Policy Study on

Improving the Quality Of Agricultural Inputs In Bangladesh

Dr. Zahurul Karim

INTRODUCTION Quality inputs play a vital role in productivity enhancement in agriculture necessary for food security, employment and economic growth of the land hungry country-Bangladesh

Population : 161 m. ha

Cultivable land : 8.57 m.ha

Per capita available land for cultivation: 0.05 ha.

Sectoral GDP Growth Rate

Study Methodology a. Reviewing existing policies, rules, acts and laws governing quality control

of agricultural inputs;b. Reviewing quality control system and capacity & capability of

implementing and regulatory agencies; c. Focus group discussions with different stakeholders;d. Consultation workshops with the policy makers and experts in the

relevant sub-sector;e. Data processing, analysis and interpretation;f. Draft report preparation and validation; and g. Final report submission

Study Objectives a) To identify laps and gaps of the regulatory policies, rules and regulation

for quality control of inputs (Seed, Fertilizers, Pesticides, DOCs, Fish Fingerlings and Fish & Animal Feeds);

b) To assess the strength and weaknesses of the regulatory and quality control agencies of both public and private sector;

c) To assess sources of adulteration of inputs;d) To suggests measures for remedial actions; and e) To suggest policy, rules and regulation reforms as and where necessary. 

IMPEDIMENTS IN IMPLEMENTATION

FERTILIZERi) Government of Bangladesh has promulgated a number of acts, rules to increase

availability of quality fertilizers. those rules and acts have some limitations and gaps:

Fertilizer Act, 2006 and Fertilizer Rules, 2007 provided outline and procedures for fertilizer quality management and standardization without substantial instruction for quality control, analysis, fertilizer ingredients and the standard of laboratories.

MoA fixed specification for major fertilizers through a notification, but not specified limit of the presence of heavy metal and physical impurity.

The Fertilizer Management Act, 2006 and subsequent modification of Fertilizer Rules in 2007 provides some guidelines and procedures for fertilizer quality management and standardization, but not provided substantial instructions on fertilizer quality analysis, fertilizer ingredients and the standard of laboratories.

The amended Fertilizer Rules, 2007, provided some guidelines for fertilizer inspection but method of inspection and support of portable analytical facilities essential to detect the permissible level of contamination is not provided.

ii) Six agencies with labs. entitled to analyze both locally produced and imported fertilizer analysis, are engaged in research & teaching but not mandated for farmers’ sample analysis. Moreover, the capacity of these Labs, are meager compared to national need. Analysing quality of these labs. are often questionable indicating poor standardization, non-maintaining of reference sample and poor cross-checking of analysed data.)

IMPEDIMENTS IN IMPLEMENTATIONFERTILIZER (contd.)Iii Some of the weaknesses of analytical institutions and systems for quality

management of fertilizers are: Absence of idependent and analytical laboratory to serve as reference tool

for all other testing laboratories. There is no unified analytical methods, procedure and standardization of

sampling and testing, approved by AOAC. maintenance of spare-parts is a serious problems, often these are not

available for continious running of the laboratories. Laboratory facilities at port of entries have poor infrastructure and limited

human resource and qualified technicians. Instead of an inspection committee, fertilizer samples are being collected

from the foreign consignment by unprofessional and lower level staff.vi) Laws, rules and regulations do not guarantee availability of quality

fertilizer in the field because: Field offices are not equipped with required testing devices for rapid

determination of fertilizer quality; Absence of qualified field inspectors at Upazila level for effective field

inspection.

IMPEDIMENTS IN IMPLEMENTATION (Contd)

SEED

i) Seed quality is governed by a plethora of policies, acts and rules in

Bangladesh. But due to some gaps and inconsistencies between policies, acts

and rules as well as in competencies of regulatory agencies, seed quality

control is jeopardized and development of private sector is hampered. These

are:

Shortage of Breeder’s seeds affecting quality seed production in

Bangladesh. NSP, 1993 offered but Seed Act,2005 restricts private sector to

develop new varieties of notified crops and getting approved from NSB;

Despite NSP prohibition adulterated seeds, seeds without appropriate

containers/packages & labeling without NSB specifications and with

fictitious or duplicate label of reputed companies are found to be sold in the

markets;

No seed health standards are specified in the country;

SCA, the public sector regulatory agency is suffering from acute shortage of

qualified, and experienced man power of their own and other physical

facilities.

No indication about infrastructure requirement for TLS production in the

Seed Rules,1998;

•Procedures delineated in “Hybrid Rice varieties evaluation and release

procedure, 1998 (amended in 2003 and 2007)” is rather complex and time

consuming;

•There exists contradiction between PQR Act, 2011 and Import & Export

Policy of the Ministry of Commerce for import-export requirement and seed

trading;

ii) Bangladesh has neither any procedure laid down nor any ISTA accredited

Laboratory which deterring seed export.

