Exportation of Barbuda’s lobster should be denied – Fisheries Division report

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The Fisheries Division conducted a preliminary inspection on Tuesday, March 27, 2018 of the Barbuda Fisheries Complex and determined that 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.

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, conducted the inspection after EU approved lobster exporters requested to resume operations (lobster packaging and inspection etc.) from the facility following its closure after the passage of Hurricane Irma in September 2017.

Acting Deputy Chief Fisheries Officer Ian Horsford, spearheaded the preliminary inspection and submitted the report entitled, “General Condition of the Barbuda Fisheries Complex Six Months post-Hurricane Irma regarding Export Readiness”, on April 30, to Cheryl Jeffrey-Appleton, Chief Fisheries Officer.

The report specifically detailed the unwarranted state of the facility and made a number of recommendations, including “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”.

Noting that 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 Fire Brigade personnel, the report highlighted that “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”.

The report further notes: “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,” the report states. “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 document also states “the perimeter of the facility should be re-fenced and a gate installed to address the issue of large vermin”.

According to the report, except for the main office on the ground floor, the facility was not properly secured. Consequently, there was need for an inventory of all equipment at the complex that 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.

The scope of the preliminary inspection included the physical infrastructure and the surrounding environment of the facility with emphasis on the key elements of Good Manufacturing Practices (GMP) and Sanitation Control Procedures (SCP) – the prerequisite programmes for Hazard Analysis Critical Control Point(HACCP), 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.

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 main products handled by the facility prior to the hurricane, included live lobster, gutted and scaled fresh fish, and fresh conch. The facility also provided ice and cold storage service to fisherfolks.

Preliminary SCP and GMP inspections highlighted that 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 causing doors, windows, aluminium shutters and the surrounding fence to be damaged by the winds. 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 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.

“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 a number of tools and equipment present showed signs of saltwater damage.

“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.

“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. 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. Deficiencies related to the safety of water were considered “critical” under the U.S. Department of Commerce Seafood Inspection Programme 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.”

The report also stated that HACCP training was mandatory for supervisors, managers and inspectors of fish processing establishments according to various international legislation; however, review of Barbuda’s staff training log indicated 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. Individuals whose certification was originally funded by the Fisheries Division have since been transferred to other departments of the Barbuda Council.

It also stated that 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.

It should be noted that hurricane Irma hit Barbuda in early September last year, and there was a seven-month lapse in evaluating the state of the fisheries facility and those who occupy it, as well as the government, are aware that all the aforementioned issues would have had to be addressed ahead of July 1, if there was an intention to have the Complex operational in time for the open season for lobster fishing which starts on July 1 annually.

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