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INDUSTRY ASSESSMENT – PAKISTAN Philip Randall and Prof. Faqir Anjum

(August – September 2014)

STUDY COMMISSIONED BY

GLOBAL ALLIANCE FOR IMPROVED NUTRITION PAKISTAN

Final 291214 – Wheat and Oil Industry Pakistan Page 1 of 80

Table of Contents Acknowledgements ......................................................................................................................... 5

Acronyms ......................................................................................................................................... 6

Background ...................................................................................................................................... 7

Overview of Assessment ................................................................................................................. 8

General ........................................................................................................................................ 8

Specific ......................................................................................................................................... 8

Methodology ................................................................................................................................... 9

Training .......................................................................................................................................... 10

Table 1 – Local Investigation team ............................................................................................ 10

Results ........................................................................................................................................... 10

Wheat ........................................................................................................................................ 10

Figure 1 – Punjab Mills .............................................................................................................. 11

Figure 2 - Balochistan Mills ........................................................................................................ 11

Figure 3 – KPK Mills ................................................................................................................... 12

Figure 4 – Sindh Mills ................................................................................................................ 13

Membership discepancies ..................................................................................................... 13

Oil and Vanaspati/Banaspati ..................................................................................................... 13

Figure 5 – Punjab Refineries ...................................................................................................... 14

Figure 6 - Balochistan Refineries ............................................................................................... 14

Figure 7 – KPK Refineries ........................................................................................................... 15

Figure 8 – Sindh Refineries ........................................................................................................ 16

Production and Consumption – Wheat Flour and Vegetable oils ................................................. 16

Table 2 – Food Balance Sheet 2011 ........................................................................................... 17

Wheat Consumption Variability ................................................................................................ 18

Table 3 – Imports and Exports of wheat and wheat flour ......................................................... 18

Table 4 – Food Balance Sheet Wheat ........................................................................................ 18

‘Ghee’ .................................................................................................................................... 19

Stakeholder Inputs ........................................................................................................................ 19

Table 5 – Synopsis of Stakeholder Inputs .................................................................................. 20

Industry Assessment Problems ..................................................................................................... 21

Wheat Industry Assessment .......................................................................................................... 22


Table 6 – Summary of local team mill visits .............................................................................. 24

Oil Industry Assessment ................................................................................................................ 25

Technical Capacity ......................................................................................................................... 27

Wheat ........................................................................................................................................ 27

Oil .............................................................................................................................................. 27

Human Resource Requirements ................................................................................................ 28

QA/QC Protocols ........................................................................................................................... 29

Wheat ........................................................................................................................................ 29

Oil .............................................................................................................................................. 29

Wheat and Oil ............................................................................................................................ 30

Requirement .............................................................................................................................. 30

Production – Installed and Actual ................................................................................................. 31

Premix Requirements .................................................................................................................... 31

WHO Recommendations ....................................................................................................... 32

Equipment Requirements ............................................................................................................. 33

Synopsis ..................................................................................................................................... 33

Requirements ............................................................................................................................ 33

Small Scale Processors ................................................................................................................... 34

Vitamin A Fortification Compliance and Oil Quality ...................................................................... 36

Table 7 - Punjab Pure Food Rules 2011 – Fortification Requirement ....................................... 37

Previous Studies .................................................................................................................... 37

Table 8 – Analytical results – market samples; oil and ghee ..................................................... 38

Iron and Phytic acid levels ............................................................................................................. 40

Table 9 – Mean values and Z stat for grain by total, mill type and region ................................ 41

Table 10 – Mean values and Z stat for Atta by total, mill type and region ............................... 42

Table 11 – Mean values and Z stat for Maida by total, mill type and region ............................ 43

Graph 1 – Intrinsic iron variation in Grain ................................................................................. 44

Graph 2 – Intrinsic iron variation in Atta Flour .......................................................................... 45

Graph 3 – Intrinsic iron variation in Miada Flour ...................................................................... 45

Wheat Price Commentary ............................................................................................................. 46

Zinc ................................................................................................................................................ 46

Conclusions and Recommendations ............................................................................................. 47


General ...................................................................................................................................... 47

Wheat ........................................................................................................................................ 47

Recommendation 1 ................................................................................................................... 47

Recommendation 2 ................................................................................................................... 47

Recommendation 3 ................................................................................................................... 47

Recommendation 4 ................................................................................................................... 47

Recommendation 5 ................................................................................................................... 47

Recommendation 6 ................................................................................................................... 48

Oil .............................................................................................................................................. 48

Recommendation 1 ................................................................................................................... 48

Recommendation 2 ................................................................................................................... 49

Recommendation 3 ................................................................................................................... 49

Monitoring ................................................................................................................................. 49

Recommendation 1 ................................................................................................................... 49

Recommendation 2 ................................................................................................................... 49

Recommendation 3 ................................................................................................................... 49

Recommendation 4 ................................................................................................................... 49

Recommendation 5 ................................................................................................................... 49

Recommendation 6 ................................................................................................................... 49

Annex 1 A TOR International consultant ....................................................................................... 51

Wheat Flour Industry................................................................................................................. 51

Oil and Ghee Industry ................................................................................................................ 52

Annex 1 B TOR Local consultant .................................................................................................... 53

Annex 2A Wheat ............................................................................................................................ 55

Annex 2B Oil .................................................................................................................................. 60

Annex 3 – Stakeholder Inputs ....................................................................................................... 65

Pakistan Flour Millers Association (PFMA) – Punjab Zone ........................................................ 65

Pakistan Flour Millers Association – Sindh Circle ...................................................................... 66

Pakistan Vanaspati Manufacturers’ Association (PVMA) .......................................................... 67

Food Department – Punjab ....................................................................................................... 68

Food Department - Karachi ....................................................................................................... 70

Policy and Strategic Planning Unit (PSPU) – Lahore .................................................................. 70


Planning & Development Department (PND) – Government of Punjab ................................... 71

Nutrition Planning Commission NPC – Islamabad ..................................................................... 72

Pakistan Standards and Quality Control Authority (PSQCA) - Karachi ...................................... 73

Pakistan Standards and Quality Control Authority (PSQCA) – Lahore ...................................... 74

Standing Committee Commerce & Investment – Punjab Assembly ......................................... 74

Pakistan Council for Scientific and Industrial Research – PCSIR................................................ 74

METRO Superstore ........................................................................................................................ 75

Current Prices Consumer Groceries Pakistan ............................................................................ 75

Jamia Tur Rashaid ...................................................................................................................... 75

TechnoMight Engineers – Faisalabad ........................................................................................ 76

Annex 4 – Mean Squares Statistics ................................................................................................ 77


Acknowledgements Consultant Philip Randall and Prof. Faqir Anjum would like to express its gratitude to Wheat

Milling (Flour Mills) and Edible Oils and Fats Industry of Pakistan for provision of access to

Industry, products information and sampling to complete this assessment survey. We have also

genuine pleasure to thanks for overwhelming support of Pakistan Flour Mills Association (PFMA)

and Pakistan Vanaspati Manufacturers Association (PVMA) for their facilitation to reach out to

their mills.

We are highly indebted for the support of the Stakeholders from the National and Provincial

Governments including Ministry of National Health Services, Regulation and Coordination,

Planning Commission of Pakistan, Pakistan Standards and Quality Control Authority, Punjab

Food Department, Planning and Development Department of Punjab. We also acknowledge

profusely the contribution of Pakistan Council for Scientific Research (PCSIR) for sample analysis

of Wheat Flour (Atta, Maida, Wheat Grain, Oil and Ghee) collected from different regions of

Pakistan.

It is privileged to record the contribution of Institute of Home and Food Science, Government

College University, Faisalabad through the Vice Chancellor Prof. Zakir Hussain (PhD). We are

extremely thankful to the team of Government College, Faisalabad University who travelled

throughout the country for data collection.

Last but not least, we would like to thank especially GAIN team, Ms. Dora Panagides, Mr. David

Morgan, Mr. Munawar Hussain, Project Manager, Large Scale Food Fortification and Mr. Syed

Sajjad Imran, Country Manager for the extensive support and persistent help during the course

of assessment.


Acronyms APLAC Asia Pacific Laboratory Accreditation Cooperation EMS European Metrological Service

FAO United Nations Food and Agriculture Organisation FAQ Fair Average Quality FFA Free Fatty Acid(s)

g Gram GAIN Global Alliance for Improved Nutrition

HDI Human Development Index IEC International Electrotechnical Commission ILAC International Laboratory Accreditation Cooperation

ISO International Organisation for Standardisation IU International Units

Kg Kilogram Kg Kilogram (1000 g) MI Micronutrient Initiative

MRA Mutual Recognition Arrangement MT Metric ton (1000 Kg)

NGO Non-Governmental Organisation NNS National Nutrition Survey NPC Nutrition Planning Commission - Islamabad

PASSCO Pakistan Agricultural Storage and Services Cooperative PCSIR Pakistan Council for Scientific and Industrial Research

PFMA Pakistan Flour Millers Association – Punjab PNAC Pakistan National Accreditation Council

PND Planning and Development Department - Punjab PS Pakistan Standard PSPU Policy and Strategic Planning Unit (Lahore)

PSQCA Pakistan Standards Quality Control Authority PV Peroxide Value

PVMA Pakistan Vanaspati Mills Association RDI Recommended Daily Intake QMS Quality Management System

RBDO Refined Bleached Deodorised Oil RDI Recommended Daily Intake

Rs Rupee (Pakistan) SUN Stepping Up Nutrition TOR Terms of Reference

VSD Variable Speed Drive WFF Wheat Flour Fortification

WFP World Food program of the United Nations


Background Pakistan is the sixth biggest country in the world, with an estimated population of more than 180 million people. Ranking 141 out of 182 countries

in the Human Development Index (HDI), Pakistan is an impoverished, underdeveloped and disaster-prone country. The National Nutrition Survey 2011 indicates that stunting, wasting and micronutrient malnutrition are

endemic in Pakistan.

