On November 8th, the European Commission’s Directorate General for Health and Food Safety made public the report of its audit and evaluation of the Indian government’s control of residues and contaminants in live animals and animal products including controls on veterinary medicinal products. The audit report shows the extensive, unique controls that the Indian government has installed to safeguard against exporting shrimp contaminated with antibiotics to the European Union. In doing so, the report also reveals why massive quantities of Indian shrimp have been directed to the U.S. market, where no comparable controls are required.
As explained in the report, all shrimp exported from India to the European Union must be shipped from an establishment approved by the Export Inspection Council (EIC) within the Indian Government’s Ministry of Commerce and Industry, with each establishment assigned a unique approval number. EIC approval for export requires that establishments maintain a Hazard Analysis Critical Control Points (HACCP) program and that they be inspected by the Export Inspection Agency every one to three months depending on the risk presented. Further, every six months, samples are collected from EIC approved facilities and are tested for the presence of antibiotics “including chloramphenicol, nitrofuran metabolites and tetracyclines.”
EIC-approved shrimp exporters may only source farmed shrimp from shrimp farms registered with the Marine Product Export Development Agency (MPEDA). Although there are 60,000 MPEDA registered aquaculture farms in the country, registered farms are a subset of all of the shrimp farms operated within India. Each MPEDA registered farm is identified with its GPS coordinates and records of each harvest must be maintained, ensuring traceability of shrimp exported to the European Union back to the original pond. For MPEDA registered aquaculture farms, shrimp batches are sampled and tested for the presence of chloramphenicol and four nitrofuran metabolites prior to harvest. The cost of the screening tests is paid by shrimp farmers, sales of the harvested batch of shrimp are accompanied by pre-harvest testing results, and the EIC-approved shrimp processing plants send staff to the MPEDA registered farms to witness harvest and seal the delivery trucks before shipments are delivered to the plant. Additionally, EIC-approved plants crosscheck the amounts received from a MPEDA registered farm with production estimated for the pond.
EIC-approval also requires that a processing plant limit the number of farms/batches in one exported consignment to four. This limitation on sourcing allows for more accurate sampling, facilitates follow-up investigations, and ensures traceability. Further, prior to export, staff from EIC laboratories visit the EIC-approved facility and take samples to test for chloramphenicol, tetracycline, oxytetracycline, chlortetracycline, and metabolites of nitrofurans. All shipments of shrimp to the European Union from India must be accompanied by the results of this analytical test. The audit report explains that through 2017, one EIC laboratory in Chennai found nitrofurans in 24 samples tested and chloramphenicol in another four samples tested through this pre-export testing regime. In the first four months of 2018, that same laboratory found nitrofurans in 32 samples tested.
However, even with all of these controls in place, the European Union requires that half of all consignments of shrimp exported from India be tested at the border. These tests continue to find banned antibiotics in Indian shrimp. The audit report estimates that in 2017 the European Union conducted roughly 1,600 tests at the border and found nitrofurans in 14 of those tests. Through October of this year, the European Union’s Rapid Alert System for Food and Feed has 13 notifications for nitrofurans found in Indian shrimp. Although the systems in place are supposed to facilitate traceability, post-detection investigations by Indian government authorities are rarely able to identify the reasons for the violative results.
The audit report concludes that despite all of the additional controls in place to eliminate antibiotics from shrimp exported to the European Union from India, the integrity of the system is undermined by the widespread availability of antibiotics in India. The audit report explains that chloramphenicol and nitrofurans continue to be sold over the counter and that the auditors were able to confirm that nitrofurans remained actively on the market, with furazolidone in approximately 40 commercial products, nitrofurazone in 11 commercial products, and furaltadone in 7 commercial products. Even more disturbingly, a number of antibiotics which are banned for use in food-producing animals in the European Union are “freely available on the Indian market and may be purchased over the counter” but are not tested for at any stage of the supply chain. The audit report notes that there is no requirement that purchase records be maintained regarding these antibiotics and there currently exists no legal tools by which to sanction producers responsible for violative results. Summarizing its findings, the audit report states:
“Overall, whilst there have been improvements in the residue control system in India, the effectiveness of the already EU-approved residue monitoring plans is weakened by a scope of testing which should better reflect the availability of veterinary medicinal products on the market and access of farmers to those substances.”
There are no similar controls or requirements in place for Indian shrimp exports to the United States. At most, a U.S. importer of Indian shrimp need only have evidence that its Indian supplier maintain a HACCP program. The differences in approach have had a huge impact on the respective markets for shrimp in the European Union and the United States. In the European Union, the single largest supplier of shrimp is Ecuador, which accounted for 15.9 percent of the value of all shrimp imports in 2017. India, in comparison, accounted for 13.1 percent of the value of shrimp imports into the European Union last year, with shipments worth roughly 555 million Euros (US$627 million).
In sharp contrast, India is by far the largest single supplier of shrimp to the United States. India accounted for 35.2 percent of the value of all shrimp imports into the United States last year, with shipments worth roughly US$2.2 billion. The next largest supplier – Indonesia – accounted for roughly half that value last year (18.8 percent of the value, roughly US$1.2 billion). And Indian shrimp shipments to the United States continued to grow significantly in 2018.
“The EU’s audit report confirms our worst fears,” said John Williams, the Executive Director of the Southern Shrimp Alliance. “The inability of our food safety regulatory system to deal with the problem of the indiscriminate use of antibiotics in aquaculture has made the United States a dumping ground for contaminated shrimp. The U.S. shrimp industry was devastated fifteen years ago when massive amounts of cheap, contaminated Chinese shrimp was re-directed to this market. The federal government cannot allow history to repeat itself.”
Read the European Commission’s “Final Report of an Audit Carried Out in India From 16 to 27 April 2018 in Order to Evaluate the Control of Residues and Contaminants in Live Animals and Animal Products Including Controls on Veterinary Medicinal Products” DG(SANTE) 2018-6345 here: http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=4055