66 0.81 0.20 0.20
KPK 36.73 0.86 0.62 0.28
North Punjab 39.79 0.82 0.19 0.15
Sindh 40.68 0.85 0.07 0.20
South Punjab 40.28 0.84 0.13 0.09
Baluchistan
Chakki
43.86 0.87 0.37 0.35
Central Punjab 39.44 0.83 0.24 0.01
KPK 33.53 0.82 1.06 0.15
North Punjab 39.65 0.89 0.21 0.63
Sindh 39.93 0.85 0.18 0.24
South Punjab 38.95 0.84 0.31 0.10
Baluchistan
Mill
46.11 0.83 0.68 0.04
Central Punjab 43.77 0.80 0.35 0.27
KPK 38.55 0.88 0.36 0.53
North Punjab 39.86 0.78 0.18 0.49
Sindh 41.01 0.85 0.03 0.18
South Punjab 41.26 0.84 0.01 0.09
Table 11 below indicates the same situation with Maida flour not being
distinguishable from the national mean but the same problem of the rangle
of intrinsic iron from 1.5 to 39 ppm indicates compliance monitoring will need
to consider audits as supporting data to quality measurement. See also
Graph 3 below.
Table 11 – Mean values and Z stat for Maida by total, mill type and region
Fe
(PPM)
St
Dev
Phytic
acid (%) St Dev Z stat
TOTAL 16.57 8.72 0.10 0.05
CHAKKI
MILL 16.49
0.09
0.01 0.21
Final 291214 – Wheat and Oil Industry Pakistan Page 44 of 80
Baluchistan
All
Central Punjab
KPK
North Punjab
Sindh
South Punjab
Baluchistan
Chakki Central Punjab
KPK
North Punjab 22.58
0.10
Sindh
South Punjab
Baluchistan
Mill
Central Punjab 13.99
0.10
0.30 0.02
KPK ?
0.13
North Punjab 15.62
0.10
0.11 0.10
Sindh 21.25
0.11
0.54 0.20
South Punjab 17.34
0.10
0.09 0.11
Note only 1 sample of Chakki Maida flour.
Graph 1 – Intrinsic iron variation in Grain
0.00
10.00
20.00
30.00
40.00
50.00
60.00
70.00
80.00
1 6
11
16
21
26
31
36
41
46
51
56
61
66
71
76
81
86
91
96
10
1
10
6
11
1
11
6
12
1
12
6
13
1
Grain
Final 291214 – Wheat and Oil Industry Pakistan Page 45 of 80
Graph 2 – Intrinsic iron variation in Atta Flour
Graph 3 – Intrinsic iron variation in Miada Flour
Annex 4 provides the statistical analysis provided by Dr Saeed which, using
the more stringent means squares technique does find significant differences. That different statistical techniques generate differing conclusions is not unknown and both methods used, are in themselves, both valid. Dr Saeed
has used the more stringent mean squares test which demonstrates, for example, that 43.9% and 39.9% are significantly different. This needs to be
put in context in that grain intrinsic iron was shown, nationally, to vary from 32 to 70 ppm and that the Southern African Grain Laboratory, an ISO 17025 laboratory for vitamin and mineral analysis, has a 95% coefficient of error of
close to 18%. From Table 11 above the national mean value for iron is 50
0.00
10.00
20.00
30.00
40.00
50.00
60.00
70.001 7
13
19
25
31
37
43
49
55
61
67
73
79
85
91
97
10
3
10
9
11
5
12
1
12
7
13
3
13
9
14
5
15
1
15
7
Atta flour
0.00
5.00
10.00
15.00
20.00
25.00
30.00
35.00
40.00
45.00
1 4 7 10 13 16 19 22 25 28 31 34 37 40 43 46 49 52 55 58 61 64 67 70 73
Maida Flour
Final 291214 – Wheat and Oil Industry Pakistan Page 46 of 80
ppm with a standard deviation of 8 ppm with a 95% coefficient of error of 9 ppm. From a practical view point the differences between the regions would
not be measurable.
Wheat Price Commentary The following was obtained from http://www.qeemat.com/wheat-price-in-
pakistan/ - „prices having almost doubled, farmers unable to find buyers at
Government rates and, some positive news, possible investment in wheat.‟
Zinc Pakistan is placing considerable effort into alleviating the zinc deficiency
problem through bio fortification.
The Harvest Plus Zinc Wheat indicates the average nutrient content is 25
mg/Kg and the target is 33 mg/Kg. In 2009 the release date was estimated
at 2012 – discussions with NPC indicate the release date to be now 2015 (3
years late) with no indication of how close to the „target‟ bio fortification has
achieved.
Pakistan has a long history of not using new seed in the wheat programme
(hence the very poor yields) and it is unknown how this will actually be
achieved through the Punjab Food Authority advise that the Seed
Cooperative and private seed companies are on board with the programme.
Even though Pakistan, generally, uses high extraction wheat flour – Atta –
the anticipated zinc increase in the wheat is 30% or 8 mg/Kg whereas WHO
recommendations would indicate 40 mg/Kg is feasible through fortification.
The down side is that fortification will not reach the deep rural area but there
is no guarantee that bio fortification will do either in a sustainable manner.
PS: Adding 40 ppm Zn as ZnO and 0.01 ppm as vitamin B12 would increase
dosage rate (and, therefore, distribution cost) by 25% with a similar increase
in premix cost. Based on costing models provide to the consultancy team
the cost of fortification is Rs6/20 Kg of which premix is calculated at
Rs1.2/20Kg. Adding zinc as a fortificant (with vitamin B12) would take that
cost to Rs1.4/20Kg
Final 291214 – Wheat and Oil Industry Pakistan Page 47 of 80
Conclusions and Recommendations
General
Annex 3 contains a significant quantity of clarification material that was
placed in the Annex to bring only the main points into the main body of the
report.
Wheat
Despite wheat fortification being trialled in Pakistan anything above even the
most basic knowledge of fortification was missing. Equipment was supplied
that was sub-optimal (mainly because the dosing capacity and the dosing
requirement did not match) and was, in almost all cases, incorrectly placed.
That some millers complained about the inability to get feeders repaired
locally also indicates the quality of the feeders was not sub-standard. The
type of feeders supplied would also not suit the operational profiles of most,
if not all, smaller (<2 MT/hour).
Information provided by the mills on actual production, when extrapolated
nationally, could not be verified by data from other sources i.e. Food
Department, Planning Commission and FAOSTAT
Recommendation 1
Assume Pakistan has had little to no exposure to wheat fortification. What
was done appears haphazard and subject to inadequate oversight
Recommendation 2
Assume almost all of the micro feeders will need replacing – a possibility
exists that some could be refurbished and relocated but this could prove
uneconomic.