Results from the 2011 National Nutrition Survey (NNS) indicated little change over the last decade in terms of core maternal and childhood nutrition indicators. The survey showed that micronutrient deficiencies were

widespread in children, and specifically in children under 5 years of age (Anemia 61.9%, iron deficiency 43.8%, vitamin A deficiency 54%, zinc

deficiency 39.2% and vitamin D deficiency 40%), and amongst mothers (anemia 50.4%, Vitamin A deficiency 17.2%, Zinc deficiency 42.1%, Vitamin D deficiency 23.2%, Calcium deficiency 52.9%).

Over the recent years, the Government of Pakistan has demonstrated a

strong commitment to prioritize the fight against malnutrition. A multi-sectoral nutrition policy guidance notes has been prepared by all provinces under the umbrella of Planning and Development Department. Pakistan has

recently joined the SUN movement as well. In order to control the micronutrient malnutrition food fortification has been identified as main

strategy.

Wheat Flour Fortification (WFF) with iron and folic acid is an effective and

sustainable intervention to reduce the prevalence of iron deficiency anemia among the population. It is estimated that 50-55% of the population in the

country consumes commercially roller-milled flour on a daily basis. There are around 1200 flour mills in the country with geographic spread of 2/3rd in Punjab and remaining in other provinces and regions.

In order to combat Vitamin A dDeficiency the sustainable methods approach is fortification of edible oil and ghee which are considered appropriate

vehicles as these are widely consumed in Pakistan, with annual consumption estimated at 2,700 million kg with average of 15-16 Kg per person per year

(roughly 90% ghee, 10% oil). Legislation currently exists on mandating fortification of edible oil and ghee with vitamin A (33,000 IU per kg) and D (The original legislation goes back to 1933, and was revised and updated in

the Pure Food Rules of 1965 and then in 2000).

However, there are significant gaps that affect the fortification efforts in the country. In order to support fortification effort, it is important to undertake an in-depth assessment of the industry in the country which includes an

inventory and capacity of the flour/ edible oil & ghee mills, availability of equipment and technical capacity etc. GAIN will support this assessment to

guide future programming.


General and Specific tasks where provided in the TOR which is given in Annex 1

Overview of Assessment

General

To conduct a detailed assessment to determine industry equipment and premix requirements, recommend protocols that can be adopted within the

current manufacturing process that can ensure fortification requirements can be consistently fulfilled and determine the training requirement for

production personnel if applicable at each of the selected:

Flour mills

Chakki mills Oil refineries

Vanaspati/Banaspati producers

Generate evidence for level of Vitamin A and D in the oil and ghee available

in different parts of the country.

The Terms of References for the international and local consultant are

provided in Annex 1A and 1B respectively.

Specific

Develop a checklist and questionnaire and assessment methodology. Conduct meetings with Pakistan Flour Mills Association, Pakistan

Vanaspati Mills Association, Pakistan Standards and Quality Control

Authority, Food Department, Health Department, Punjab Food Authority, Planning Commission, development partners and any other

important stake holders to seek their inputs. Stratify industry based on the production and geography.

Visit all industry and meet with the designated production personnel and management staff. Estimated 7% of milling industry and 15% of oil industry.

Estimate the production capacity and actual production achieved by each of the producers and based on this provide projections for premix

requirements Based on the plant layout, design and capacity, develop a detailed

equipment list and/or process changes that would be required to

fortify at an appropriate quality. The specifications should be detailed enough to enable procurement of appropriate micro-feeders and/or

dosers. The consultant should also provide a list of potential suppliers of such equipment and estimated costs of process upgrades that are proposed.

Document production protocols in place at each of the manufacturing plants and provide recommendations of appropriate QA/QC protocols


that would have to be adopted to produce fortified products in accordance with National standards.

Observe technical capacity of production personnel and in consultation with plant managers provide an objective brief on extent and type of

training that would be beneficial/required. Identify wheat flour consumption pattern and variations among

different provinces, which could impact on required level of

fortification. Collect sample and provide analysis of level of Vitamin A in Oil and

Ghee from different sources and parts of country by having a representative sample.

Methodology Questionnaires (these where field tested by the lead consultants during the

early stages of the assessment) and mill/refinery stratification (based on size and locality) where developed. The questionnaires, as used by the local assessment teams, are provided in Annex 2A and 2B.

Mill data was obtained through the membership rolls of the Pakistan Flour

Millers Associations (PFMA) [Punjab 843, KPK, 153, Suindh 139 and Balochistan 36; total mills on membership rolls 1171] and from this list the spatial mapping was carried out by District, number of mills and the range of

installed capacity per day. Islamabad was dealt with as a separate entity as it is a Federal District in its own right (others are Provincial Districts).

A similar list of oil refineries (100 in total) was obtained through the Pakistan

Vanaspati Mills Association (PVMA). From this list the spatial mapping was

carried out by District, number of refineries and the range of installed

capacities (,000 MT per annum). Islamabad was dealt with as a separate

entity as it is a Federal District in its own right (others are Provincial

Districts.

From the supplied database a cross section of mills was suggested to the

Pakistan team for consideration based on spatial difficulties (logistics etc.).

The security situation, however, indicated that mill and refinery selection

would have to take into account the security situation first.

The target of 90 mills plus 48 Chakkis (both the stone mill and metal bladed

or China type) and 16 refineries plus 10 unregulated 1 refineries required that

local resources be used to visit the facilities. These resources were identified

and recruited from the Department of Food Science, Nutrition and

Economics, Government College University, Faisalabad, Pakistan (see Table 1

below).

1 It remains unclear what exactly is meant by ‘unregulated’


Training

A half day training course was run for the investigative team in which the

following was presented and discussed:

Why fortify

Fortification technologies for wheat flour and vegetable oil

Situations to watch for onsite that would indicate special attention

o Flow path of finished product

o Possible errors in the fortification process and/or placement of a

micro feeder

o How fortification was carried out at participating wheat mills

2008 – 2011

Refinery production – batch or continuous

Sampling protocols for wheat flour (on site) and vegetable oil (market

retail/sector)

The two questionnaires (Annex 2A wheat and Annex 2B Oil) and the

major task was using the questions as a guideline and understanding

the underlying purpose of the questions

The team were left with electronic copies of the training materials.

Prof Anjum identified target mills, Chakkis and oil refineries; and the

questionnaires were based on the interviews already carried out by the

consultants.

Table 1 – Local Investigation team

Team Areas

Dr.Ali Imran Faisalabad ,Lahore, Gujrwala

Dr.Frhan Saeed/ Dr.Tahir Sargodha, Dera Ismail khan, Sahiwal, Multan

Dr.Azmat Bhwalpur /DGk/,Sukhar

Mr. Afzaal Karachi, Hydeabad

Dr.Sajid Arshad Quetta

Dr.Nazir and Mr.Haroon Rawalpindi, Peshawar

Results

Wheat

Spatial mapping was carried out by District, number of mills and range of

installed capacities. Islamabad is dealt with as a separate entity and has 40 mills ranging from 40 to 360 MT per day installed capacity.


NOTE: The Food Department based in Rawalpindi advised they have on record 70 mills in Rawalpindi and 41 mills in Islamabad.

Provincial data is for Punjab (Figure 1) – which was further sub divided into

North, Central and South, Balochistan (Figure 2), KPK Figure 3 and Sindh

Figure 4

Figure 1 – Punjab Mills

Figure 2 - Balochistan Mills


Figure 3 – KPK Mills


Figure 4 – Sindh Mills

NOTE: The Chairman of the Sindh Flour Millers Association advised the

Association had 198 members mostly in the range 200 to 280 MT. This

number is significantly higher than the 139 the consultants had on their list

of millers in the Sindh region.

Membership discepancies

Differences in the number of mills throughout Pakistan were noted with no

clear reason as to why. Differences could have come about due to:

Registers not being updated in all of the sources i.e. PFMA not having

the latest version of the SFMA register (none of the registers had

dates).

If the market is over supplied then the liklihood of mills closing and/or

changing hands is high

Ghost mills (mills that exist but do not mill but sell on their quota

allocation, or mill only their quota allocation) are known to exist

Oil and Vanaspati/Banaspati

Spatial mapping was carried out by District, number of refineries and range

of installed capacities (,000 MT per annum). Islamabad was dealt with as a separate entity as it is a Federal District in its own right (others are Provincial

Districts) and has 4 refineries ranging from 28,000 to 45,000 MT per annum

Provincial data is for Punjab (Figure 5), Balochistan (Figure 6), KPK (Figure

7) and Sindh (Figure 8).


Figure 5 – Punjab Refineries

Figure 6 - Balochistan Refineries

Attock 2; 18-20

RYK 1; 44

Sialkot 2;

Faisalabad 7; 22-72

Lahore 12; 18-110

Gujranwala 4; 15-34

Jhang 2;

18

Bahawalpur 2; 45-54

Okara 1; 55

Sahiwal 1; 60 Muzaffargarh 1; 22

DGK 1; 18

Burewala 1; 36

Multan 5; 24-48

Quetta 2; 22-54


Figure 7 – KPK Refineries

DI Khan 1; 12

Peshawar 3; 43-65

Dargai 2, 22-36

Hattar 6; 18-82

Haripur 1; 55

Malakland 2; 44-72

Nowshera 1; 48


Figure 8 – Sindh Refineries

GAIN Pakistan were to be kept advised through all stages of the project and

this was carried out through three formal debriefs, daily meeting when

possible and almost daily telephone calls.

