GOVERNMENT OF ANTIGUA AND BARBUDA MINISTRY OF … · 2018-07-09 · General Condition of the Barbuda Fisheries Complex Six Months post-Hurricane Irma regarding Export Readiness Page

GOVERNMENT OF ANTIGUA AND BARBUDA MINISTRY OF AGRICULTURE, FISHERIES AND BARBUDA AFFAIRS

FISHERIES DIVISION Point Wharf Fisheries Complex

Lower North Street, St. John’s, Antigua Phone: (268) 462-1372/6106/562-4309

Fax: (268) 462-1372 E-mail: [email protected]

Website: www.fisheries.gov.ag

Parham Fisheries Complex: (268) 562-4920/21 Urlings Fisheries Complex: (268) 562-4917/18 Point Wharf Fish Processing Plant: (268) 562-5737/38

Inspection Report: General Condition of the Barbuda Fisheries Complex Six Months

post-Hurricane Irma regarding Export Readiness Date of Inspection: March 27, 2018 Report Date: April 30, 2018 Prepared by: Ian Horsford, Acting Deputy Chief Fisheries Officer Submitted to: Cheryl Jeffrey-Appleton, Chief Fisheries Officer

In accordance with Section 63 (2) of the Fisheries Act 2006 concerning the safety and quality of fish and fishery products and in keeping with the role of the Fisheries Division as the National Competent Authority for export of fish and fishery products to the European Union (including member states overseas countries and territories), the following summarises the findings of a preliminary inspection conducted Tuesday, March 27, 2018 of the Barbuda Fisheries Complex. This preliminary inspection was initiated in response to a request from EU approved lobster exporters to resume operations (lobster packaging and inspection etc.) from the facility following its closure after the passage of Hurricane Irma in September 2017. The main products handled by the facility prior to the hurricane, included live lobster (Panulirus argus), gutted and scaled fresh fish, and fresh conch (Strombus gigas). In addition, the facility also provided ice and cold storage service to fisherfolks. Since the storm the upper floor of the administration and fish handling building housed personnel from the Antigua and Barbuda Defence Force and the Royal Police Force of Antigua and Barbuda (including personnel from the Fire Brigade). Note the Barbuda Fisheries Complex was one out of four landing sites in Antigua and Barbuda that was in compliance with EU technical specification concerning fish landing sites prior to the hurricane; the other approved sites were Point Wharf Fisheries Complex, Urlings Fisheries Complex and the Parham Fisheries Complex. The scope of the preliminary inspection included the physical infrastructure and the surrounding environment associated with the facility with emphasis on the key elements of Good Manufacturing Practices (GMP) and Sanitation Control Procedures (SCP) (i.e., the prerequisite programmes for HACCP – Hazard Analysis Critical Control Point). HACCP is a “preventative-based” food safety system that is mandatory for export of fish and fishery products to the European Union, United States of America and Canada and has been adopted by the Codex

General Condition of the Barbuda Fisheries Complex Six Months post-Hurricane Irma regarding Export Readiness

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Alimentarius Commission – the principal body of the Joint FAO/World Health Organization (WHO) Food Standards Programme. Following favourable inspection with respect to the aforementioned, establishments currently approved in Barbuda will be audited to ascertain their status with respect to:

(1) EU food laws including implementation of HACCP (Regulation 178/2002, Regulation No 852/2004, Regulation No 853/2004, Directive 98/83/EC, Regulation No 1881/2006, Regulation 2073/2005, etc.);

(2) EU mandatory catch certification scheme to address illegal, unreported and unregulated fishing (Regulation No 1005/2008 and Regulation No 1010/2009); and

(3) unresolved issues predating the passage of Hurricane Irma (See Annex). In accordance with guidance provided by European Commission Notice C278/2016 regarding HACCP prerequisite programmes (GMP and SCP) and taking into consideration US GMP regulatory requirement (Title 21 CFR Part 110), the following specific areas were addressed during the inspection:

• Infrastructure (including building, grounds and equipment) • Sanitation procedures (cleaning and disinfection) • Pest control – focusing on prevention • Technical maintenance and calibration • Water quality • Air control • Staff training • Traceability and product recall