Recommendation 3
Before implementing Recommendation 4 it is suggested that short
sensitisation workshops be held which provide an overview of the course
content to be used in Recommendation 4
Recommendation 4
Fortification training i.e. the typical „Millers Best Practices‟ concept as used by
FFI consultants should be implemented through a „Training of Trainers‟ so
that local teams could ensure widest possible coverage and provide, at
millers cost, top up and/or revision training as required.
Recommendation 5
Should the programme consider that micro feeders need to be procured on
behalf of the programme then the millers should be capacitated to identify
Final 291214 – Wheat and Oil Industry Pakistan Page 48 of 80
what flow rate of feeder(s) are required – this would be part of
Recommendation 3.
The logic behind this is that industry information provided to entities outside
of the mill may have hidden agendas i.e. influencing the quota allocation. By
placing the onus on the miller to identify current (and possibly future)
requirements the programme can have a reasonable level of confidence the
equipment supplied would be suitable (Recommendation 3 would have
highlighted the problems with poor feeder selection).
Requiring the miller to procure and then apply for a rebate (partial or full) is
one option though a more cost effective option would be bulk purchasing
through a tender based on the information provided by the mill.
Recommendation 6
The premix supply chain needs to be secured. The oil industry uses local
agents and this model could be easily transferred to wheat. This chain could
be used as part of the monitoring system
Oil
The oil industry has had mandatory fortification with vitamin A (vitamin D is
also added though not legislated) for many years. It is widely known in the
industry that compliance levels are „low‟ but data from the regulatory
authorities indicate almost complete compliance. Both industry and the
regulator use semi-quantitative measurements to determine compliance so
determining adequately fortified oil and oil products is not possible.
Industry is adding vitamin A in the correct place (those seen by consultant
Randall) but is adding it incorrectly i.e. addition is made of the concentrated
vitamin A and not the generally accepted method of pre-dilution (50 fold)
and recirculation. Whilst industry does recirculate the difference in specific
gravity of the concentrated vitamin A and the oil/oil product indicates the
vitamin A could be simply dropping to the bottom of the tank and only very
slowly blending with the oil or oil products.
Industry visited by consultant Randall indicated production typically produced
product with a FFA approaching zero and a PV below 1 though the market
results would indicate that either production had a PV significantly higher
than 1 or something drastic is happening in the distribution chain causing an
increase in PV.
Recommendation 1
Before implementing Recommendation 2 it is suggested that short
sensitisation workshops be held which provide an overview of the course
content to be used in Recommendation 2
Final 291214 – Wheat and Oil Industry Pakistan Page 49 of 80
Recommendation 2
Fortification training i.e. the typical „Oil Fortification Best Practices‟ concept
as used by FFI consultants should be implemented through a „Training of
Trainers‟ so that local teams could ensure widest possible coverage and
provide, at refiners cost, top up and/or revision training as required.
Recommendation 3
The premix supply chain needs to be identified and secured. This chain could
be used as part of the monitoring system.
Monitoring
Monitoring in wheat is not geared to fortification but price control and
moisture and in oil is poorly equipped to do so. Whilst generally
unannounced ensuring that the inspector obtains a compliant sample is not
difficult and the regulatory authorities appear to be taking little notice of
independent studies carried out on market samples of oil and oil products
that clearly indicate a high level of non-compliance or, potentially worse, oil
and oil products whose quality was sufficiently poor (PV and FFA) that any
added vitamin A has been oxidised and rendered nutritionally useless.
Recommendation 1
As NaFeEDTA is water soluble the probability exists that adapting the
methodology used with iCheck IRON could be used as part of the monitoring
system
Recommendation 2
Use iCheck Chroma3 to monitor vitamin A
Recommendation 3
Use FoodFatLab22 to determine PV and FFA
Recommendation 4
The degree of hydrogenation carried out in the production of
Vanaspati/banaspati needs to be monitored
Recommendation 5
Revisit the existing standards for wheat and oil to see if they are stringent
enough to make fortification viable. The oil quality standards on PV are not
ideal and industry should be capable of producing low PV oil and oil products.
Recommendation 6
YOU MAY WANT TO DELETE THIS
22
http://www.cdr-mediared.com/food-diagnostics/foodlabfat/control-quality-edible-oils-fats
Final 291214 – Wheat and Oil Industry Pakistan Page 50 of 80
Subject the laboratories involved in the testing of vitamin A, PV and FFA to
proficiency testing. Sample tested by iCheck, Potsdam University and SGS
Germany (latter 2 laboratories used HPLC) had reasonable correlation but
differed entirely with the Pakistan results. This puts the analysis of PV, in
particular, in question. Iron analysis was as expected though some samples
look questionable (low iron content)
Final 291214 – Wheat and Oil Industry Pakistan Page 51 of 80
Annex 1 A TOR International consultant
Wheat Flour Industry
a) General tasks:
To conduct a detailed assessment at each of the selected flour mills and Chakki mills in Pakistan in order to determine their respective equipment and premix requirements, recommend protocols that can be adopted within the
current manufacturing process that can ensure fortification requirements can be consistently fulfilled and determine the training requirement for
production personnel if applicable. b) Specific tasks:
Develop a checklist and questionnaire and assessment methodology. Conduct meetings with Pakistan Flour Mills Association, Food
Department, Health Department, Punjab Food Authority, Planning Commission, development partners and any other important stake holders to seek their inputs.
Stratify large scale, medium and small scale flour mills and chakkis for assessment based on the production and geography.
Visit all selected flour mills and meet with the designated production personnel and management staff. (Expected number of mills to be assessed is 90 (7% of total), stratified based on production and
geography) Visit all selected Chakkis and meet with the designated production
staff and owner. (Currently there is no source of information available providing exact number of chakkis. It is expected that a total of 48
Chakkis, stratified province/region wise would be required to be visited)
Estimate the production capacity and actual production achieved by
each of the producers and based on this provide projections for premix requirements
Based on the plant layout, design and capacity, develop a detailed equipment list and/or process changes that would be required to fortify at an appropriate quality. The specifications should be detailed
enough to enable procurement of appropriate micro-feeders. The consultant should also provide a list of potential suppliers of such
equipment and estimated costs of process upgrades that are proposed. Document production protocols in place at each of the manufacturing
plants and provide recommendations of appropriate QA/QC protocols
that would have to be adopted to produce fortified products in accordance with National standards.
Observe technical capacity of production personnel and in consultation with plant managers provide an objective brief on extent and type of training that would be beneficial/required.
Final 291214 – Wheat and Oil Industry Pakistan Page 52 of 80
Identify wheat flour consumption pattern and variations among different provinces, which could impact on required level of
fortification.
Oil and Ghee Industry
a) General tasks: To conduct a detailed assessment at each of the selected Oil and Ghee mills
and unregulated producers, in Pakistan in order to determine their respective equipment and premix requirements, recommend protocols that can be adopted within the current manufacturing process that can ensure
fortification requirements can be consistently fulfilled and determine the training requirement for production personnel if applicable. Generate
evidence for level of Vitamin A and D in the oil and ghee available in different parts of the country.
b) Specific tasks: Develop a checklist and questionnaire and assessment methodology.