Production and Consumption – Wheat Flour and Vegetable oils As indicated below (Table 2) Pakistan has a high consumption of wheat and

vegetable oil products according to the United Nations Food and Agriculture

Organisation.

Wheat flour is not subject to mandatory fortification but is subject to

voluntary fortification parameters under Punjab Food Authority Act 2011 and

Pakistan Standard PS 4782: 2008

Vegetable oils have mixed fortification status:

Fortified when sold as an identified oil

Fortified when sold as part of a blend of oils

Fortified when sold as part of vegetable ghee

No fortification requirement


The primary vegetable oils are Palm oil, Cottonseed oil, Rapeseed (Canola)

oil and Sunflower oil and constitute >95% over total vegetable oil

consumption.

Table 2 – Food Balance Sheet 2011

Production Imports Food Use Kg/Yr/Capita

,000 MT

Wheat and products 25214 63 20050 114

Soybean Oil # 0 56 37 0.2

Groundnut Oil * # 23 0 23 0.1

Sunflower seed Oil 185 27 115 0.7

Rape and Mustard Oil ##

350 0 249 1.4

Cottonseed Oil * 420 0 356 2

Palm kernel Oil *** 10 10 0.1

Palm Oil # 2140 1296 7.4

Coconut Oil * 7 8 13 0.1

Sesame seed Oil * 6 0 6 0

Olive Oil * 1 1 0

Rice bran Oil ** 5 5 0

Maize Germ Oil 0 0 0

Oil crops Oil, Other 59 2 0 0

Vegetable Oils 1055 2244 2111 12

Source: FAOSTAT July 2014

* Not required to be fortified

** Unknown status – PS 1681:1985 refers to „Rice Bran (solvent extracted); presumably

refering to the oil

*** Not mentioned in Punjab Food Authority Act 2011 but does have a Pakistan Standard (PS

3404:2003)

# Fortified if used in Vanaspati/Banaspati, blended vegetable oil or sold separately.

## Members of the family Brasicaceae Rapeseed is a generic term and, in this case, is

typically (but necessarily entirely) referring to Canola. Mustard seed oil is not mentioned in

Punjab Food Authority Act 2011 but does have a Pakistan Standard (PS 25:2003)

Table 3 below indicates Pakistan has a checkered history on wheat and wheat

flour imports and exports but the trend towards increasingly being a net

exporter is apparent (the drought in 2008 created unusual imports) and from


Table 4 the average 2 consumption pattern is flat at around 250g per person

per day.

Wheat Consumption Variability

The 2011 NNS indicates there is some variability in wheat consumption in

different parts of Pakistan with 8.2.2 indicating that mean consumption of

mothers (only other group reported was infants) was 298 g/day with urban

consumers at 280 g/day and rural consumers at 306 g/day. Sindh Province

was highlighted as being “low” without any numerical value.

Divergent opinions were given on whether wheat flour products were moving

towards higher extraction flours or more refined flours.

Table 3 – Imports and Exports of wheat and wheat flour

Flour MT Wheat MT

Import Export Import Export

2007 36 517 135960 458882

2008 9336 256060 1820225 29691

2009 25 0 3102634 142506

2010 78177 5179 94058 4950

2011 24606 1239102 21841 2087422

Source: FAO TRADE on FAOSTAT July 2014

Table 4 – Food Balance Sheet Wheat

Wheat Equivalent ,000 MT Flour Equivalent 80%

Production Import Export Food Kg/Yr g/cap/day Kg/Yr g/cap/day

2007 23295 139 1079 17853 108.9 298 87.1 238.7

2008 20959 1835 346 18694 111.9 307 89.5 245.3

2009 24033 3104 160 19388 114 312 91.2 249.9

2010 23311 203 28 19681 113.7 312 91.0 249.2

2011 25214 63 3577 20050 113.8 312 91.0 249.4

Source: FAOSTAT July 2014

The full situation in the oil market is less clear in the FAO data bases. FAO

FBS and Trade do not agree on import and export data – probably because

FAO does not distinguish between refined oil, crude oil and oilseed only

between oil and seed. The use of Tables to explain the situation concisely is,

therefore, difficult.

Palm oil is not grown locally and is being totally imported, according to the oil

refineries, mainly from Malaysia and in the form of Refined Bleached

2 It is important to note this is AVERAGE consumption data. Using an average consumption of 250 g per

person per day and 90% of the population consuming then P5, P50 and P95 are 76, 228 and 456 g respectively


Deodorised Oil (RBDO) 3 4 - exports of Crude Palm Oil (CPO) being subjected

to an export tariff 5 to protect the local consumer and industry in Malaysia

and Singapore. Imports have been flat to slightly increasing and are

currently running at circa 2.1m MT

Cottonseed oil, however, is all local production and production of seed has

been steadily increasing to almost 5m MT. Cottonseed is, however,

approximately 20% oil but FAO indicates Pakistan oil production from the

seed is closer to 10%

Canola seed is produced locally and imported (circa 25:75) but again oil from

the seed is below the theoretical expectations of 40% at circa 30-35%

Sunflower seed oil is produced from an increasing proportion of locally

produced sunflower seed (circa 67:33) and extraction rates are closer, but

still lower, too theoretical. Exports of sunflower oil are increasing accounted

for over 60% of total production in 2011

Soybean seed is not locally produced and is imported 6 as crude oil. The

imports are, however, extremely volatile presumably due to market forces.

Estimates for the relative production of Vanaspati/Banaspati (deliberately not

using the terminology ghee – see below) and vegetable oil range from 90:10

to 60:40 (some newer players in the market are more oil biased)

‘Ghee’

The terminology „Ghee‟, according to the Punjab Pure Food Rules 2011 Part

IV (5) and (6) states:

(5) “Any food which resembles ghee but not solely derived from milk fat

shall not be described on any label, invoice, voucher, advertisement, price or

trade list by any expression combining the word ghee therewith”.

(6) “The use of such expressions as “vegetable ghee”, “khalis banaspati

ghee”, “artificial ghee”, natural/pure banaspati” or “velayati” ghee is

prohibited”.

Stakeholder Inputs The following is a synopsis of stakeholder inputs – further detail is provide in

Annex 3 – and are not provided in order of interview.

3 RBDO is a not technically correct. Imports should be defined as either RBDPO or RBDPL (Palm oil and

Palm Olein respectively) 4 Refineries indicate they bring in Olein not Oil

5

http://www.researchgate.net/profile/Amzul_Rifin/publication/235980339_The_Effect_of_Export_Tax_on_Indonesia's_Crude_Palm_Oil_(CPO)_Export_Competitiveness/links/0deec515250ff48273000000 6 There is some suggestion that local extraction of imported soybean seed is taking place.

http://www.researchgate.net/profile/Amzul_Rifin/publication/235980339_The_Effect_of_Export_Tax_on_Indonesia%27s_Crude_Palm_Oil_%28CPO%29_Export_Competitiveness/links/0deec515250ff48273000000

http://www.researchgate.net/profile/Amzul_Rifin/publication/235980339_The_Effect_of_Export_Tax_on_Indonesia%27s_Crude_Palm_Oil_%28CPO%29_Export_Competitiveness/links/0deec515250ff48273000000


Table 5 – Synopsis of Stakeholder Inputs

Stakeholder Comments

Pakistan Flour Millers Association

(PFMA) – Punjab Zone

Estimate number of mills in Pakistan

to be 1,200 Provided membership list (843)

Positive to fortification Engaged in self checking during the 2007 – 2010 fortification initiative

Prices are fixed and strictly controlled so fortification must be

included in the pricing model Wheat quality of concern Consultant is of the opinion micro

feeder selection was sub optimal

Pakistan Flour Millers Association –

Sindh Circle

Provided membership list (139)

Positive to fortification Engaged in self checking during the

2007 – 2010 fortification initiative Prices are fixed and strictly controlled so fortification must be

included in the pricing model Cocerned about Chakki mills as they

account for circa 50% of wheat milled but did recognise the problems with bringing these mills

into fortification

Pakistan Vanaspati Manufacturers‟

Association (PVMA)

Supportive but gave indications

influential members may try to block PVMA from actively participating.

Despite legislation compliance is low Adulteration of vegetable oil and ghee is known to be a problem

Food Department – Punjab and

Karachi

Very supportive Responsible for wheat pricing and

monitoring market price Storage capacity inadequate

Policy and Strategic Planning Unit (PSPU) – Lahore

Supportive Have main planning role but admit

they would need to be guided Consumer awareness is low


Stakeholder Comments

Supply chain largely unknown

Planning & Development

Department (PND) – Government of

Punjab

Not fully aware about fortification Have several misconceptions

including sensory changes, in flour, being caused by fortification

Do have the power to demand compliance

Nutrition Planning Commission NPC – Islamabad

Oil noncompliance due to inadequate monitoring Cost would be a significant barrier

Consumer does have some nutrition label awareness

Pakistan Standards and Quality

Control Authority (PSQCA) – Karachi

and Lahore

Federal agency 565 Food Standards of which 42 are

mandatory Karachi analysed 800 food samples last year

Vitamin A tested using the semi-quantitative test method with “very

few failures” in Karachi and all 70 passed in Lahore

Standing Committee Commerce & Investment – Punjab Assembly

Highly supportive – asked what they could do to help

Pakistan Council for Scientific and Industrial Research – PCSIR

ISO 17025 laboratory – but not for vitamins and minerals; but willing to implement that as soon as possible.