Note other key areas which require direct observation of plant operations such as staff hygiene, working methodology (e.g., standard operating procedures), waste management, protection from adulterants, maintenance of cold chain, etc., were not addressed due to the fact that the facility was not in operation and the Senior Fisheries Officer for the Barbuda Fisheries Department was not available to facilitate the process despite numerous attempts made by the Chief Fisheries Officer to contact him. The main findings of the preliminary SCP and GMP inspection were as follows:

• The Barbuda Fisheries Complex was descending into a serious state of disrepair which may ultimately affect its status as an EU approved facility for export. Hurricane Irma had inundated the ground floor of the administration and fish handling building with seawater and doors, windows, aluminium shutters and the surrounding fence were damaged by the winds (Figures 1 to 2). Thus far these items have not been replaced or properly refurbished; hence areas such as the grounds were unsecured and horses, donkeys, goats and other animals had littered the area with their faeces making it unsanitary (Figure 3). In addition, a maggot-filled carcass of a dog was left unattended on the grounds highlighting the general lack of supervision of the facility by its tenants (Figure 4). With respect to the administrative building only the main office on the ground floor was locked; the receiving room of the fish handling centre was left unsecured and various elements of other rooms of the facility were in need of repair (plumbing, tiles, fixtures, walls, etc.). The machine room needed serious renovation and number of tools and


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equipment present showed signs of saltwater damage (Figure 5). In addition some of the bin carts, fish trays, insulated fish boxes and other pieces of utensils were also unaccounted for. Note 6 bin carts, 15 fish trays and 15 insulated fish boxes were provided for the facility in 2011.

• In terms of basic sanitation, the entire facility required substantial cleaning and disinfecting. Floors, walls and food contact surfaces had a build-up of dirt (Figure 6) and the cold storage had a “mouldy” offensive odour despite being cleaned and disinfected post-Hurricane Irma; this was due to the putrefaction of hams and turkeys stored in the chiller prior to the storm in violation of standard operating procedures to minimise cross-contamination and avoid the introduction of additional hazards (e.g., Salmonella) beside those associated with fishery products. Fisher-folks’ washroom and showers in current use by tourists visiting the Frigate Bird Sanctuary were in urgent need of cleaning and refurbishing; toilet bowls had faeces and urinals were filthy and rank (Figures 7 to 10). This had negative implications for the quality of the tourism product. Drain pipes from the roof were used to shunt household waste to the ground floor (Figure 11).

• Pest control programme for the administration and fish handling building was inadequate; various areas (receiving room, corridors, etc.) were littered with rat faeces despite some attempts to use baited traps (Figures 12 to 13). Pigeon’s droppings also defaced the walls of the building increasing the risk of cross contamination (Figure 14). Flies were common in the building due to the presence of animal faeces and carcasses on the premises.

• Concerning technical maintenance and calibration, the amount of working hours on the backup generator was cause for concern; the generator on average clocked 18 hours a day for the past six months without a major maintenance overhaul. The specification on the generator provided for the facility was for a much lighter workload (e.g., an electrical blackout not exceeding 7 days). Whilst the cold storage was in working condition, the status of the industrial ice maker was unknown; a major leak in the underfloor plumbing that provided potable water to the machine prevented the equipment from being properly tested by maintenance personnel. Note the absence of ice had serious implications for the safe handling and processing of fresh fish in Barbuda.

• There was an inadequate supply of potable water to the facility and storage of water was unsecure and insanitary; reservoir for APUA (Antigua Public Utilities Authority) water supply and reservoir for rainwater supply from the roof were left open to the elements and there was an accumulation of dirt and debris in both tanks making water treatment (i.e., chlorination) problematic (Figures 15 to 17). Both reservoirs were supplied to the facility along with a filtration and automated (sodium hypochlorite) chlorination system since APUA water falls outside WHO guidelines for drinking-water quality from time to time and the island suffered from protracted droughts. At the time of inspection the filtration and automated chlorination system was not working. Note deficiencies related to the safety of water were considered “critical” under the US Department of Commerce Seafood Inspection Program and establishments shall not be recommended for listing as “approved” establishments; the Canadian Food Inspection Agency (CIFA) and the European Directorate-General for Health and Food Safety (DG SANTE) also followed similar guiding principles.