Conduct meeting with Pakistan Vanaspati Mills Association, Pakistan Standards and Quality Control Authority, Health Department, Punjab Food Authority, Planning Commission, development partners and any
other potential stake holder to seek their inputs. Stratify large scale, medium and small scale Oil and Ghee Mills and un-
regulated producers for assessment based on the production and geography.
Visit all selected Oil and Ghee Mills and meet with the designated
production personnel and management staff (Total expected mills to be visited with geographic distribution is 16 (15% of total).
Visit all selected un-regulated producers of the oil and ghee, stratified based on geography from all provinces and regions. (the total
expected producers will be 10) Estimate the production capacity and actual production achieved by
each of the producers and based on this provide projections for premix
requirements Based on the plant layout, design and capacity, develop a detailed
equipment list and/or process changes that would be required to fortify at an appropriate quality. The specifications should be detailed enough to enable procurement of appropriate dosing equipment. The
consultant should also provide a list of potential suppliers of such equipment and estimated costs of process upgrades that are proposed.
Document production protocols in place at each of the manufacturing plants and provide recommendations of appropriate QA/QC protocols that would have to be adopted to produce fortified products in
accordance with National standards.
Final 291214 – Wheat and Oil Industry Pakistan Page 53 of 80
Observe technical capacity of production personnel and in consultation with plant managers provide an objective brief on extent and type of
training that would be beneficial/required. Collect sample and provide analysis of level of Vitamin A and D in Oil
and Ghee from different sources and parts of country by having a representative sample. (48 samples to be collected)
Annex 1 B TOR Local consultant a) General Task
To co- lead the detailed country wide industrial assessment for flour mills,
chakki mills, oil and ghee mill in Pakistan. The assessment shall provide an
in-depth analysis of the current state of equipment and industrial processes
for wheat flour production. The analysis shall provide guidelines for the
development of industry and human resource capacity building for large scale
fortification. This may include buy not limited to the premix requirements,
fortificant supply chain mechanisms currently in place and current human
resource capacity. Conclusively recommend protocols that can be adopted
within the current manufacturing process to ensure mandatory fortification in
country.
b) Specific tasks:
Provide technical inputs on study design, checklist, assessment
methodology and questionnaire.
Co-lead and facilitate meetings of assessment team with key
stakeholders (PFMA, PVMA, Food Department etc)
Gather available literature, data, and other information to facilitate the
in country work of international consultant.
Recruitment of six data collectors in collaboration with Project Manager
for food fortification as per qualification and experience specified by
GAIN.
Arrange and co-facilitate training of data collection team including
logistic arrangements, field orientation and pretest of questionnaire.
Supervise the data collection team, data collection process, and cross
verification of randomly selected 5% data of the team.
Manage collection of samples of wheat grain, wheat flour, edible oil
and ghee as per study design.
Identify and assist in selection of laboratory for analysis of samples
and coordinate with selected laboratory for managing analysis of
collected samples.
Final 291214 – Wheat and Oil Industry Pakistan Page 54 of 80
Analyze the results of sample reported by the laboratory and data
collected by the data collection team, and shape it for using in the
assessment report by the international consultant.
Provide support and inputs to international consultant for report writing.
Final 291214 – Wheat and Oil Industry Pakistan Page 55 of 80
Annex 2A Wheat Industrial assessment for wheat flour in Pakistan for food fortification
Flour Mill Organization Profile
Name of Flour Mill: ________________________________________________________________
Address:
________________________________________________________________
CEO: _____________________________________________________________
___
Telephone: ______________________________
Contact Person: _______________________________
No of Workers: ______________________________
Area of Flour mill: __________________________________
Is there any food technologist? __________________
Milling Capacity: ___________________________________ Storage Capacity: _________________________________________
Flour Production & Quality
Question Answer Remarks
Grinding Capacity….Ton per
24 hrs. 3 Shifts?
Grinding per unit of electricity? (Normal 20kgs per unit)
Extraction percentage of Atta
Extraction percentage of
maida
Extraction percentage of Sugi
Extraction percentage of Bran
Types of flour
Final 291214 – Wheat and Oil Industry Pakistan Page 56 of 80
Question Answer Remarks
Export potential of wheat product?
Do you suggest any change in food laws?
Types of flour
Export potential of wheat product?
Do you suggest any change in food laws?
What do you know about the National Food Fortification
Program in Pakistan?
Role of food department?
How often are you inspected by the authorities, which ones and what do they do?
Wheat cleaning equipment‟s
No. of break roll bodies
No of reduction roll bodies
Which sifters are being used
in your mill?
What are tempering conditions
What kind of package material is used for flour packaging?
What process do you use to mill your grains?
Is the mill environmentally
friendly?
What is the shelf life of
different products produced here?
Is there any product recall process?
If you are to adopt flour fortification, what kind of
assistance would you like?
Where do you get your raw
material from? (farmers/traders/own
Final 291214 – Wheat and Oil Industry Pakistan Page 57 of 80
Question Answer Remarks
farm/contract farms, Govt)
Installed capacity
Actual production
Extraction rate
Operating hours – hours per day, days per week, weeks
per year
Reason for not fully
operational
Total production in last year
Schematic Wheat: Inspect the mill and sketch
the factory layout with approximate dimensions and note the following:
a. Mill type: b. Country of
manufacture: c. How many mills are
installed in parallel? (take photos if permitted):
Which analysis regarding the composition of flour?
Location of the current fortification point
Pest control method
Is there any fortificant used
at the mill
Food safety issues in the mill
ISO/HACCP Certified?
Who fortifies and what QA/QC checks
Laboratory facilities – basic to good
GMP status
Suitable place to store premix
Current buying price of raw
Final 291214 – Wheat and Oil Industry Pakistan Page 58 of 80
Question Answer Remarks
material
Variation in price during the year – how much?
Variation in price during the year – how much
How wide a distribution area?