Possible site for fortification training

METRO Superstore Typical major superstore – have

own laboratory Conduct audits on suppliers

No problems with vitamin A in own label products

Jamia Tur Rashaid Supportive Would be highly influential in consumer awareness

Has its own publications that target women and children

TechnoMight Engineers – Faisalabad Also millers who had been involved in previous fortification

Have designed their own and reverse engineered micro feeders

Industry Assessment Problems Difficulties where encountered, especially by the local team, in gaining access

to processing facilities and to obtaining interviews.


Future missions should take cognisance of this fact as it will create significant

difficulties regarding data acquisition and will require high level advocacy.

Wheat Industry Assessment This assessment is based on overall findings and not on a specific

individual mill observations.

Unlike their milling colleagues animal feed operations (with highly

modernised systems) the flour mills are locally manufactured and/or so

called „Russian Mills‟ which are actually Miag (Buhler) mills made under

license in the Ukraine. Most mills are from circa 1960‟s. Parts are locally

sourced except for the rolls which are imported from Russia, Ukraine etc.

(the name „Russian mills‟ has stuck despite local components) Some of the

larger mills are now looking to expand operations and imported milling

equipment is being favoured. Companies such as Alapala 7 have a large

footprint mainly due to their turn-key capability; Turkey is also infiltrating

the market.

The flour milling sector appears to have no significant foreign investment and

all of the mills are privately owned.

The wheat quota system has had a significant impact on the shape and

structure of the Pakistan milling sector. The quota mechanism is based on a

quaint standardised concept of the number of „bodies‟ linked to „daily milling

capacity‟. In the Government system each „body‟ is capable of milling 20

MT/day – another terminology for „body‟ is „roller stand‟. In this Government

system the quota is up to 8 „bodies‟ which has, therefore, tended to limit the

size of mills to 8 bodies (though several mills have installed more than 8

„bodies‟).

The 8 „body‟ quota system maximum has not only constrained the size of the

mills but it has also permitted inefficient mills to continue operations despite

factors such as indicated below:

The Food Department can be relied upon to store grain so mills do not

have to establish large scale storage systems

Wheat price is subsidised (as discussed earlier) and is below market

price.

The quota system is not adequately monitored so mills can actually be

not operating (ghost mills) but still receive a quota which is sold on to

other millers.

In a good year (high crop) at harvest time the wheat price can be lower than

the Food Department price so mills with adequate funds, and storage, can

7 http://www.alapala.com/en

http://www.alapala.com/en


procure significant quantities of quality wheat and then „top up‟ with Food

Department wheat of poor quality.

Several mills used terminology such as „400 times more supply than demand‟

but this could not be substantiated at all. In fact despite many mills not

working much more than 16 hours/day due to load shedding several were

expanding operations through upgrades and at least one through the

purchase of a 360 MT/day new mill and, like in the interview mentioned

above, if power was not an issue they would be constrained more by wheat

supply than demand.

Power was of great concern to the millers and ranged from „no problems‟

(mills on a new industrial estate in Karachi) to „we receive a schedule of load

shedding but do experience some non-scheduled events‟ to „no load shedding

schedules provided‟. As a rule of thumb industrial areas could expect 10

hours without power whereas in residential areas unscheduled load shedding

could happen at any time and 6 times a day was not unusual. The

consequences of an unscheduled load shedding event on a mill in full

operation are significant:

Time lost manually emptying the mill streams as a mill cannot be

restarted from a „load on‟ position

Significant energy usage to restart the mill – this energy usage drops

once the mill is stable.

The quality of the flour noticeably decreases

The short term extraction rate significantly decreases, in an

unpredictable manner, which would

impact on fortification unless the

mills were fitted with gravimetric

micro feeders

The most common pack size was 20 Kg though smaller packs are becoming

more popular (indicating possible financial pressure in the marketplace)

despite the higher cost per Kg overall.

The wheat industry produces several types of flour ranging from highly

refined to high extraction:

Suji

Fine Maida

Maida

Special Atta

Atta

Suji was sometimes also called semolina but this product was very fine

(unlike wheat semolina used in pasta production). Maida flours are

predominantly used in commercial baking operations with Atta flours being

Identified risk factor –variable premix

addition to be resolved


the most common. Opinion was divided on whether the market was moving

towards more refined flours like Maida or almost wholemeal Atta.

Bran varied from 2% in commercial Chakki operations to 15-22% in

commercial mills. Similarly the price of bran varied dramatically from Rs

5.2/Kg from the Chakki mill to Rs 21/Kg from commercial mills.

As mentioned earlier the local team also visited mills – commercial and

Chakki – with the same questionnaire and for the purposes of collecting

samples of grain, atta and maida for analysis of total iron content and phytic

acid.

Analysis of their reports was collated by Prof Anjum summarised per Table 6

below:

Table 6 – Summary of local team mill visits

Regions No. of Flour

Mills Visited

Capacity (MT/24hr)

0-100 101-200 201-400

Baluchistan 5 0 4 1

Central Punjab 32 1 8 23

KPK 7 0 4 3

North Punjab 12 1 5 6

Sindh 13 0 10 3

South Punjab 17 1 9 7

Total Flour Mills Visited 86 3 40 43

From the questionnaires the team identified:

Knowledge/awareness of fortification 56 (65%)

Willing to participate in fortification 56 (65%) with 10% undecided

Already have micro feeders 22 (26%)

Production vs Theoretical capacity is discussed later but generally the

smaller the facility the percentage utilisation decreased.

Inspection by the Food Department varied considerably from „daily‟ to

„annual‟ with the majority being visited 2-4 times per month. Not

specifically noted by the team but these visits probably only occur

during the issuance of the quota.


Support required varied from a broad statement of „financial‟ to more

detailed responses of micro feeders, specific fortification training and

premix supply (millers generally felt the cost could not be passed on to

the consumer but they were not aware Food Department was willing to

include fortification in the flour price calculation)

Laboratory facilities were extremely limited (moisture with a few doing

other checks or using (abusing) electronic facilities at PFMA and a few

other mills – note the use of such equipment is providing a false sense

of security)

Vast majority of mills did not have ISO status or a HACCP plan (some

had not even heard of the terms) and GMP status was in the main

considered „satisfactory‟ by the team. Note very few of the mills would

pass inspection in Europe and many would not pass a WFP inspection

Storage facilities were often limited with the predominant storage

mechanism being bags under cover – silos were becoming increasingly

popular with larger mills but the concept/capacity of gristing was

largely unknown.

The file embedded below contains the detailed responses.

Final Report 1.xlsx

Oil Industry Assessment This assessment is based on overall findings and not on a specific

individual refinery observations.

Unlike the wheat (and rice, cotton and sugarcane) the oilseed supply is

totally neglected. The Pakistan Oilseed Development Board was established

in 1995 but was dissolved following the 2011 devolution amendment to the

Constitution. As a result the oilseeds industry has no lobbying body and

oilseeds have no support price structure and no Government procurement

strategy to back it up.

As a result of the above local industry has focussed on importing oilseeds

though the local sunflower production is expanding.

Equipment wise the refineries are also circa 1960 – 1970‟s, invariably

physical refineries operating on a batch process (with positive release

systems) with no automated systems (though a couple of smaller refineries

are investigating the option but are currently turned off by the cost).


All of the refineries visited had generators using diesel, wood or oil as fuel

(some refineries had 2 different fuel types of generators). As a result the

gap between installed capacity and actual production was 20% or less

(though smaller refineries had higher differentials up to 50%).

Being well established in the market i.e. high Brand exposure, was a

significant factor. Lesser known brands were often constrained in expanding

operations as they had so much capital tied up in what was either a credit

sale or product being in the market on a sale or return basis. The potential

market for vegetable oil was buoyant with some players indicating expansion

of 10 to 15% per annum. Sales are highest in the winter months.

Village level processing was widely considered to be a minor portion of the

market and whilst output did fluctuate, mainly due to speculation by traders,

the overall trend was downwards.

Pack sizes were very varied from 100 g pouches to 16 L buckets with the

most popular sizes being the smaller packs 1 L and less.

Drums (175 Kg) are used in for commercial operations but the sale of loose

oil is prohibited and loose Vanaspati/banaspati is only permitted under

special license.

Market forces are moving from Vanaspati/banaspati towards vegetable oils,

apparently at the behest of the media and medical opinion but the market

remains heavily in favour of Vanaspati/banaspati at 60- 80% of the total

market. Newer players in the market have significantly higher proportionate

vegetable oils sales due to branding (so finding it difficult to enter the

market).

Premix was found in the refineries visited - all from BASF with most refineries

advising they procured from local agents (deliberate multiple) rather than

imported directly. Monitoring purchases of premix from local agents would

be a useful monitoring tool and an early indicator of potential non-compliance

issues.

Inspection from the authorities – PSQCA and more recently from the Ministry

of Health, Food Authority - was intense with visits sometimes being on a

monthly basis.

All the refineries use Nickel formate as a catalyst in the production of

Vanasapti/banaspati and PSQCA test the presence of Nickel (maximum 0.25

ppm) as part of quality monitoring – this does not, however, prevent the

refineries from adding Nickel so imitating a hydrogenated oil product (at least

in part).


Technical Capacity

Wheat

Technical capacity is the wheat sector is very weak, even by developing

world standards, and there is little to encourage a quality focussed culture.

Whilst it is true some high technology quality parameter instrumentation is

available at PFMA Lahore and at a few (very few) of the mills – such as the

Chopin Infraneo 8 9 the equipment is a) not subjected to adequate validation

(being checked against official analytical methods) and b) being used outside

the scope even Chopin claim 10 (testing flours from different mills without

bias adjustments).

The most common analysis performed by the mills is on moisture:

Grain on intake

Grain to 1st Break

Finished flour

The most common moisture meters in use are the Gann 11 and the Wile 12

though some Perten 13 Inframatic NIR instruments (older and more basic

version of the Infraneo).