IMPEDIMENTS IN IMPLEMENTATION (Contd)

PESTICIDES

i)The entire process of pesticide production, import and trading are done by private sector in Bangladesh;ii)Pesticide rules, regulations, and acts promulgated by the government provide basic framework for the regulation and control of pesticide quality. Though there are sufficient rules and regulations for the purpose a number of limitations exists for proper implementation of the regulations. These are as follows:iii)Mandatory guidelines of FAO for labeling, handling, storage and transportation of pesticides are not followed in Bangladesh, and pesticides rules have no penalty clause for such misdeeds.iv)There are insufficient facilities in the private sector for pesticide storage; quality analysis;v)There is a dearth of laboratory analytical procedure, pre-shipment inspection (PSI) and labeling.vi)Recent acts and rules have not specified the punishment/ penalty, disposing procedure of pesticides found not to conform with required standard. vii)Most of the pesticides industries in Bangladesh do not maintain a laboratory, if maintain lack necessary laboratory equipments, technical manpower to ensure its product quality as per FAO International Code of Conduct.viii)Post-registration surveillance to ensure that the registered product is properly handled, distributed and to ensure enforcement and monitoring of the actual use of product is weak and less credible in Bangladesh.ix)There is no field testing facilities for pesticide’s residual value analysis in the country; one small laboratory located at DAE, under the MoA is largely inadequate to support pesticide analysis;viii) For quality monitoring no field level analytical facility is available to provide on the spot guidance to field inspectors. Pesticide rules,1995 and subsequent modifications ignored this important area.

IMPEDIMENTS IN IMPLEMENTATION (Contd)FISH& A ANIMAL FEED, DOCs, FISH FINGERLINGS

Fish & Animal Feeds

i)Policy and regulatory system for quality control fish and animal feed in

Bangladesh is at infant stage.

ii)Recently developed policies and regulations are National Poultry

Development Policy, 2008; Fish and Animal Feed Act, 2010; Fish Feed

Regulations 2011; and Animal Feed Regulation Act (Draft), 2013.

iii)There are visible gaps inconsistencies in the policy formulation and

deficiencies in regulatory framework for efficient quality control of feeds in

Bangladesh.

There is no provision for microbiological control of animal feeds in the Fish

and Animal Feed act, 2010 particularly of salmonella control;

The Fish and animal Feed Act, 2010 listed the reference laboratories but

most of the laboratories have little facilities regarding procedure,

guidelines/manual, standard protocols and efficient man power to

accomplish the task, manpower particularly for the determination of

ingredient physical properties and other adulterations.

The Fish and Animal Feed Act, 2010, did not specified laboratories for specic

tests.

In the Fish and Animal Feed Act, 2010, feed Manufacturing practices are not

defined and there is no rules for GMP(Good Manufacturing Practices).

In Animal Feed Regulation(Draft), 2013, there also no indication about

specific methods for testing;

Animal feed regulation yet not finalized. Therefore, strict monitoring for

quality control of animal feeds yet not started;

Feed Act and Animal Feed Regulation (Draft), 2013, does not categorized

the antibiotics, hormones and other restricted items.

No specific guidelines have mentioned on feed regulations to identify

porcine materials or other residuals in animal proteins.

IMPEDIMENTS IN IMPLEMENTATION (Contd)

FISH& A ANIMAL FEED, DOCs, FISH FINGERLINGS (Contd)

Day-Old Chicks

i) National Livestock development policy, 2007 has provided guidelines to

supply quality DOCs without indication of husbandry practices and

pathological conditions necessary for breeding flock for quality chick

production.

ii) National livestock policy,2007 also provided no guidelines for handling

hatching eggs, establishing quality chicks.

iii) Poultry Policy does not illustrates the form of physical deviation and

detailed lay out or protocols for disease free DOCs.

iv) Animal Disease Regulations, 2011, has setup conditions for starting grand

parent farms, parent stock farms, and commercial farms so that for disease

free DOCs production. However, the implementation arrangement for

quarantine of DOCs is not illustrated in the regulations.

v) There is no provision for guidelines in the poultry development policy for

handling and transportation of DOCs which affects in the mortality rate of

DOCs in the rearing farms.

vi) There is no specific indication in the National Poultry Policy regarding bio-

security in the breeding farms and hathery units.

vii) There is an absence of rules and regulations for the prevention and

control of Avian Influenza (AI) outbreaks.