Types of storage
Storage capacity
Marketing strategies
Remarks ------------------------------------------------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------
Critical remarks (only filled by Surveyor)-------------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Suggestions:------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------
----------------------
Final 291214 – Wheat and Oil Industry Pakistan Page 59 of 80
Name of the resident person Surveyor provided information
Date:____/_____/_____
Final 291214 – Wheat and Oil Industry Pakistan Page 60 of 80
Annex 2B Oil Title: Industrial assessment for wheat flour and edible oil in Pakistan for food fortification
Objective:
To conduct a detailed assessment at each of the selected Oil and Ghee mills and unregulated producers, in Pakistan in order to determine their respective equipment and premix requirements, recommend protocols and fortification
process with special reference to vitamin A & D
Section 1
Organization informations
1. Name-----------------------------------------
2. 2. Location------------------------------------------------- --
3. Mailing address---------------------------
4. 4. Contact informations-------------------------------
5. History---------------------------------------
6. 6. CEO-----------------------------------------------------------
7. Total no of employees ----------------------------------------------------------
8. Non-technical--------------------------------
9. Technical personals--------------------------------------
10.Average Education of Non-technical employees --------------------------
----
11.Average Education of technical employees--------------------------------
----
12. Total no of Food technologists---------------------------------------------
----
Section 2
Equipment and Protocols
1. What kind of equipment‟s are utilized (Local machinery or Imported plant)------------------------------------------------------------------------
------------
2. When you last update your plant-----------------------------------------------
Final 291214 – Wheat and Oil Industry Pakistan Page 61 of 80
3. Age of the plant ----------------------------------------------------------------
4. Production capacity---------------------------------------------------------
----
5. Current production ---------------------------------------------------------
----
6. Source for oil and ghee-----------------------------------------------------
----
7. What is your acceptance and rejection criteria--------------------------------
8. What kind of Pre-processing analysis you are perform for raw materials---------------------------------------------------------------------
------------------
9. Are you periodically update your protocol for production-----------------
----
10. Which catalyst you are using during hydrogenation----------------------
----
11. What is its concentration-------------------------------------------------------
12. Are you carried physical or chemical refining---------------------------------
13. What are the Operating hours – hours per day, days per week, weeks per year----------------------------------------------------------------------
--------
14. If the plant is running in under capacity? Please elaborate the
reasons---------------------------------------------------------------------------------------
15. What is your last year production-------------------------------------------------------------------------------
16. Please provide the information regarding the different chemicals which are utilized for degumming, refining and etc.----------------------
---------------------------------------------------------------------------------------------------
17.What is the Temperature of oil after final chiller---------------------------------------------------------------
18.What is the diameter of pipework going to the tank farm----------------
----
Final 291214 – Wheat and Oil Industry Pakistan Page 62 of 80
19.What is the approximate distance from final chiller to tank farm that the oil actually travels ------------------------------------------------------
-----------
20.Total no of finished products---------------------------------------------------
Section 3
Fortification
1. Are you fortifying the oil and ghee for vitamin A & D---------------------
----
2. Which sources you are utilized for Vitamin A------------------------------
----------- & D-------------------------------------------------------
3. What concentration for vitamin A & D is used----------------------------
----
4. Which protocol are you adapting for the fortification-------------------------
5. Is there any periodic improvement in your protocol of fortification-------------------------------------------------------------------------------------
--------
Section 4
(Certifications & Documentation)
1. Have you obtained any certification regarding ISO and HACCAP---------------------------------------------------------------------------------------
---------
2. What is your company food safety policy---------------------------------
---------------------------------------------------------------------------------------
3. What kind of documentations are usually prepared--------------------------
4. Is there any traceability system for your products---------------------------
5. Any other specific documentation------------------------------------------
----
Section 5
Lab and analysis facilities
Final 291214 – Wheat and Oil Industry Pakistan Page 63 of 80
1. Do you have laboratory---------------------------------------------------------
2. If yes than what is the capacity of the lab---------------------------------
----
3. Analysis performed in the lab----------------------------------------------
----
4. Do you have facility to analyze Vitamin A and D--------------------------
----
5. If no how you claim the concentration in your final product-----------------------------------------------------------------------------------------------------
6. What is the qualification of the lab in charge------------------------------
----
Section 6
Training of the employees
1. Is there any policy of the company regarding the employees training----------------------------------------------------------------------------------------
--------
2. What is the level of training---------------------------------------------------
-------------------------------------------
Remarks ----------------------------------------------------------------------------
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------
----------------------------------
Critical remarks (only filled by Surveyor)-------------------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------
---------------------------
Final 291214 – Wheat and Oil Industry Pakistan Page 64 of 80
Suggestions---------------------------------------------------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Name of the resident person Surveyor Provided information
Final 291214 – Wheat and Oil Industry Pakistan Page 65 of 80
Annex 3 – Stakeholder Inputs
Pakistan Flour Millers Association (PFMA) – Punjab Zone
PFMA Punjab estimated the total number of mills to be approximately 1,200
flour mills 23 and provided the consultancy team with a list of 843 members.
The PFMA (Punjab) are very positive towards fortification and during the
2007 -2010 fortification initiative PFMA had external teams checking on
participating mills every 15 days with the spot test (indicating a high level of
industry self-regulation).
PFMA advised they have their own laboratory 24 with a qualified analyst that
provides analysis free of charge to its
members. Analysis is believed to consist
of protein, moisture, ash, gluten, water
absorption on wheat and wheat flour
In the opinion of PFMA – Punjab - the market for wheat flour varies from a
movement to whole wheat
Atta flour in specific areas
with whiter (more refined)
flours being preferred in
Karachi. The general
movement was towards whiter flours. PFMA advised, however, that the
market was subject to strong competition due to being in an oversupply
situation.
Grain prices are fixed by the Federal Government prior to the harvest and
food security (Federal Government) is ensured by the Food Department
(discussed later). As prices
are strictly controlled (see
Wheat price commentary
later) the ability to pass on
the cost of fortification to
the consumer was a
constant discussion point
within the membership.
Consultant Randall was
advised that this issue had
been taken up with the
Food Department and the
23
The consultants identified 1171 Sindh has 139 mills on the list but the PFMA Sindh region say it is 198 24
Not seen by the consulting team
Identified risk factor - believed to be carried
out using NIR or NIT technology such as the
‘Chopin Infraneo’
Identified risk factor – high phytic acid in whole wheat
Atta and low nutrition content in more refined flours
Identified risk factor – the cost of fortification needs to
be incorporated or severe resistance/non-compliance
from industry will be a significant issue. It is unclear,
however, why feeder amortisation is included (double
entry in accounts as this is automatically claimed) and
why external monitoring needs to be funded by the
fortification programme itself – Government (Federal
and Provincial) are responsible for food monitoring not
the consumer.
Final 291214 – Wheat and Oil Industry Pakistan Page 66 of 80
cost of fortification (premix, internal monitoring and micro feeder
amortisation) was being considered for inclusion in the floor price for wheat
and wheat flour.
Wheat quality was recognised as a point of concern especially in the area of
moisture content and impurities (which frequently exceed 3%). This area is
a long standing one which relates to the use of a „fair average quality‟ criteria
coupled with a „no loss policy‟. This
catastrophic combination of policies
combined with poor timing of key
decisions (price in particular) and
implementations has already been
more than adequately covered by Kansas State University 25, Storage
Technology and Transfer, December 1989.
Brand registration and recognition is strong making monitoring and recall
possible.
PFMA reported no major issues with fortification during the 2008 to 2011
period but several claims were made by other parties that:
PFMA coordinated the procurement of micro feeders to the project
The micro feeders were of Turkish origin
The micro feeders were not suitable for direct use in the programme
but required the premix to be diluted prior to use (confirmed by
consultant Randall).
No guidance (or incorrect guidance) was given on correct positioning
of the micro feeders (confirmed by consultant Randall).