Few mills have laboratories and whilst some mills (and PFMA) will use the

Infraneo to measure gluten, Zeleny etc. the same problems of validation etc.

prevail; though the presence of a qualified technician may mitigate that

problem if the „laboratory‟ is provided with some analytical equipment to

maintain the calibrations. Some mills have equipment designed to measure

damaged starch and falling number (indicator of enzymatic activity).

Oil

The oil sector is better equipped, has at least basic laboratory equipment and

does monitor quality of the oil at all stages from raw material intake to

finished product. Tests carried out by the refineries include (but may not be

an exclusive list; not all oil products require all of the following tests and not

all refineries carry out tests on all of the quality parameters mentioned in the

Standards and Food Law):

8 http://www.chopin.fr/en/produits/45-infraneo.html

9 http://www.chopin.fr/media/produits/pdf/infraneo-documentation.pdf

10 The instrument works on the basis of interactions in infrared wavelength part of the spectrum – the

instrument claims to be measuring “minerals” – but minerals do not have chemical bonds so they cannot interact. 11

http://www.gann.de/Produkte/ElektronischeFeuchtigkeitsmessger%C3%A4te/ClassicSerie/HydrometteG86/tabid/109/language/en-US/Default.aspx 12

http://www.farmcomp.fi/en/wile/products/wile-for-wood/wile-bio-moisture-meter 13

http://www.perten.com/Products/

http://www.chopin.fr/en/produits/45-infraneo.html

http://www.chopin.fr/media/produits/pdf/infraneo-documentation.pdf

http://www.gann.de/Produkte/ElektronischeFeuchtigkeitsmessger%C3%A4te/ClassicSerie/HydrometteG86/tabid/109/language/en-US/Default.aspx

http://www.gann.de/Produkte/ElektronischeFeuchtigkeitsmessger%C3%A4te/ClassicSerie/HydrometteG86/tabid/109/language/en-US/Default.aspx

http://www.farmcomp.fi/en/wile/products/wile-for-wood/wile-bio-moisture-meter

http://www.perten.com/Products/


1. Bleachability

2. Cloud point

3. Colour

4. Free fatty acids or Acid value

5. Impurities

6. Iodine value

7. Melting point

8. Mineral oil

9. Moisture

10.Nickel

11.Peroxide value

12.Refractive index

13.Sulphite

Peroxide value (PV) and free fatty acids/acid value (FFA) are the most

significant in oil fortification and all refineries visited perform such tests.

Additionally all of the refineries carry out qualitative testing for vitamin A

(simplified Carr Price reaction). Results of samples taken from the

marketplace are discussed later (Table 8).

Refineries may benefit from using more modern technologies to determine

PV and FFA such as FoodLabFat14.

Human Resource Requirements

Almost without exception the technical staff are „qualified by experience‟ and

have had no formal training in any of the aspects of wheat milling and/or oil

refining. Whilst having practical experience they have little to no theoretical

knowledge and/or understanding of what they are doing. This was most

apparent in the wheat industry were millers were conditioning their wheat

prior to milling at significantly different moisture contents and for

significantly different times (one miller was even blending wet wheat‟s with

drier wheat‟s to control his moisture content) – factors such as this have a

direct impact of fortification in that if the flow of raw material through the

mill is a variable the ability to consistently fortify is compromised. A milling

course is not being suggested but in fortification training the consistency of

the product to be fortified does need to be addressed.

In the laboratories a similar situation appears to exist. Solutions with

inadequate identification, chipped glassware, no control samples, instruments

being switched on and off etc. all indicate to sub-optimal control of quality

due to lack of some basic skills and understanding.

14

http://www.cdr-mediared.com/food-diagnostics/foodlabfat/control-quality-edible-oils-fats



QA/QC Protocols

Wheat

In the wheat industry circa 135 mills (unknown if and how many Chakki mills

were in this initiative) had participated and most of those commercial mills

visited by the consultant and Prof Anjum had been part of that initiative.

None of the mills reported any problems with fortification and considered

themselves reasonably competent in the procedure.

Under more specific questioning, however, it was identified that almost every

single mill had found it necessary to dilute the premix so that the correct

dosage rate could be achieved – mills

interviewed advised that all of their milling

colleagues had encountered the same issue

and, therefore, thought this was „normal‟.

All mills allowed the consultant to visit the mill area where fortification was

taking place and to see the equipment that was used at that time and the

following key areas of weakness were identified:

The type of micro feeder was, in almost all the cases seen (may not

apply to the whole country), of Turkish manufacture (Milleral) and

had:

o Inadequate (consultants‟ opinion) agitation

o Single screw delivery (not a major issue)

o Volumetric delivery

o Difficult to calibrate variable speed drive (VSD)

o Gearing not conducive to required delivery rate

Incorrect positioning

Incorrect delivery flow

In adequate access to monitor flow rate on a routine basis

Training on the micro feeders appears to have come from PFMA.

Oil

The oil industry is required to add vitamin A at 33,000 IU/Kg to the oils and

oil products discussed earlier. Most mills were adding the industry standards

vitamin A and D3 – though this was not altruism but because it is cheaper –

and some were adding vitamin E as well.

In most of the refineries visited by the consultant the point of addition was

suitable i.e. after the final chiller but a couple appeared to be adding it during

the final deodorisation process which is under vacuum and at high

temperatures (though they did indicate this tank was also used as a final

chiller – a rather unusual plant configuration).

Identified risk factor – feeders not

suitable and incorrectly placed


All bar one of those visited were not diluting the oil, and the one that was

was not doing it to what is

generally considered „best

practice‟ of diluting at least

50 fold.

All of the refineries had recirculation systems which they ran for 15 to 30

minutes (probably adequate if diluted premix was used but would need

verification; and some had agitation systems as well). As the only data

available at the refinery is qualitative it could not be determined if the premix

was distributed in the oil or was actually lying at the bottom of the tank. The

refineries adding slowly is probably a mitigating factor but, without

verification, it could not be determined if the oil was adequately fortified.

Wheat and Oil

QA/QC protocols were uniformly weak though some facilities were slightly

better than others. In essence some level of QA/QC is being carried out but

the production facility would have a difficult time

proving that to an outsider as record keeping was

abysmal. Records such as they were where

focussed on what was happening at that particular

point in time i.e. essentially process control.

The use of computers for record keeping – except for sales and financial

records was limited to non-existent. Graphical representation of records was

not available – though once the concept was discussed with technical staff in

the refineries (wheat facilities had virtually no data to graph) they

immediately grasped the concept, saw the benefit of the approach and some

started to do so immediately.

A robust system of record keeping which would be an integral part of a

verifiable system audit is required. This system could be developed jointly

with the regulatory authorities so forming part of external auditing.

Requirement

Whilst there is some exposure to fortification this is not the same as a full

understanding of how to fortify and adequately control the process. It is

recommended that training be designed assuming no knowledge on the part

of the trainees and that the training programme targets a „training of the

trainers‟ approach and be both comprehensive and formally presented so

that it could be implemented within a formal training environment such as a

place of tertiary education and a formal training certificate issued.

Identified risk factor – incorrect addition method

Identified risk factor –

inadequate record keeping


Production – Installed and Actual Both the wheat and the oil industry were operating below their stated

installed capacity.

The wheat industry capacity being calculated on „bodies‟ may actually

overestimate the installed capacity but the power situation is the limiting

factor (except at the new Karachi Industrial Estate) and will remain the

limiting factor for several years to come (several millers stated “at least 4

years”).

Splitting the mills into groups based on installed capacity then the claimed

operational hours were:

Mills < 100 MT/Day - Only a few hours – indication were mill may be

operating solely on their wheat quota

Mills 100-200 MT/Day - Typically 12+ hours per day

Mills >200 MT/Day - Typically 15+ hours per day

It was also noted that geographical differences also existed with average

operational times being:

Baluchistan 5-6 hours,

Smaller cities 8-10 hours and

Larger cities 16 hours.

In terms of oil refined it is necessary to generalise and split the refineries

into 3 approximately equal

numbers per group based on

their installed capacity as

declared. The claimed actual production was:

Refineries <30,000 MT per annum claimed ± 50%

Refineries 30,000 to 50,000 MT per annum claimed ± 65%

Refineries >50,000 MT per annum claimed ± 80%

Premix Requirements To calculate premix requirements the information provided by FAOSTAT, the

Planning Commission, the Food Department and by industry was compared.

When adjusting industry data to take into account load shedding etc. and

extrapolating out to all of the production facilities of the membership lists the

total raw material processed exceed local production and imports by a

significant margin. As the FAOSTAT, Planning Commission and Food

NOTE – These are very broad generalisations and probably vary significantly according to

time of year

NOTE – These are very broad generalisations


Department data was very similar the industry data was excluded from the

premix requirement estimation.

The local assessment team repeatedly came across the comment that the

wheat quota allocation was significantly different in „their area‟ (always

negatively) compared to, for example, Lahore or Karachi. The implications of

this are that the installed capacity data is inherently flawed and probably

deliberately inflated to maximise their quota.

As mentioned earlier the wheat milling industry produce multiple type of

flours with some mills producing 2 types of Atta and 2 types of Maida plus

Suji which further complicates the premix requirement.

Suji can be excluded as it is a very small proportion of production but Maida

and Atta will need to be fortified.