Fish Fingerlings i) Fish fingerlings are produced and marketed by both public agency- DoF and private enterprises. Fingerlings quality is still over looked in the hatcheries owned by private enterprises. ii) Amongst the fishery rules and regulations promulgated by the government Hatchery Act, 2011, provides methods of fingerlings production. The acts has the following gaps: There is no provision in the hatchery rules for the tests of water pH, hardness, total ammonia nitrogen and water changeover rates, required water flow and disease management; Methods or detection protocols for the identification of traceable elements are absent/

iii) No provision for the identification of hazards and defects in fingerling

production

KEY FINDINGS AND RECOMMENDATIONS

FERTILIZER Specification of the fertilizer materials need to be periodically reviewed

through a national committee. It is necessary to re-evaluate maximum limit of heavy metal

contamination based on analytical facilities in different laboratories. Quality control for fertilizer requires standardization, analysis of fertilizer

materials, field inspection & monitoring and punishment of unscrupulous traders.

It is necessary to setup an Independent Accredited Laboratory with adherence of several field laboratories.

For inspection and monitoring, a strong national system need to be established to enforce the implementation of fertilizer Act. 2006. DAE and SRDI should be strengthen to jointly conduct field inspection and testing.

The authority of the inspector should be strengthened and simplified removing the existing complexcity in the Act, 2006.

The government of Bangladesh should set up Mobile Courts in different regions for awarding exemplary punishment for unscrupulous traders, manufacturers, importers and dealers.

 

KEY FINDINGS AND RECOMMENDATIONS (Contd)

SEEDS i) to increase national food grain production from existing 32 million tonnes

to 35 million tonnes, the SRR must be raised up to 30 percent through building infrastructure and capacity improvement of NARS institutes, public and private sector agencies for BS and FS production.

ii) The existing anomalies between NSP, 1993; the Seed (Amendment) Act, 1997; the Seed Rules, 1998 and the Seed (Amendment) Act, 2005 for the development and release of new varieties of notified crops, seed standardization and seed certification must be removed and updated.

iii) Capability and capacity of SCA should be improved with its own qualified manpower, requisite infrastructure and physical facilities.

iv) For creating database with dependable information regarding the quantity and quality of seeds uses by farmers, regular survey similar to “ drill-box” as has been done in other developed countries should be carried out in Bangladesh.

KEY FINDINGS AND RECOMMENDATIONS (Contd)

PESTICIDESi) Pesticide licensing, registration, trading, monitoring and marketing should be

managed and supervised by an independent agency.ii) Post registration activities should be strengthened . iii) Technical materials are either produced locally or imported should conform to the

specifications of FAO or WHO and a valid certificate of analysis must accompany each sale of the technical material.

iii) At port of entry professional team should visit the material and arrange quality evaluation through well established laboratories at the port.

iv) One national laboratory doing analysis for standardization is highly inadequate. The procedure and facilities for sampling from the farmer’s field for analyzing the residual value need to be included in pesticide Rules, 1995 and in the Pesticide Act, 2007.

iv) The inspection and analysis of domestically produced product must be strengthening.v) Necessary Laws should be introduced by the parliament for awarding punishment for

the unscrupulous traders .vi) Pesticide rules need to be revised to provide adequate support for toxicological

analysis of pesticide and environmental friendly disposal of harmful materials (by-products etc).

vii) To ensure product quality and specifications through internationally accepted laboratory test methods, it is necessary to maintain a laboratory with sufficient equipment and efficient manpower.

KEY FINDINGS AND RECOMMENDATIONS (Contd)

FISH AND ANIMAL FEEDS, DOCs, AND FISH FINGERLINGS

Fish and Animal Feedsi) A quality control laboratory need to be established with all sorts of facilities for testing

fish and animal feeds.ii) Reference laboratories should be specified for specific type of analysis particularly for

the identification of mycotoxins and adulterations presence in animal feeds.iii) Laboratory tests facilities should be extended to the regional level and ensure farmers’

access to the tests facilities.iv) Provisions should be made on the Fish and Animal Feed Act 2010 regarding GMP in the

commercial feed mills, and protocols for GPM should be described in feed regulations.v) Government needs to set up adequate quality control mechanism for ensuring good

quality feed to the customers.vi) Necessary Infrastructure facility and manpower need to be developed for quality

control of feeds. DOCsi) Hatchery Act and Guidelines should be formulated by the government covering quality of

hatching, incubation, handling, transportation of DOCs.ii) Bio-security and surveillance should be strengthened for quality DOCs production in the

country.iii) Strong institutional support in all phases of development should be ensured and

adequate manpower should be employed where necessary. Fish Fingerlings i) Hatchery rule should be supported by an operation manual.ii) Provisions for water filling and procedures of pond water curing for fingerling production

should be mentioned on hatchery rules. iii) There needs to develop brood stock bank in the country through Public- Private-

Partnershipiv) Government should establish independent quality control body to monitor and test and

analysis of feeds

THANKS FOR

PATIENT HEARING