Pakistan Flour Millers Association – Sindh Circle
The consultants had originally been provided with a list of 139 members of
the Sindh PFMA but were advised on meeting the Association that the
membership now stood at 198 with the majority in the region of >200MT to
280MT
As with the Pujab Chapter the Association was very positive towards
fortification and had been extensively involved in the 2008-2010 initiative.
Price control (as discussed above) was a major point of concern for PFMA –
Sindh – and the Chairman was not convinced that the Food Department
would incorporate fortification costs into the wheat pricing equation. Wheat
quality was not an issue.
Another concern was the question of Chakki mills, especially in rural areas,
that the Association estimate account for circa 50% of the wheat flour milled.
25 http://pdf.usaid.gov/pdf_docs/Pnabb925.pdf
Identified risk factor – wheat supply is on a
‘quota’ system for 7 to 8 months of the
year. Could be used as a leverage point.
Final 291214 – Wheat and Oil Industry Pakistan Page 67 of 80
The Association did, however, recognise that Chakki mills presented multiple
problems not least of which were:
Being able to identify where they were
Majority provided a milling service not commercial flour
Logistics in getting premix to the relevant millers
Consumer awareness and acceptance
Monitoring and quality control
PFMA willingly agreed to facilitate meetings with members and cooperate in
any way possible.
Pakistan Vanaspati Manufacturers’ Association (PVMA)
Interview led by Mr Faiz (GAIN) and proved to be the antithesis of the
meeting with the PFMA Secretary General.
The PVMA indicated that noncompliance was extremely high and that even
those who do add vitamin A and D 26 do not do so all of the time – this,
allegedly applies to even the best known brands (difficult to reconcile with
the heavy marketing the top brands indulge in).
Passing compliance testing was achievable by a certain amount of collusion
with the authorities and an awareness of the distribution of the product into
areas more likely to be subjected to verifiable testing (would not expand
further). A common approach is also to charge for „analytical fees‟
(laboratories do not charge their respective compliance officials).
In deep rural areas vegetable oil and vanaspati/banaspati is frequently
adulterated with used cooking oil (most of which is being imported for the
soap industry and „leaking‟ into the market) and with chicken oil (made from
the offal etc. of chickens). Blending in 5-10% of each into regular oil and oil
products and the adulterant „disappears‟. Customs Intelligence apparently
estimated that 63,000 MT of „adulterant‟ leaked into the system in 2013.
According to PVMA „everyone‟ knows about this as it is frequently in the
media –“but competition rules” -and that in Karachi the authorities are being
intimidated as even the low cost of fortification generates millions of Rupees
due to the scale of operations. Under filling is also alleged to be common as
is the use of mineral oil 27, most often in so called “loose oil”.
26
Vitamin D is not required by either a Pakistan Standard or any Government legislation. Refineries where not aware of the reason they were adding vitamin D – which is probably because vitamin A +D is the most common oil fortificant worldwide and is, usually, cheaper and more readily available than vitamin A on its own. 27
This form of adulteration is highly toxic.
Final 291214 – Wheat and Oil Industry Pakistan Page 68 of 80
Approximately 350 brands are licensed in Pakistan.
Karachi has 11 major refineries who are “interdependent” and usually
involved in joint ventures with operations in Malaysia.
Pricing is highly dependent on the world market and 60-70% of the
membership have a minimum base price they will not fall below which goes
someway to explaining consumers accepting knowingly adulterated oil which
can sell at Rs85-90/Kg against a commercial product at Rs160/Kg 28. An
example was given of a domestic worker taking home used cooking oil from
their employer as it was better than what they could get at home.
Adulterated oil is most commonly used in manufacturing/lower end
restaurants and street food i.e. indirect consumption. Purchasing power is a
significant factor with 70% of population apparently living on less than USD
1/day.
PVMA declined to facilitate
any meeting with members
nor would the Secretary
permit Mr Faiz speak directly to Board members at a future Board meeting –
but if Mr Faiz put in writing what he wished to put before the Board the
Secretary would study it to see if warranted the Boards attention.
Food Department – Punjab
A group of approximately seven managers of the Food Department attended
the meeting and advised they took the NNS 2011 very seriously and the
Director stated they were fully committed to this initiative and would be
willing to cooperate in whatever way they could.
The Food Department has multiple inter-linked functions:
Approve the wheat release price and set the wheat flour price
Purchase of wheat whilst the millers are taking up all they can procure
(available finance being the limiting factor followed by storage)
Procurement takes place during harvest period (mid April to mid June)
Procurement protects the farmers against the financial impact of a
bumper crop
Develop strategic wheat stocks
o Strategic reserve is circa 3.7m MT and
o Release a similar quantity during September to April
Monitor, and enforce, the price of wheat flour to ensure price stability
28
Later in the interview these numbers changed to Rs120 and Rs200 respectively (in line with supermarket prices seen).
Identified risk factor – PVMA Secretary antagonistic
Final 291214 – Wheat and Oil Industry Pakistan Page 69 of 80
The latest pricing in the Food Department indicates:
Purchase price Rs 1,200/40Kg (Maund) 29
Overheads and storage take price to Rs 1,520 – 1,580/40Kg
Selling price Rs 1,330 to 1,340/40Kg
Difference is Federal Government subsidy circa 10-15%
The Food Department admitted that wheat quality was a weak area (from
poor yields to poor milling characteristics). Standards are set using the „Fair
Average Quality‟ (FAQ) system though implementation is “weak” except for
on the moisture which is “strictly kept” 30 at 10 -11%. Impurity levels in the
grain was “not so strictly
implemented” 31 and whilst
up to 3% was the norm the
Food Department would accept up to 5% to favour the farmers as this was
an “environmental factor” [80% of wheat is grown under irrigation but out
dated practises apparently result in a 25% loss of water before reaching the
fields]
Pakistan has no mechanical driers so grain is spread in the fields to dry 32;
the grain is then stored under cover and “checked weekly” with fumigation
on a reactive basis (due to regular checks fumigation is rarely required)
Current storage capacity (according to the Punjab Food Authority) in the
country for the strategic reserve is inadequate at circa 50% (2m MT) in silos
and the rest in bags under tarpaulin – though the storage areas are mainly in
the production areas.
The Food Department has no real idea of the number of farmers in Pakistan
(or Punjab) but the approximately 4m MT they collect comes from circa
300,000 farmers. It is a political policy that the Food Department
target/support small farmers (80% of farmers in Punjab farm on < 2
hectare).
The wheat price is set in February/March and is arrived at after considering:
Inputs from the Provincial Governments
Incentive to produce to the farmers
Cost including inputs
Impact on the flour price
29
Traditional unit of mass. Formed basis of metrication in India and Pakistan and is defined as exactly 37.3242Kg 30
The milling industry would disagree with this statement 31
It can be argued that is a direct cause of having a FAQ and a No Loss policy with poor quality management – leads to deliberate addition of impurities to maintain a zero loss of grain on the books 32
Once dry soil and stones can be ‘accidently’ swept up with the grain
Identified risk factor – wheat grain supply and quality
Final 291214 – Wheat and Oil Industry Pakistan Page 70 of 80
The Federal Government does take into account the export parity but it
should be borne in mind only Government can export wheat.
