Fisheries value chain: Good practice for Safety and Quality Assurance with special focus on Fish Maw

Entebbe, 3rd September 2019. The Ministry of Agriculture Animal Industry and Fisheries developed guidelines through the Directorate of Fisheries Resources to ensure that the country maintains the exemplary position as one of the leading exporters of quality fish on the regional and international market.

Among these was a Code of Good Practice (CoP) for safety and quality assurance for fish maws.

The code provides general guidelines on the recommended best practices for production, handling, preparation, processing and handling fish and fish products by all operators involved along various stages in the artisanal fishery, from capture to sale. 

The code also focuses on providing basic information, laws, regulations, procedures and principles for addressing food safety and quality for fish maws. 

It is applied during handling, preparation (such as drying), processing, packaging, storage, transport and marketing of fish maws.

Above: A fisheries expert packaging fish at a fish factory in Entebbe. A risk-approach based on Hazard Analysis Critical Control Point (HACCP), an internationally tested management tool for food safety, has been adopted in the CoP.  The Code aims at assisting fishers, fish handlers, fish processors, fish traders in understanding good practices necessary to produce safe products, minimize losses and maintain quality and safety thus increasing their earnings.

It is important that all operators embrace the code to improve the integrity of fish maws products placed by the operators on Ugandan, regional and international markets.

The Legal framework

The 1995 Constitution of the Republic of Uganda (as Amended) Section XIII notes that the State shall protect important natural resources, including land, water, wetlands, oil, fauna and flora on behalf of the people of Uganda.

The Fisheries and Aquaculture Policy, 2018, calls for a strong regulated industry, and this requires relevant laws and regulations to ensure compliance, strategic development, fairness among all stakeholders and protection of fishers and fish farmers. Government will, therefore, review, develop and enforce appropriate laws, regulations and relevant protocols hence the need for this code of practice for fish Maws. 

The Fish Act Cap. 197(2000)  makes provision for the control of fishing, the conservation of fish, the purchase, sale, marketing and processing of fish, and matters connected therewith and is the principal law governing fisheries in Uganda

The Fish (Fishery and Aquaculture Products) (Quality Assurance) Rules, 2017 Rule 2 prescribes: measures for monitoring and control of fish, fishery and aquaculture products and the inputs used in the aquaculture value chain; and procedures for monitoring the substances and groups of residues likely to contaminate fish, fishery and aquaculture products.

Rule 22. Provides for: approval of fish maw processors and exporters including compliance by processing establishment; Fish maws processing in a manner that ensures quality and safety of the product, and that meets the relevant environmental and health requirements; prescription of compliance before placement of the products on the market; and the conditions for storage and transport of fish maws.

Rule 12(1) of The Fish (Fishing) Rules, 2010, states that a person shall not engage in any fishing activity without a license or permit issued under these Rules by the Chief fisheries Officer or an Authorized licensing officer.

To operationalize these laws this guideline is issued with the purpose of providing for a streamlined value chain flow and involvement of all actors, with minimum standards for any gutting facility for fish at local market level and including facilitating government revenue generation.

The guidelines are also premised on the fact that the quality aspects at the Nile perch value chain have been well handled and fish exports continue to be guaranteed by the Directorate of Fisheries Resources as the Competent Authority.

Fish maws being a product attached to the Nile perch, the unsustainable quality practices may endanger the whole export industry with undesirable socio-economic consequences if the prime market rejected our fish and fishery products.