Using data from FAOSTAT, Planning Commission, Food Department as well as

confirmatory data provided by GAIN consultant Kalim Ghauri the total

national flour production is circa 18.2 m MT of which Chakki mills account for

47% OR 8.5 m MT and Large mills 53% or 9.7 m MT

WHO Recommendations

Flour consumption averages at 96Kg/capita/annum or 263g/capita/day and

following the WHO Recommendations15 on wheat flour fortification we can

arrive at 2 basic premix formulations. Adding only iron (as NaFeEDTA) and

folic acid the addition rate would be 200g/MT but Pakistan has a zinc problem

(discussed later) and vitamin B12 is commonly added with folic acid and this

premix would have an addition rate of 275g/MT

Currently the thinking is only adding iron and folic acid.

For the wheat industry the premix could be linked into the quota system

(flawed as that is) but not directly. The Food Department, who handle wheat

equivalent to 38% of the large mills total production and about 20% of the

national production, would not handle the premix per se but their database

could be used to widen the scope of the identifiable mills – any mill that gets

a quota is required to fortify, and prove it or they do not get the next quota.

The usage of quota could also be centrally monitored and premix sales from

a „ghost‟ mill to another mill could be prohibited by requiring mills to procure

only from registered suppliers – and prove it.

Excluding Chakki mills the premix requirement would be 1,940 MT per

annum based primarily on Atta production.

A similar approach was used on the oil data and circa 2 m MT of oil and oil

products require fortifying at 33,000 IU/Kg which is 33.3g/MT of 1m IU/g

vitamin A. Total premix requirement would be circa 67 MT 15

http://www.who.int/nutrition/publications/micronutrients/wheat_maize_fortification/en/

http://www.who.int/nutrition/publications/micronutrients/wheat_maize_fortification/en/


Equipment Requirements

Synopsis

Each mill will require careful assessment as the flow rate of flours – assuming

both Atta and Maida are to be fortified – will range considerably. Whilst one

supplier will have equipment to suit all of the anticipated flow rates one

model of micro feeder will not be capable of covering the range of flow rates.

The alternative, especially for the smaller mills i.e. <100 MT/day (may also

be suitable for larger producers) is to use a proportional mixer like the Roff

3-in-1. This mixer can fortify and mix faster than the mill can produce the

flours so if the mill installs some extra bin space for flour storage then a

single unit can fortify multiple flours. The cost is equivalent to a single mid-

range micro feeder.

Requirements

World Grain supplier list 16 is possibly the biggest directory of equipment

suppliers but is heavily biased towards USA companies and companies exist

in Pakistan (TechnoMight discussed earlier) who could „reverse engineer‟ any

piece of equipment at very cost effective prices.

During the local team assessment an underlying theme was that the

equipment and the premix would have to be provided as the consumer would

not/ could not afford even the Rs 6/20Kg increase. This attitude will create

the market for copies of existing feeders and, possibly, inferior copies at that.

If we make some assumptions that all mills are generating at least 2 types of

flour then mills doing less than 50 MT per day would be producing around 40

MT of flour per day of which Atta around 60% or 1 MT per hour maximum

and the other flour Maida at 660Kg per hour. The variation in the flow rate

may also be significant. Such mills would require very low speed feeders

though a more logical option would be

some type of proportional mixing

equipment such as the Roff 17 3-in-1.

This type of equipment has an inlet

hopper with a low level sensor which

stops the equipment if there is no product

to fortify. The equipment has a very

efficient mixing system (right) and this

concept can also be introduced into large

milling operations – replacing part of the

16

http://sosland.gcnpublishing.com/gmabg/index.cgi?final_cat1=7&final_cat2=145&cat1_2=7&cat2_2=145&search_type=&search=search 17

http://www.roff.co.za/

http://sosland.gcnpublishing.com/gmabg/index.cgi?final_cat1=7&final_cat2=145&cat1_2=7&cat2_2=145&search_type=&search=search

http://sosland.gcnpublishing.com/gmabg/index.cgi?final_cat1=7&final_cat2=145&cat1_2=7&cat2_2=145&search_type=&search=search



auger with the mixing paddles.

A major advantage of this equipment is that it can operate faster than the

mill can produce (speeds of 4 MT/hour can be achieved) meaning that the

mill would need only 1 piece of fortification equipment with multiple storage

bins for the flours to be fortified. Alternatively the flour could pass through

the equipment on the way to the packing station.

The only known supplier of this equipment is ROFF Industries (Pty) Ltd; Cnr.

Piet de Vries and 7th Avenue, Kroonstad, 9499, South Africa;

[email protected], +27 (0) 56 212 2697, +27 (0) 56 212 2696,

http://www.roff.co.za This equipment was specifically designed by Roff to

capacitate South African small millers when fortification became mandatory

in 2003. Discussions with Roff should be opened to have the equipment

made locally under license.

Larger mills would require micro feeders though each mill would need to

supply some highly specific pieces of information so that the necessary

gearing can be incorporated in the feeder.

The information required would be the maximum and minimum flow rates

through each of the relevant flour collection augers.

Basic reagents for the modified AACC 40-40 iron spot test would be required

– Potassium thiocyanate and 2N Hydrochloric acid

For the oil industry the only requirement would be for the refineries to dilute

down at least 50 fold the vitamin A they are „currently‟ adding. Equipment –

such as that supplied to Afghanistan – could be utilised but that option is not

a priority and could be viewed as being not cost effective.

Semi qualitative test kits from BASF will be required along with the necessary

chemicals – embedded below

Small Scale Processors In the wheat industry, with very few exceptions, the Chakki mills are not

commercial operations (defined as selling their own wheat, procured in the

marketplace and/or self-grown, under their own brands).

Urban mills are typically capable of milling 240 to 320 Kg/hour and a few

even have their own cleaning equipment and operate 4 hours per day

servicing clients who bring in anything between 10 and 50Kg of wheat for

grinding.

mailto:[email protected]



Milling costs were typically Rs 3/Kg though some millers charged Rs 5/Kg;

cleaning costs were Rs 0.75/Kg

There was no difference in milling costs between the China Chakki

(hammer/pin mill type) and the Stone Chakki (rotating stone of local origin)

as the power requirements were similar.

Stone mills need to sharpen the grinding stone every week – most do it

themselves as the stone grind pattern is basic – and millers observed clients

could tell when a stone needed sharpening.

No small scale oil operations were identified – being mainly in the deep rural

areas.

Commercially operating Chakki mills do exist in urban areas but there

numbers appear to be small and produce around 2 MT during the 12+ hours

they operate per day.

Fortification is possible in such mills, with a little reconfiguration to the flow

line, but the fortification process would be clearly visible which may lead to

consumer resistance unless a strong advocacy campaign has convinced

consumers of the benefits. The mill itself, being open to the street, could be

used as an advocacy point in its own right. Equipment such as the Roff 3-in-

1 discussed above would be suitable.

Specifically designed for hammer mills, and now being extensively trialled in

Africa, is the SANKU18 (shown below) which fits over the inlet hopper to

hammer mill and can be

installed and commissioned in

15 minutes. The advantage of

the system is that it operates

on the basis of proportional

dosing so for every „X‟ g

(typical setting is 330g) of

grain that flows through the

hopper „Y‟ g of premix is

dispensed with the grain which

is then milled – which carries

out the mixing process (actually more efficiently than a roller mill can mix)

before discharge back into the clients receptacle. The „doser‟ also has an

inbuilt monitoring device that indicates how much grain has been milled and,

as it assumes the grain has been fortified, how much premix has been used

and, therefore, when the miller will need a fresh supply of premix. BASF has

reached an agreement with SANKU and supplies premix in 5Kg bags and

provides the SANKU at a discounted, or even gratis, price based on reaching

18

http://sanku.com/

http://sanku.com/


a contractual agreement with the miller. The communication of grain milled

has obvious positive implications for food consumption surveys.

Whilst GAIN Pakistan has advised that provisions can be made in law to

require Chakki millers who are milling a client‟s own grain to add fortification

premix as per a law which requires salt crushers to add iodine to clients

bringing their own salt a brief look at the UNICEF/MI Vitamin and Mineral

Deficiency19 (VMD) Global Assessment report of 2004 indicates Pakistan has

an estimated 17% of households with access to iodised salt (and this is figure

will be considerably smaller if the criteria is adequately iodised) which clearly

indicates that compliance monitoring is extremely weak.

With Chakki mills it is also important to note that:

1. Fortification is essentially voluntary (having a law requiring the mills to

add will not prevent the consumer from finding a miller prepared to

flout the law)

2. The cost of fortification moves from <1% increase in commercially

fortified flour to possibly doubling the cost of milling the consumers

grain (fortification becomes a percentage of milling cost as the grain

has „no value‟)

Additionally:

1. Extensive consumer advocacy would be required

2. Monitoring resources would need massive expansion

3. Distribution of premix would be a significant logistical issue

Vitamin A Fortification Compliance and Oil Quality Samples submitted to PCSIR 3rd September 2014 for free fatty acid, peroxide

values and vitamin A. Samples to be tested against the Punjab fortification

requirements at per Table 7 below.