Despite the „bias‟ towards the producers the main source of complaint comes
from the farmers
themselves and, as a
result, the farmers
have a tendency to
grow for themselves and not for the commercial market.
According to the Punjab Food Department of the 19m MT produced circa 4m
MT is taken up by them, about 1.5m MT by Pakistan Agricultural Storage and
Services Cooperative (PASSCO), circa 2m MT is traded at harvest time and 8-
9m MT is retained. From the crop some 70% of the crop is being retained at
village level, some for seed 33 (circa 10%) and the rest for own use and/or
later trading. Visual inspection of the wheat indicates that it is a spring type
wheat but the agricultural practise is a winter wheat protocol.
The Food Department Punjab advised they have three (3) laboratories
through its nine (9) Divisions and samples are sent to the nearest laboratory
with the results submitted to Lahore to be checked against the Standard.
The Food Department expressed they were 99% satisfied with the quality
and recognised that most deviations (from the moisture maximum) was in
December and due to the seasonal rains.
Recently the Food Department has started to become stricter on supply times
from the farmers who, having been contracted to sell at a fixed price to the
Food Department, find the spot market price is higher renege on the
contract. Additionally „middlemen‟ are buying from the smaller small farmers
to generate a consolidated consignment for the millers – this invariably
means that the producer is not benefiting from the price control system (as
the price the miller is prepared to pay is the limiting step).
Food Department - Karachi
Sindh Food Department was thought to store circa 1.5m MT and PASSCO a
small uptake meaning Government total wheat holdings approximate 7.5 to
8m MT
Policy and Strategic Planning Unit (PSPU) – Lahore
PSPU described the NNS 2011 as “alarming” and that a multi-sectorial plan
was being developed integrating the sectorial plans of both Health, Food and
Agriculture – in the light of probable (as in the reason for this assessment)
fortification initiatives these plans would need tweaking to ensure maximum
impact.
33
Continuously keeping part of the crop back for next years seed is a major factor in the poor yields being achieved
Identified risk factor – if grown on a semi subsistence basis the
wheat will be Chakki milled and extremely difficult to fortify
Final 291214 – Wheat and Oil Industry Pakistan Page 71 of 80
PSPU has the main coordinating role – but seemed unsure of what and how
to coordinate – and recognised consumer awareness of nutrition and
fortification in particular was an
unknown and, according to
PSPU, a local study should be
commissioned (by the donors!!)
and that a deeper
understanding of the supply
chain was required (ditto).
PSPU noted that it was recognised Pakistan Standards and Quality Control
Authority (PSQCA) had outdated Standards that were not being used and in
need of review. According to PSPU legislation could be ready in a month.
Mr Munawar (GAIN) advised the Punjab Food Authority is working on revision
of standards of fortified wheat flour and fortification could be made
mandatory through amendent in the rules as an alternative to legislation. As
per Punjab Food Authority, enforcement of revised standards would require a
lead time of 12 months. For M&E an Egyptian model was being investigated
and it could potentially be replicated in Pakistan.
Planning & Development Department (PND) – Government of Punjab
Interview led by Mr Munawar and Prof Anjum.
Prof Anjum provided the scope of the assessment whilst Mr Munawar
requested support into understanding why the low level of compliance in the
vegetable oil industry and how to address industry practises and gain a
knowledge of industry insights.
PND asked if fortified and unfortified products would be both available and it
was reiterated (from the scope already given) that there would be a grace
period of 12 months in which capacity would be built
The advice of PND was to seek industries‟ opinion of legislation and overcome
their (industries) fears 34 etc. rather than change legislation; then contradict
themselves with advice to go to the
Provincial Governments and institute
separate legislation or alter the Food Rules
to incorporate wheat. PND could give strict
instructions to adopt the fortification
amendments.
PND advised that a media campaign would be required targeting millers and
consumers -but took the point no further.
34
Industry has no fear of the current legislation as it is either not enforced (oil) or is not in place and required (wheat).
Identified risk factor – May require being ‘advised’
on what coordination is desirable/required. The
health department was keen to determine their
role for wheat flour and Oil and Banaspati
fortification initiative.
Identified risk factor – appear
weak and may require being
‘advised’ on what planning is
desirable/required
Final 291214 – Wheat and Oil Industry Pakistan Page 72 of 80
Of major concern was that early in interview PND was firmly of the opinion
that fortification would (not
might) change the sensory
attributes of wheat flour. When
asked for the evidence supporting
this assertion PND was more
circumspect and admitted this was something that they had been advised
about but had not seen any evidence for or against the sensory change.
Consultant Randall has provided Prof Anjum and Mr Munawar with peer
reviewed publications over a number of years supporting the position that no
sensory changes occur when fortification is carried out within scientifically
accepted norms (as are proposed for Pakistan) and/or at levels of inclusion
significantly higher than those proposed for Pakistan (Nigeria 40 ppm iron as
NaFeEDTA). These publications have been forwarded to PND by Prof Anjum
and Mr Muawar
PND also cautioned that misperception was a problem in Pakistan citing the
Polio issue (linked with contraceptives) and consumers insisting on being able
to access non-iodised salt. PND, however, had no suggestions as to how
these „bad‟ messages were originating or being disseminated.
Nutrition Planning Commission NPC – Islamabad
NPC is the Stepping Up Nutrition (SUN) focal point.
NPC was of the opinion that the oil industry was not cooperating despite the
fact that in 1965 when fortification of oil was made mandatory the price was
adjusted to accommodate fortification 35. This, NPC, believe was due to lack
of monitoring and in 1998 advised that 50% of tested samples had no
vitamin A and 10% were inadequately fortified.
NPC advised that costing, on both vehicles was a significant issue with pricing
of staple foods being regularly raised in the Supreme Court – with the
intention of keeping prices down. Prices do, however, vary between cities
and provinces.
Supplementation, fortification and bio fortification are all programmes
fortification that Pakistan is putting
considerable faith in – particularly the
zinc wheat bio fortification (discussed
later).
NPC also consider dietary diversification to be an attainable goal.
NPC advice is that consumers are
aware of nutrition factors from the
35
Mr Faiz (GAIN) advised the Government also paid for the necessary changes to the label.
Identified risk factor – zinc efforts placed
almost entirely on bio fortification
Identified risk factor – PND appears not to
require substantive evidence before proceeding
with action and/or policy
Identified risk factor – contradiction in level of
consumer awareness
Final 291214 – Wheat and Oil Industry Pakistan Page 73 of 80
label but consumer awareness was a matter constantly under discussion.
They also advised that it would be necessary to deal with “top people very
carefully”.