• In regard to air control, the flow of air in the plant was adequate (i.e., flowing from clean areas to contaminated areas), however the air conditioning unit in the fish handling room


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was not working properly; 16 °C to 20 °C was considered the ideal room temperature, in terms of worker’s comfort and maintaining the cold chain philosophy in the plant.

• HACCP training was mandatory for supervisors, managers and inspectors of fish processing establishments according to various international legislation (EU: Reg. (EC) 852/2004; USA: 21 CFR 123.10; and Canada: Fish Inspection Regulations); however review of Barbuda’s staff training log indicted that none of the personnel had basic HACCP and GMP certification that was current according to international standards (i.e., within the last five years) nor were they a member of any professional food safety organisation. Note individuals whose certification was originally funded by the Fisheries Division have since being transferred to other departments of the Barbuda Council.

• The lack of a “functioning” local fisheries management authority on-island currently precluded the implementation of traceability and product recall procedures essential for exports to the EU, USA and Canada. Specifically these measures formed the basis of the EU mandatory catch certification scheme to address illegal, unreported and unregulated fishing (Regulation No 1005/2008 and Regulation No 1010/2009) as well as certain aspects of the EU General Food Law (Regulation 178/2002) concerning importers. As of January 01, 2018, the majority of fishing vessels in Barbuda were operating illegally due to the fact that the Barbuda Fisheries Department had not performed any of its basic administrative functions (registration and licensing of vessels, issuing of lobster permits, etc.) required by law (Fisheries Act 2006, Fisheries Regulations 2012 and Barbuda Fisheries Regulation 2014) and critical for satisfying export requirements. In an effort to maintain access to the EU export market, a few Barbudan fishers have opted to license their vessels in Antigua. Note the Barbuda Local Government Act 1976 gave the Barbuda Council authority to administer local fisheries (Part V, Section 4c) including the right to retain taxes on fishery exports and powers to make by-laws concerning fishing and fish intended for human consumption (Part V, Sections 19[1] [xxxii] and [viii]); the Fisheries Act 2006 also makes provision for a local fisheries management authority.

Based on the aforementioned, permission for the Barbuda Fisheries Complex to resume operations with respect to the packaging and inspection of live lobster to the EU and other countries should be denied. Given the unwarranted state of the facility, the following measures are recommended:

• There is an urgent need for the Barbuda Fisheries Complex to be turned over to the local and national management authority, the Barbuda Council and the Fisheries Division respectively, since the facility is rapidly descending into a serious state of disrepair. The current use of the upper floor of the facility for dwelling purposes goes against guiding principles of food safety since activities of residents can negatively impact food production. All of the deficiencies outlined with respect to infrastructure need to be addressed urgently given that the Food and Veterinary Office of the European Commission initiated a desk study on Antigua and Barbuda in September 2016; this is normally a precursor for a formal mission to evaluate the equivalency of Antigua and Barbuda legislation to the relevant EU requirements and to assess the performance of the Antigua and Barbuda authorities competent for the control of the conditions of production and export to the EU of fishery products.

• In light of the fact that the facility is not properly secured (with the exception of the main office on the ground floor), an inventory of all equipment currently present at the


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complex needs to be created; this should be crosschecked with inventories conducted prior to the hurricane in order to account for “missing” items as well as chart the way forward regarding essential equipment and utensils for daily operations.

• Regarding basic sanitation, the entire facility should be cleaned and disinfected including removal of carcasses (dog, rats, etc.) prior to the resumption of fisheries related operations. In the interim, a cleaning programme should be promptly put in place to address the fisher-folks’ washroom and showers as well as the grounds of the facility given that it is currently in use by the tourism sector.

• The perimeter of the facility should be re-fenced and a gate installed to address the issue of large vermin. The accordion door of the receiving room should be repaired and electric fly traps installed in the fish handling centre; these measures should increase security and enhance current pest control programme.

• In terms of technical maintenance, ascertaining the status of the industrial ice maker and the overhauling the standby generator are the main priority. Securing the necessary funds to cover supplies and for the maintenance personnel to spend at least a week in Barbuda is critical.