Why the code was developed

The Code was developed by the Ministry of Agriculture Animal Industry and Fisheries to achieve the following specific objectives.

i.            To provide guidelines on handling, processing, marketing and trade of fish maws  to be undertaken by business operators with minimum contamination, and reduced/eliminated hazards while promoting fair trade

ii.           To provide for a streamlined value chain flow and involvement of all actors, with minimum standards for any gutting facility for fish at local market level including facilitating government revenue generation.

iii.          To strengthen official controls (certification, inspection , sampling, testing )   of fish maws  and ensure compliance  to the regulations and standards premised on the quality assurance system built for the export of   the Nile perch value chain 

iv.          To ensure  fish exports including fish maws are  guaranteed by the Directorate of Fisheries Resources as the Competent Authority and therefore  minimize and /or   eliminate food safety risks that  may endanger the whole export industry with un desirable socio-economic consequences if the prime market rejected our fish and fishery products.

v.           To raise high level of awareness and promote voluntary compliance to the actors along the value chain

Requirements for Licensing

The Fish (amendment) Act, 2011 clause 22B states that the Chief Fisheries Officer shall by notice establish and maintain a registry of all persons issued with a license.

To engage in fish maw trade one should be licensed and to be licensed he/she must provide the following:

(a)         TIN number

(b)         National ID/passport

(c)          Phone and physical address

(d)         Age

(e)         Copy of previous license

(f)          An application filled out (an online application form)

(g)          Proof of registration by the licensing office.

(h)         Proof of Payment from bank depending on the type of License required.

Handling of fish at landing sites

All fish must be handled according to the following conditions:

(a)         All fish must be landed at approved/gazetted landing sites and must be inspected by fisheries staff at the landing site;

(b)         No fishing vessel will be allowed to land with fish maws or gutted fish;

(c)          The fish to be commercially traded should be issued with a fish movement permit that indicates the quantities and the destination;

(d)         Fish from landing sites must be carried as whole fish (no gutting/removing fish maws) apart from those to be consumed within the local areas;

(e)         Fish and fisheries products to be carried in clean containers to the handling facility;

(f)          Fish and fisheries products should be transported in insulated containers/trucks/boxes;

(g)          The insulated trucks should be licensed;

(h)         Fish handlers must wear clean uniforms when handling the fish; and

(i)           Fish handlers must be medically examined by relevant health official.

Facilities for Fish Gutting (Processing)   

a)           A person shall not engage in any gutting of fish at landing sites without a license or permit issued by the chief fisheries officer or authorized licensing officer.

b)           Gutting shall be carried out only at an approved facility outside the official area handling fish for export but within the designated landing site.

c)           The applicant in the above case shall submit the design of the facility to the central competent Authority (CCA) for approval before proceeding with construction.

d)           The design of the handling facility should clearly show these key features:

i)            clean water source (portable water);

ii)           a raised working surface/platform with smooth and easy to clean surfaces, hand washing facility supplied with soap. The raised surfaces must be constructed with a shade, drainage systems and solid waste handling facility;

iii)          Accessible toilet facilities for the personnel. 

e)           The area should be fenced off/enclosed.

f)            All staff/personnel handling fish and fishery products shall follow Good Hygiene practices (GHP) that shall include: Hand washing before handling fish; having a bi-annual medical examination and certificate; wearing protective uniforms, headgears, footwear/gumboots (PPE); and training in hygiene and food safety.

g)           The facility must have a fish and fish maws storage facility which is approved (insulated).

h)           The fish and fishery product shall be kept at temperatures approaching that of melting ice.

i)            All fish received for gutting in a processing facility other than the factory must be accompanied by a fish movement permit issued by an authorized officer.

j)            The facility shall be inspected by a local fish inspector

k)           Processing capacity will be determined and allocated by the Chief Fisheries Officer

l)            The facility must have a management plan and management team.

m)         The fish for gutting must meet the minimum recommended fish size as per the Fish (Fishing) Rules, 2010.

n)           Fresh fish and fishery products shall be kept at temperature approaching that of melting ice during transportation.

o)           The fish maws leaving the facility shall be issued with a fish maws movement permit.

p)           The gutted fish destined for the market shall be issued with a fish movement permit.

q)           Gutted and whole fish shall not be transported in the same vehicle/vessel/container.

r)           Fish maws and gutted fish shall not be transported in the same containment.

s)           Vehicles used for transport of fish and fish products shall be approved and issued with a certificate of inspection and license.

t)            Transport of fresh fish on motorbikes shall only be in insulated containers/boxes.

u)           The transporter must have a valid transporters license.