Pakistan Standards and Quality Control Authority (PSQCA) - Karachi
Discussions held with the Director (Agri & Food) Standards Development and
Director Quality Control Center (South).
PSQCA covers >30,000 Standards (72 mandatory) of which 565 related to
food items (42 food
products are mandatory).
Of importance is that:
PSQCA is Federal
Imports and Exports must follow the relevant PSQCA Standard (if
existing) 36
Samples are only taken if
o The Standard is mandatory or
o The Standard Mark is being used
Standards are adopted from ISO, IEC, CODEX (most Standards are
harmonised with Codex)
Should CODEX be updated the national Standard remains in place until
the Standard is updated 37
ISO/IEC Guide 21 has been adopted in Pakistan
Approximately 800 food samples were analysed in the past calendar year by
the laboratory that serves two „masters‟:
Conformity Assessment Division –compliance testing
Quality Control Center – providing an analytical support to industry on
a pay for service basis
PSQCA provides results to the relevant party without interpretation but do,
importantly, provide analytical uncertainty at 95% confidence.
Vitamin A is tested on a qualitative basis (basically the short Carr Price
reaction with Antinomy trichloride) only and they have had very few failures;
36
Theoretically this could create a Technical Barrier to Trade (TBT) as imports must follow PSQCA whereas local companies could argue they are following Provincial (which is in its own right a Government under the 18
th Amendment of the Constitution) law i.e. Punjab Food Rules 2011. Opinion is divided on whether
the Punjab (Provincial Government) Food Rules, for example, take precedence over National (Federal Government) Standards though they the different pieces of legislation do try to be complementary 37
Alteration of a Standard can take between 3 and 12 months depending on the complexity
Identified risk factor – many Standards outdated, in
conflict with CODEX and with Provincial legislation
Final 291214 – Wheat and Oil Industry Pakistan Page 74 of 80
whereas Peroxide Value (PV) and Free Fatty Acids (FFA) are accredited under
the Pakistan National Accreditation Council (PNAC) 38
Pakistan Standards and Quality Control Authority (PSQCA) – Lahore
This visit was primarily to gain access to some refineries in the area. PSQCA
– Lahore confirmed that Peroxide Value (PV) and Free Fatty Acids (FFA) are
accredited under the Pakistan National Accreditation Council (PNAC) and the
reason it was not on the PANC website is that “it has not been put up there
yet”.
Advised that PSQCA have a quarterly visit schedule (inspection plans exist
but not seen), the qualitative test is used for vitamin A – 70 samples tested
in the last year with no failures.
Standing Committee Commerce & Investment – Punjab Assembly
Introduced by GAIN Country Director Sajjad Imran. Ramesh Singh Arora,
Chairman of the above Committee indicated he was aware of many of the
issues relating to fortification and the problems a National Programme was
facing. GAIN was more than welcome to approach him personally as a
means to expediting any nutritional intervention and he would see that the
matter was brought before the Committee as appropriate.
Pakistan Council for Scientific and Industrial Research – PCSIR
Discussions held with the Director in charge of the laboratory and the
Director General.
Most of the laboratories at PCSIR have achieved ISO 17025 accreditation
since 2003 on at least some methods. In total PSCIR has 278 accredited
analytical methods. To date these do not include vitamin and mineral
analysis though the Director General was willing to look at applying for an
„extension of scope‟ which would then bring vitamins and minerals under ISO
17025 (some technical and financial support may be required). Interest was
expressed in getting involved as a service provider from fortification to
complementary foods.
PCSIR run training programmes capable of being applied to 1 to 250
delegates and boast 20 lead auditors in various aspects of ISO 17025 as well
as 50 highly trained in in ISO 17025.
Originally under Norwegian Accreditation PCSIR now falls under the Pakistan
National Accreditation Council (PNAC) which was launched during the year
2001. PNAC achieved a milestone of Mutual Recognition Arrangement (MRA)
with International Laboratory Accreditation Cooperation (ILAC) and Asia
38
No reference to PSQCA could be found on the PNAC website http://www.pnac.org.pk/index.php?PageId=87
Final 291214 – Wheat and Oil Industry Pakistan Page 75 of 80
Pacific Laboratory Accreditation Cooperation (APLAC) in 2009 and MLA status
in 2013. Pakistan is now included in the list of countries having equivalent
status for accreditation of testing & calibration laboratories and certification
bodies for QMS & EMS all over the world.
PSCIR expressed interest in immediately procuring iCheck Chroma3
(information on system provide to PCSIR via Prof Anjum)
A suggestion from the Director General was that implementation, within
Pakistan, would be best carried out using local NGO‟s etc.
METRO Superstore Discussions with the floor manager of a local superstore in Lahore indicated
the store carried up to 130 different types/brands of combinations including
their own two brands. On wheat flour they only carried their own brands.
As a typical major superstore they have their own laboratories and food
technologists (most from under Prof Anjum tutelage) and they do conduct
extensive audits on their own label products and have their own quality
specifications. Metro has not experienced any problems with vitamin A in
their labelled products.
Within the store it was noted that labelling used terminology such as “added”
and “enriched” with some declaring quantities on the label. Common
labelling practise was 33 IU/g vitamin A, 2.6 IU/g vitamin D and some also
claiming 60µg/Kg of vitamin E. Sometimes this would be accompanied by
nutritional claims such as vitamin A 45%
RDI, vitamin D 50% RDI and vitamin E
15% RDI. Additional to this products
frequently used the claim “0% cholesterol” or “cholesterol free” compounding
the observation that serious attention needs to be spent on labelling laws
and nutritional claims.
Current Prices Consumer Groceries Pakistan
On-line shopping provides some indication of current food prices
http://www.pakistangrocery.com/send-grocery-to-pakistan162.htm
Jamia Tur Rashaid
Use of „role models‟ and „people of influence‟ is common in fortification
advocacy – the above Institution is dedicated to multi-disciplinary studies of
Shariah based on Halaal awareness and combines religious studies with
„conventional‟ higher education (accounting, business studies etc.) and is well
respected internationally. The institution charges no fees (even provides
Identified risk factor – labelling laws
Final 291214 – Wheat and Oil Industry Pakistan Page 76 of 80
students with a small stipend) and has a current student base of circa 2,500
most of whom are in residence. Funding is from private donations.
The institution would be highly influential in any communications campaign.
The institution also has its own publications 39, targeting women and children 40, called „The Truth‟ and expressed interest in disseminating nutritional
messages 41 suitably written for the intended age group. They also have a
Facebook page and a worldwide computer network.
Of great significance is that senior executives of the Institution suggested
that Friday prayers could include components which corrected misperceptions
and/or discuss the benefits of fortification.
During discussion with faculty members it became clear they recognised the
lack of awareness, belief that millers/refineries were impacting on quality
(negative connotation), profit was a prime motivator and that demand
creation would have to be addressed; and that they would be willing to
participate within the jurisprudence of their faith.