• Once the facility resumes operations, daily chlorine residual testing of water should be conducted prior to processing, ice-making or cleaning as a measure of water “potability”; when chlorine residual levels are below WHO guidelines (0.5 mg/L at the delivery point after at least 30 minutes contact time and pH < 8.0), disinfecting agent should be manually added to the reservoir for APUA supply, in the interim, until the automated sodium hypochlorite system can be fixed. From a sanitation standpoint including prevention of algal growth, the interior of reservoirs should be visually checked on a regular basis and emptied and cleaned at least once every four months or as required. Regarding the rainwater reservoir tank, the roof should be swept regularly to minimise sedimentation in the tank or a first-flush diverter should be installed to prevent the initial roof-runoff from entering the tank, thereby reducing the level of contaminants (Figure 18). All action taken with respect to water quality (including visual checks of reservoirs, daily chlorine residual testing, etc.) should be logged.

• Concerning basic HACCP and GMP training, the Fisheries Division can facilitate the staff of Barbuda Fisheries with obtaining the necessary certification however it is important that the Barbuda Council recognise that trained personnel need to be maintained on staff in order to meet international requirements. Other options for certification include Cornell University Good Manufacturing Practices Online Course, North Carolina State University Online HACCP Course and SafeCheck® Advanced Food Safety Online.

• The reconstitution of the Barbuda Council (i.e., having a quorum to pass resolutions) is essential for the functioning of the local fisheries management authority as required by the Barbuda Local Government Act 1976. The Fisheries Division should formally communicate with all councilmembers regarding the impact that non-functioning of the Council is having on day-to-day fisheries administration mandatory for export of live lobster and important for the recovery of the local fisheries sector. In the interim, the Fisheries Division can assist with vessel licensing and export inspection; however the modus operandi with respect to revenue collection would have to be worked out with councilmembers since the Council has the right to retain licensing fees and export duty on fishery products.


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Ian Horsford (Mr.) Acting Deputy Chief Fisheries Officer Association of Food and Drug Officials / Seafood HACCP Alliance Trainer


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Figure 1. Damaged accordion door left unsecure to the receiving room, Barbuda Fisheries

Complex (Mar. 27, 2018).

Figure 2. Door originally dislodged by the passage of Hurricane Irma (Mar. 27, 2018).


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Figure 3. Animal droppings and litter at the Barbuda Fisheries Complex (Mar. 27, 2018).

Figure 4. Maggot-filled carcass of a dog at the Barbuda Fisheries Complex (Mar. 27, 2018).


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Figure 5. Tools and equipment in the machine room of the Barbuda Fisheries Complex

showing signs of saltwater damage (Mar. 27, 2018).

Figure 6. Build-up of dirt on the floors and table (Mar. 27, 2018).


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Figure 7. Tourist utilising fisher-folks’ washroom at the Barbuda Fisheries Complex (Mar.

27, 2018).

Figure 8. Fisher-folks’ toilet with faeces, Barbuda Fisheries Complex (Mar. 27, 2018).


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Figure 9. Urinals, floors and walls were filthy and rank in the fisher-folks’ washroom (Mar.

27, 2018).

Figure 10. Tourist heading to the Frigate Bird Sanctuary from the Barbuda Fisheries

Complex (Mar. 27, 2018).


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Figure 11. Rainwater drain pipe from the roof was used to shunt food waste to the ground

(Mar. 27, 2018).

Figure 12. Rat trap in receiving room of the Barbuda Fisheries Complex (Mar. 27, 2018).


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Figure 13. Trap and rat faeces in corridor, Barbuda Fisheries Complex (Mar. 27, 2018).

Figure 14. Pigeon’s dropping defaced the walls of the Barbuda Fisheries Complex (Mar. 27,

2018).


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Figure 15. Reservoir for APUA water supply (left) and reservoir for rainwater supply from

the roof (right) were left open to the elements (Mar. 27, 2018). .

Figure 16. APUA water supply was contaminated with dirt and debris (Mar. 27, 2018).


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Figure 17. Rainwater supply was contaminated with dirt from the roof; note the build-up of

dirt on the outside of the reservoir tank (Mar. 27, 2018).

Figure 18. First-flush diverter is a simple mechanism that diverts the first flow of water away

from a rainwater reservoir.

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GOVERNMENT OF ANTIGUA AND BARBUDA MINISTRY OF … · 2018-07-09 · General Condition of the Barbuda Fisheries Complex Six Months post-Hurricane Irma regarding Export Readiness Page