Handling of Fish in Local Fish Markets

Fresh Products

       (a) Apply for a license as in application requirements above.

       (b)There should be defined areas in the market for handling fish;

       (c) Fish traders should wear a clean uniform when handling fish;

       (d) The fish must be handled on easy to clean surfaces and they should be clean at all times;

      (e) Should have appropriate cold chain storage facilities;

      (f) There should be hand washing facilities;

      (g) The handling personnel should be medically examined; and

      (h) There should be potable clean water all the time.

Cured Fish Products

(a)         Should operate in a dry raised platform;

(b)         The handling surfaces should be easy to clean, smooth, durable and should be kept clean at all times;

(c)          The working environment should be kept in a hygienically acceptable condition with waste management facilities;

(d)         There should be appropriate storage facilities for the  fish; and

(e)         Handlers

(f)          must dress in overcoats and head gears during time of work.

Specific Guidelines and Standards for Fish Maw Handling

a)           Fish maws shall be prepared from sound swim bladders of the designated fish species, which is of an acceptable quality and fit for human consumption;

b)           Swim bladders shall be extracted from mature fish which is complying to the fishing rules and regulations;

c)           Water used for washing the fish maws should be clean;

d)           After washing, the fish maws shall be dried either in the sun or in artificial dryers until the required moisture content is obtained;

e)           The fish maws, while drying, shall be protected against contamination from dirt, sand, and insects;

f)            The dried fish maws shall have the characteristic colour and odour of dried fish maws and shall be free from any indication of spoilage such as mouldiness;

g)           The product shall be wholesome and free from stains, blood vessels, shreds, blood spots and any other form of foreign matter.

h)           Dried fish maws shall have moisture content (% max) as 8, acid insoluble ash (% max.) 1.5, and total ash (% max) 15.

i)            The microbiological set limits include: Salmonella in 25g to be absent, E. coli per gram to be absent, Staphylococcus aureus CFCU/gram to be 103, Total Viable Cost at 105/g, Clostridium perfrgens spp to be absent and yeast and mould at 104. Contaminant limits (Maximum limit – mg/kg) for dried fish maws is set as follows: Arsenic (0.1), lead (0.3), Cadmium (0.3) and mercury (0.5).

j)            The dried fish maws is also prescribed not to contain more than 10 microgram per kilogram total aflatoxin of which not more than 5 microgram per kilogram may be aflatoxin B1 when tested in accordance with US ISO 16050.

k)           Dried fish maws shall comply with those maximum pesticides residue limits established by the Codex Alimentarius Commission.”

l)            If food additives  are used in processing of dried fish maws it should be indicated on the label

m)         Packaging of dried fish maws to be in accordance set guidelines in fish quality assurance rules.

n)           Specific labelling requirements that are  legibly and indelibly marked:  with  the name of the product; name and physical address of processor or/packer, net weight in grams or kilograms, date of packaging, batch or code number, expiry date, storage conditions, country of origin  and nutritional labelling, nutrition and health claims made accordingly.

Roles of different stakeholders

Fish Maw Processors and Exporters

a)           Register and be member of an association and provide proof of belonging to the association (recommendation);

b)           Apply and acquire license by filling out an online application form;

c)           Establish processing establishment;

d)           Fish processing facility must be inspected and if compliant be issued with an establishment approval certificate (No) before being licensed ;

e)           Fish maws exporters and processors must implement a traceability system and comply to all other requirements specified in the Fish (Fisheries and Aquaculture) Rules 2017;

f)            Fish maw exporters to buy maws from only fish maw traders and value added maws from factories.

g)           No fish maw processor or exporter will buy fish maws from landing sites.

h)           Fish maws exporters and processors must declare their source of fish maws from factories and fish maw traders;

i)            Pay fish levy for any fish leaving Uganda; and

j)            Fish maw processors and exporters shall be required to provide returns monthly.