TechnoMight Engineers – Faisalabad
Local company that has been involved in the wheat fortification programme
since the beginning as millers and then became involved in studies (some of
which were under Prof Anjums‟ leadership) in Chakki mill fortification and
designed small scale micro feeders, which, according to them, worked „well‟,
for the project.
Currently they have a conventional size micro feeder which is a „reverse
engineered‟ version of the one supplied by American Ingredients to a few
(very few) millers originally involved. This micro feeder is commercially
available but sales have been very low.
During discussion with the engineers modern concepts in micro feeder
technology were discussed and the company undertook to taken them into
consideration (feeder requirements for Pakistan are discussed later).
39
Gallop estimate readership to be 1.8m for the women’s magazine and 2m each for the children’s magazine in English and Urdu 40
http://www.thetruthmag.com/ 41
Consultant Randall was requested to write suitable ‘stories’ for the magazine – which he look to do – but only to be published when the advocacy campaign starts. Editor understood the importance of timing.
Final 291214 – Wheat and Oil Industry Pakistan Page 77 of 80
Annex 4 – Mean Squares Statistics Dr. Farhan Saeed; Assistant Professor; Department of Food Science; Institute of Home and Food Sciences; Government College University,
Faisalabad-Pakistan, observed, using mean squares the following:
Iron
The iron content in flour and grain samples of different chakkies and mills
regarding different regions have been presented in Table 1. Mean squares depicted that iron content varied significantly among different regions. In
addition, interaction among flour and grain was also found significant. The iron content in flour of different chakkies in various regions ranged from 39.43 to 43.86 ppm while it ranged from 45.57 to 47.54 in grain samples of
different chakkies.
The iron content was recorded significantly high in wheat flour sample of chakki existed in Baluchistan region (43.86 ppm) followed by flour of chakki
present in South Punjab and Sindh regions (39.92 ppm) but with non significant differences for iron content among North Punjab (39.43 ppm),
central Punjab (39.43 ppm) and KPK regions (39.63 ppm). Moreover, the iron content in grain samples of different chakkies regarding different regions varied significantly and found highest in grain samples of Sindh region (47.54
ppm) and South Punjab region (47.54 ppm) followed by grain samples of North Punjab region (46.08 ppm), Central Punjab region (46.08 ppm) and
KPK region (45.57 ppm). The grain samples did not procure from the chakkies existed in Baluchistan region. It is also obvious from the results that iron content in flour and grain samples of different flour mills regarding
different regions was found significant and interaction among flour and grain samples was also explicated momentously. The iron content in flour samples
of different flour samples regarding different regions ranged from 38.86 to 46.10 ppm and it varied from 42.47 to 52.94 ppm in grain samples of Flour mills. The iron content was observed significantly high in flour sample of
different flour mills existed in Baluchistan region (46.10 ppm) followed by flour of mills present in North Punjab (43.28 ppm) and North Punjab regions
(43.28 ppm) but with non significant differences for iron content among Sindh region (41.01 ppm), South Punjab (41.01 ppm) and KPK regions (38.86 ppm). Furthermore, the iron content in grain samples of different
flour mills regarding different regions varied significantly and found highest in grain samples of both Central Punjab and North Punjab region (52.94 ppm)
followed by grain samples of South Punjab region (50.02 ppm), and Sindh region (50.02 ppm). The iron content was explicated lowest in grain samples of flour mills collected in KPK region (42.47 ppm). The wheat flour containing
higher amount of iron content is beneficial to the population suffering with anemia which may help to alleviate iron deficiency anemia (IDA). Iron
deficiency anemia reduces a person‟s ability to perform physically demanding tasks and anemic laborers have demonstrated productivity.
Phytic Acid
Final 291214 – Wheat and Oil Industry Pakistan Page 78 of 80
The phytic acid content in flour and grain sample of different chakkies and mills collected from different regions of Pakistan have been presented in
Table 1. Mean squares depicted that phytic acid content assorted significantly among different regions. In addition, interaction among flour and grain was
also found momentous. The phytic acid content in flour of different chakkies in various regions ranged from 0.82 to 0.86% while it ranged from 0.82 to 0.99% in grain samples of different chakkies.
The phytic acid content was recorded significantly high in wheat flour sample of chakki existed in Baluchistan region (0.86%) followed by flour of chakki present in South Punjab and Sindh regions (0.85%) but with non significant
differences for phytic acid content among North Punjab (0.83%), central Punjab (0.83%) and KPK regions (0.82%). Moreover, the phytic acid content
in grain samples of different chakkies regarding different regions varied significantly and found highest in grain samples of Sindh region (0.99%) and South Punjab region (0.99%) followed by grain samples of KPK region
(0.94%), Central Punjab region (0.83%) and North Punjab region (0.82%). The grain samples did not procure from the chakkies existed in Baluchistan
region. It is also obvious from the results that phytic acid content in flour and grain samples of different flour mills regarding different regions was found significant and interaction among flour and grain samples was also explicated
momentously. The phytic acid content in flour samples of different flour samples regarding different regions ranged from 0.78 to 0.88% and it varied
from 0.90 to 1.03% in grain samples of Flour mills. The phytic acid content was observed significantly the maximize in flour sample of different flour mills existed in KPK region (0.88%) followed by flour of mills present in
South Punjab (0.84%) and Sindh regions (0.84%) but with non significant differences for phytic acid content among Baluchistan region (0.83%), North
Punjab region (0.78%), and Central Punjab (0.78%). Furthermore, the phytic acid content in grain samples of different flour mills regarding different regions varied significantly and found highest in grain samples of Baluchistan
region (1.03%), followed by South Punjab (1.02%), Sindh region (1.01%). The iron content was explicated lowest in grain samples of flour mills
regarding KPK region (0.90%) and Central Punjab (0.90 %).
Table 1: Iron and Phytic acid contents of flour and grain samples of chakkies and flour mills regarding different regions
Iron Content (ppm) Phytic Acid (%)
Regions Chakki Flour Mills Chakki Flour Mills
Flour Grain Flour Grain Flour Grain Flour Grain
Baluchistan 43.86 0 46.10 48.19 0.86 0 0.83 1.03
Final 291214 – Wheat and Oil Industry Pakistan Page 79 of 80
KPK 39.63 45.57 38.86 42.47 0.82 0.94 0.88 0.98
Central Punjab 39.43 46.08 43.28 52.94 0.83 0.83 0.78 0.90
North Punjab 39.43 46.08 43.28 52.94 0.83 0.82 0.78 0.90
Sindh 39.92 47.54 41.01 50.02 0.85 0.99 0.84 1.01
South Punjab 39.92 47.54 41.01 50.02 0.85 0.99 0.84 1.02
Draft FIVE Wheat and Oil Industry Pakistan Page 80 of 80
Figure 1: Iron and Phytic acid contents of flour and grain samples of chakkies and flour mills regarding different regions
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