19

http://www.micronutrient.org/CMFiles/PubLib/Report-67-VMD-A-Global-Damage-Assessment-Report1KSB-3242008-9634.pdf




Table 7 - Punjab Pure Food Rules 2011 – Fortification Requirement

Fortify Minimum 33,000 IU/Kg No Fortification Required

Refined Blended vegetable oils Cottonseed Oil

Refined Canola Oil Groundnut Oil

Refined Sunflower Oil Sesame Oil

Refined Soybean Oil Olive Oil

Vanaspati/Banaspati Poppy seed Oil

Refined Palm Oil Coconut Oil

Refined Palm Olein Rapeseed/Mustard Oil *

Refined Maize Oil Linseed Oil

Table Margarine Sunflower Oil *

Margarine Spread Taramira Oil

Spread Almond Oil

Soybean Oil

Niger seed Oil

Safflower seed Oil

Maize Oil * * These are not typographical errors – „Refined‟ is deliberately specified on fortified products

Previous Studies

PSQCA – no (or very few) failures in past 12 months

Mehmood et al 2011 20 Oil - 28.6% vitamin A detected, FFA 0.03 to 0.80 with

68.6% compliant, PV 0.7 to 84 with 80% compliant, weight 48% compliant

Mehmood et al 2013 21 Ghee - 47.5% vitamin A detected, FFA 0.08 to 0.33

with 75% complaint

Methods used in this study:

AOCS 1998 official method Ca 5a-40 For FAA

AOCS 1998 tentative method Cd 8-53 for POV

AOAC 2007 for vit A

BP 2007 method for vit D

In Table 8 below 44 of the 45 samples could be tested for vitamin A. 31 of

the 44 (70.5%) samples indicated the presence of vitamin A but only 6

(13.6%) samples could be considered compliant; 4 of which did not even

20

http://jcsp.org.pk/ArticleUpload/4394-20718-1-CE.pdf 21

http://www.researchgate.net/publication/220027405_Quality_Evaluation_and_Safety_Assessment_of_Different_Cooking_Oils_Available_in_Pakistan

http://jcsp.org.pk/ArticleUpload/4394-20718-1-CE.pdf




indicate the presence of added vitamins; and 6 inadequately fortified – all of

which did not indicate addition. No vitamin D was detected in any of the

samples.

On Free Fatty Acid (FFA) or just Acid value all of the 45 samples were

compliant ranging from 0.03 to 0.09 (average 0.04) mg KOH/kg. All of the

samples would pass either an oilor a Vanaspati/banaspati specification. This

levelof results would satisfy WFP specifications of 0.1% maximum (as

palmitic acid) for fortified palm olein.

On Peroxide Value (PV) the situation was much more disturbing. On oil –

maximum value of 10

milli equivalents

KOH/Kg all bar 1 of

the 14 oil samples

passed. The range (excluding the 12.6 analysis), however, was from 3.4 to

7.3 with an average of 5.5 which, whilst within the national standard, is

above the WFP specification of 2 milliequivalents for fortified palm olein. It is

also far higher than the assessment team was led to believe would be the

case as refineries indicated they worked to specifications close to, or below, 1

millequivalent for both oil and Vanaspati/banaspati. Increasing from 1 to 5

in the short period the oil industry indicated there product was in the

production to consumption chain – circa 2 months or less – is disturbing and

will influence vitamin A stability.

Table 8 – Analytical results – market samples; oil and ghee

ID Oil ‘Ghee’ Indicating fortification

Fortified FFA PV Vitamin A

1 √ Yes –A/D No 0.08 6.3 ND

2 √ Yes –A/D No 0.07 6.0 851

3 √ No No 0.04 4.3 ND

4 √ No No 0.04 4.3 726

5 √ No Sample problem

0.03 3.7

6 √ No Yes -

inadequate

0.08 7.3 21659

7 √ No Yes - non

compliant

0.03 3.4 11104

8 √ No Yes - non

compliant

0.04 6.0 19216

9 √ No Yes - non

compliant

0.03 4.3 9296

10 √ No Yes - non

compliant

0.04 4.0 15847

11 √ No Yes - non

compliant

0.03 4.1 11083

Identified risk factor – possible rapid increase, over a short

period, in PV with negative implications for vitamin A stability


ID Oil ‘Ghee’ Indicating

fortification

Fortified FFA PV Vitamin

A

12 √ No Yes - non

compliant

0.04 6.7 3448

13 √ No Yes - non

compliant

0.03 12.6 1259

14 √ No Yes - non

compliant

0.04 4.0 17761

15 √ Yes –A/D/E No 0.03 5.4 548

16 √ Yes –A/D/E No 0.04 5.7 665

17 √ Yes –A/D No 0.04 4.8 710

18 √ Yes –A/D No 0.07 5.8 ND

19 √ Yes –A/D No 0.09 5.3 690

20 √ Yes –A/D No 0.03 5.3 183

21 √ No No 0.03 3.6 ND

22 √ No No 0.03 7.0 328

23 √ No No 0.04 5.0 207

24 √ Yes –A/D No - dilution

error?

0.03 6.6 2343

25 √ Yes –A/D No -

dilution error?

0.03 7.0 3797

26 √ No Yes - compliant

0.03 5.0 32254

27 √ Yes –A/D Yes - compliant

0.04 6.2 35349

28 √ Yes –A/D/E Yes - compliant

0.04 6.3 31372


0.04 5.0 31214


0.04 5.6 28939

31 √ No Yes -

compliant

0.04 5.3 34064

32 √ No Yes -

inadequate

0.03 6.0 24340

33 √ No Yes -

inadequate

0.04 5.0 21775

34 √ No Yes -

inadequate

0.04 4.7 21730

35 √ No Yes -

inadequate

0.04 7.7 20603

36 √ No Yes -

inadequate

0.04 6.2 22987


ID Oil ‘Ghee’ Indicating

fortification

Fortified FFA PV Vitamin

A

37 √ Yes –A/D/E Yes - non

compliant

0.04 4.7 7790

38 √ No Yes - non

compliant

0.05 6.0 9680

39 √ No Yes - non

compliant

0.04 5.0 8756

40 √ No Yes - non compliant

0.04 6.7 10443


0.04 5.0 6480


0.04 5.3 3540


0.03 7.4 2542


0.04 7.0 2912


0.04 4.6 11415

On the Vanaspati/banaspati analysis all passed on FFA as indicated above but

19 of the 31 samples (61.3%) failed on PV. As with the oil industry the

range was similar 3.6 to 7.7 milliequivalents with an almost identical average

of 5.7 milliequivalents.

Iron and Phytic acid levels Methods used in this study were from AOAC 2012 for iron and phytic acid

A total of 368 samples were collected for total iron and phytic acid content

and comprised of Grain (132), Atta (160) and Maida (73). Additionally 3

samples of Atta 2 – a finer Atta flour were collected but left out of the

subsequent analysis as they were no different to the Atta samples.

Samples were placed into a matrix based on product type (grain, atta and

maida), region (Baluchistan, Central Punjab, KPK, North Punjab, Sindh,

South Punjab) and mill type (Chakki and commercial).

The samples were then tested using the Z statistic which compares the

means of the different populations:

Standardized score = Z = (X - μ) / σ

In the tables below the means for grain, atta and maida are compared by the

means for each region – the sample size dictates that it would be an over

extrapolation to compare the regions against one another.

http://stattrek.com/AP-Statistics-1/Position.aspx?Tutorial=stat


Results below in Table 9 are considered to be extremely closely related.

Table 9 – Mean values and Z stat for grain by total, mill type and region

Fe

(PPM)

St

Dev

Phytic

acid (%) St Dev Z stat

TOTAL 50.00 8.06 0.94 0.09

CHAKKI 49.32 0.96 0.08 0.21

MILL 50.36 0.93 0.04 0.11

Baluchistan All

No Data

Central Punjab 50.78 0.93 0.10 0.12

KPK 43.41 0.97 0.82 0.40

North Punjab 47.85 0.96 0.27 0.23

Sindh 49.12 1.01 0.11 0.79

South Punjab 49.47 0.91 0.07 0.33

Baluchistan

Chakki

No Data

Central Punjab 52.86 0.97 0.35 0.36

KPK 45.57 0.95 0.55 0.13

North Punjab 46.42 0.97 0.44 0.39

Sindh 47.54 1.00 0.30 0.65

South Punjab 49.93 0.92 0.01 0.19

Baluchistan

Mill

48.19 1.03 0.22 1.06

Central Punjab 52.97 0.88 0.37 0.65

KPK 42.48 0.98 0.93 0.52

North Punjab 51.37 0.91 0.17 0.26

Sindh 50.02 1.02 0.00 0.86

South Punjab 49.01 0.90 0.12 0.48

Table 9 above indicates that the national mean total iron content was 50 ppm

and the phytic acid content 0.94 %. The mean values for grain at different

mill types and in different regions was no different to the national mean.

Table 10 below indicates the same conclusion – note that the iron and phytic

acid content have not significantly dropped and that the standard deviations

of both the iron and phytic acid data is not much different between the grain

and the atta.

Whilst the grain data was close to a normal distribution with the iron varying

from 32 to 70 the atta results ranged from 2 to 60 ppm. Whilst excluding

results around 2 and 12 could be justified their

were also some samples in the low 20‟s meaning

that atta flour, which is what will be subject to

compliance monitoring has a natural intrinsic

Identified risk factor – high

variation in intrinsic iron


content of anything from 20 to 60 ppm before the addition of 20 ppm of

NaFeEDTA making monitoring on iron content highly questionable.

Intrinsic iron is poorly absorbed and with high phytic acid levels in Atta flour

this will be even more prevalent. The WHO recommendations do not take

into account intrinsic iron as it is, nutritionally, of little significance regardless

of the level (up to 60 ppm) and consumption of fortified flour with highly

bioavailable iron dictates the level of fortification.

As analysis of fortified wheat flour measures total iron content i.e. intrinsic

plus added and prior knowledge of the intrinsic content before fortification

would be impractical the regulatory authorities would need to use more

complex chemical protocols i.e. measuring the content of EDTA and back

calculating even then system audits will need to support any analysis data.

The variation in intrinsic iron content could also cause problems in the

development of a fortified wheat standard as such a standard would have to

recognise that both environment and extraction significantly cause variation

in intrinsic nutrient content and that neither of these factors can be

controlled or predicted with adequate certainty for legal purposes.

See also Graphs 1 and 2 below.