 7.2        Roles of Boat owners and Fishers

a)           Register as boat owner or fisher;

b)           Possess a license, the Licensee shall submit previous year’s data before obtaining a new licence;

c)           Licensees must sell fish to licensed fish traders or suppliers only or community members for local consumption.

Roles of fish maw traders

a)           Provide documentation required for licensing.;

b)           Follow official controls (Inspections, certification, sampling, testing, approvals) as the Competent Authority

c)           Pay for license and get a license;

a)           Purchase fish maws from fish processors with approved establishments;

b)           Purchase fish maws from locally consumed fish at landing sites and not on waters;

d)           Maintain fish quality and safety during transportation and marketing; and

e)           Provide returns to Directorate of Fisheries Resources.

Roles of fish suppliers

a)           Provide documentation required for licensing;

b)           Pay for license and get licensed;

c)           Purchase fish un-gutted from boat owners;

d)            Sell the fish to processing factories and national markets;

e)           Maintain fish quality and safety during transportation and marketing; and

f)           Provide returns to Directorate of Fisheries Resources.

Roles of the Directorate of Fisheries Resources

a)           Provide overall policy guidance

b)           Provide regulatory services as the Competent Authority.

c)           Provide training and sensitization to all stakeholders.

d)           Prepare programs for the development of the sub-sector value chain

e)           Promote PPP in developing the fish maw value chain.

These guidelines will be implemented as an interim measure until the Ministry comes up with a new Fisheries and Aquaculture Act. They will be revised from time to time.

Notes for editors

About the Ministry of Agriculture, Animal Industry and Fisheries (MAAIF)

The Ministry of Agriculture, Animal Industry and Fisheries is a Ministry in the Government of Uganda charged with creating an enabling environment in the Agricultural Sector.

The Ministry formulates, reviews and implement national policies, plans, strategies, regulations and standards and enforce laws, regulations and standards along the value chain of crops, livestock and fisheries.

Vision: A competitive, profitable and sustainable agricultural sector.

Mission: To transform subsistence farming to commercial agriculture.

Strategic Objectives

  • To initiate the formulation and review of the policy and legal framework for the sector
  • To establish and implement systems for service provision in the sector
  • To strengthen and implement strategies, regulatory framework, standards, institutional structures and infrastructure for quality assurance and increased quantities of agricultural products to access and sustain local, regional and export markets
  • To design and implement sustainable capacity building programmes for stakeholders in the agricultural sector through training, re-tooling, infrastructure, provision of logistics and ICT
  • To develop strategies for sustainable food security
  • To develop appropriate agricultural technologies for improved agricultural production, productivity and value addition through research
  • To develop effective collaborative mechanisms with affiliated institutions and
  • To take lead and establish a system and institutional framework for agricultural data collection, analyses, storage and dissemination to stakeholders including Uganda Bureau of Statistics.

The Ministry of Agriculture, Animal Industry and Fisheries (MAAIF) is made up of four Directorates including the Directorate of Crop Resources, Directorate of Animal Resources, Directorate of Agricultural Extension Services and the Directorate of Fisheries Resources each with Departments, Divisions and Partnership Projects.

The Departments of the Ministry which do not fall directly in the above include the Department of Agricultural Planning and Development, the Human Resource Department, the Department of Finance and Administration and the Department of Agricultural Infrastructure, Mechanisation and Water for Agricultural Production.

The Ministry is also made up of seven Agencies including the National Agricultural Research Organisation (NARO), the National Agricultural Advisory Services (NAADS), Cotton Development Organisation (CDO), Dairy Development Authority (DDA), Uganda Coffee Development Authority (UCDA) and Coordinating Office for the Control of Trypanosomiasis in Uganda (COCTU) and the National Animal Genetic Resources Centre and Databank (NAGRC&DB).