Table 10 – Mean values and Z stat for Atta by total, mill type and region

Fe

(PPM)

St

Dev

Phytic



TOTAL 41.20 7.25 0.83 0.10

CHAKKI 39.66 0.85 0.21 0.18

MILL 42.02 0.82 0.11 0.10

Baluchistan

All

44.76 0.85 0.49 0.20

Central Punjab 42.66 0.81 0.20 0.20

KPK 36.73 0.86 0.62 0.28

North Punjab 39.79 0.82 0.19 0.15

Sindh 40.68 0.85 0.07 0.20

South Punjab 40.28 0.84 0.13 0.09

Baluchistan

Chakki

43.86 0.87 0.37 0.35

Central Punjab 39.44 0.83 0.24 0.01

KPK 33.53 0.82 1.06 0.15

North Punjab 39.65 0.89 0.21 0.63

Sindh 39.93 0.85 0.18 0.24

South Punjab 38.95 0.84 0.31 0.10

Baluchistan

Mill

46.11 0.83 0.68 0.04

Central Punjab 43.77 0.80 0.35 0.27

KPK 38.55 0.88 0.36 0.53

North Punjab 39.86 0.78 0.18 0.49

Sindh 41.01 0.85 0.03 0.18

South Punjab 41.26 0.84 0.01 0.09

Table 11 below indicates the same situation with Maida flour not being

distinguishable from the national mean but the same problem of the rangle

of intrinsic iron from 1.5 to 39 ppm indicates compliance monitoring will need

to consider audits as supporting data to quality measurement. See also

Graph 3 below.

Table 11 – Mean values and Z stat for Maida by total, mill type and region

Fe

(PPM)

St

Dev

Phytic


TOTAL 16.57 8.72 0.10 0.05

CHAKKI

MILL 16.49

0.09

0.01 0.21


Baluchistan

All

Central Punjab

KPK

North Punjab

Sindh

South Punjab

Baluchistan

Chakki Central Punjab

KPK

North Punjab 22.58

0.10

Sindh

South Punjab

Baluchistan

Mill

Central Punjab 13.99

0.10

0.30 0.02

KPK ?

0.13

North Punjab 15.62

0.10

0.11 0.10

Sindh 21.25

0.11

0.54 0.20

South Punjab 17.34

0.10

0.09 0.11

Note only 1 sample of Chakki Maida flour.

Graph 1 – Intrinsic iron variation in Grain

0.00

10.00

20.00

30.00

40.00

50.00

60.00

70.00

80.00

1 6

11

16

21

26

31

36

41

46

51

56

61

66

71

76

81

86

91

96

10

1

10

6

11

1

11

6

12

1

12

6

13

1

Grain


Graph 2 – Intrinsic iron variation in Atta Flour

Graph 3 – Intrinsic iron variation in Miada Flour

Annex 4 provides the statistical analysis provided by Dr Saeed which, using

the more stringent means squares technique does find significant differences. That different statistical techniques generate differing conclusions is not unknown and both methods used, are in themselves, both valid. Dr Saeed

has used the more stringent mean squares test which demonstrates, for example, that 43.9% and 39.9% are significantly different. This needs to be

put in context in that grain intrinsic iron was shown, nationally, to vary from 32 to 70 ppm and that the Southern African Grain Laboratory, an ISO 17025 laboratory for vitamin and mineral analysis, has a 95% coefficient of error of

close to 18%. From Table 11 above the national mean value for iron is 50

0.00

10.00

20.00

30.00

40.00

50.00

60.00

70.001 7

13

19

25

31

37

43

49

55

61

67

73

79

85

91

97

10

3

10

9

11

5

12

1

12

7

13

3

13

9

14

5

15

1

15

7

Atta flour

0.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

40.00

45.00

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43 46 49 52 55 58 61 64 67 70 73

Maida Flour


ppm with a standard deviation of 8 ppm with a 95% coefficient of error of 9 ppm. From a practical view point the differences between the regions would

not be measurable.

Wheat Price Commentary The following was obtained from http://www.qeemat.com/wheat-price-in-

pakistan/ - „prices having almost doubled, farmers unable to find buyers at

Government rates and, some positive news, possible investment in wheat.‟

Zinc Pakistan is placing considerable effort into alleviating the zinc deficiency

problem through bio fortification.

The Harvest Plus Zinc Wheat indicates the average nutrient content is 25

mg/Kg and the target is 33 mg/Kg. In 2009 the release date was estimated

at 2012 – discussions with NPC indicate the release date to be now 2015 (3

years late) with no indication of how close to the „target‟ bio fortification has

achieved.

Pakistan has a long history of not using new seed in the wheat programme

(hence the very poor yields) and it is unknown how this will actually be

achieved through the Punjab Food Authority advise that the Seed

Cooperative and private seed companies are on board with the programme.

Even though Pakistan, generally, uses high extraction wheat flour – Atta –

the anticipated zinc increase in the wheat is 30% or 8 mg/Kg whereas WHO

recommendations would indicate 40 mg/Kg is feasible through fortification.

The down side is that fortification will not reach the deep rural area but there

is no guarantee that bio fortification will do either in a sustainable manner.

PS: Adding 40 ppm Zn as ZnO and 0.01 ppm as vitamin B12 would increase

dosage rate (and, therefore, distribution cost) by 25% with a similar increase

in premix cost. Based on costing models provide to the consultancy team

the cost of fortification is Rs6/20 Kg of which premix is calculated at

Rs1.2/20Kg. Adding zinc as a fortificant (with vitamin B12) would take that

cost to Rs1.4/20Kg

http://www.qeemat.com/wheat-price-in-pakistan/

http://www.qeemat.com/wheat-price-in-pakistan/


Conclusions and Recommendations

General

Annex 3 contains a significant quantity of clarification material that was

placed in the Annex to bring only the main points into the main body of the

report.

Wheat

Despite wheat fortification being trialled in Pakistan anything above even the

most basic knowledge of fortification was missing. Equipment was supplied

that was sub-optimal (mainly because the dosing capacity and the dosing

requirement did not match) and was, in almost all cases, incorrectly placed.

That some millers complained about the inability to get feeders repaired

locally also indicates the quality of the feeders was not sub-standard. The

type of feeders supplied would also not suit the operational profiles of most,

if not all, smaller (<2 MT/hour).

Information provided by the mills on actual production, when extrapolated

nationally, could not be verified by data from other sources i.e. Food

Department, Planning Commission and FAOSTAT

Recommendation 1

Assume Pakistan has had little to no exposure to wheat fortification. What

was done appears haphazard and subject to inadequate oversight

Recommendation 2

Assume almost all of the micro feeders will need replacing – a possibility

exists that some could be refurbished and relocated but this could prove

uneconomic.

Recommendation 3

Before implementing Recommendation 4 it is suggested that short

sensitisation workshops be held which provide an overview of the course

content to be used in Recommendation 4

Recommendation 4

Fortification training i.e. the typical „Millers Best Practices‟ concept as used by

FFI consultants should be implemented through a „Training of Trainers‟ so

that local teams could ensure widest possible coverage and provide, at

millers cost, top up and/or revision training as required.

Recommendation 5

Should the programme consider that micro feeders need to be procured on

behalf of the programme then the millers should be capacitated to identify


what flow rate of feeder(s) are required – this would be part of

Recommendation 3.

The logic behind this is that industry information provided to entities outside

of the mill may have hidden agendas i.e. influencing the quota allocation. By

placing the onus on the miller to identify current (and possibly future)

requirements the programme can have a reasonable level of confidence the

equipment supplied would be suitable (Recommendation 3 would have

highlighted the problems with poor feeder selection).

Requiring the miller to procure and then apply for a rebate (partial or full) is

one option though a more cost effective option would be bulk purchasing

through a tender based on the information provided by the mill.

Recommendation 6

The premix supply chain needs to be secured. The oil industry uses local

agents and this model could be easily transferred to wheat. This chain could

be used as part of the monitoring system

Oil

The oil industry has had mandatory fortification with vitamin A (vitamin D is

also added though not legislated) for many years. It is widely known in the

industry that compliance levels are „low‟ but data from the regulatory

authorities indicate almost complete compliance. Both industry and the

regulator use semi-quantitative measurements to determine compliance so

determining adequately fortified oil and oil products is not possible.

Industry is adding vitamin A in the correct place (those seen by consultant

Randall) but is adding it incorrectly i.e. addition is made of the concentrated

vitamin A and not the generally accepted method of pre-dilution (50 fold)

and recirculation. Whilst industry does recirculate the difference in specific

gravity of the concentrated vitamin A and the oil/oil product indicates the

vitamin A could be simply dropping to the bottom of the tank and only very

slowly blending with the oil or oil products.

Industry visited by consultant Randall indicated production typically produced

product with a FFA approaching zero and a PV below 1 though the market

results would indicate that either production had a PV significantly higher

than 1 or something drastic is happening in the distribution chain causing an

increase in PV.

Recommendation 1

Before implementing Recommendation 2 it is suggested that short

sensitisation workshops be held which provide an overview of the course

content to be used in Recommendation 2


Recommendation 2

Fortification training i.e. the typical „Oil Fortification Best Practices‟ concept

as used by FFI consultants should be implemented through a „Training of

Trainers‟ so that local teams could ensure widest possible coverage and

provide, at refiners cost, top up and/or revision training as required.

Recommendation 3

The premix supply chain needs to be identified and secured. This chain could

be used as part of the monitoring system.

Monitoring

Monitoring in wheat is not geared to fortification but price control and

moisture and in oil is poorly equipped to do so. Whilst generally

unannounced ensuring that the inspector obtains a compliant sample is not

difficult and the regulatory authorities appear to be taking little notice of

independent studies carried out on market samples of oil and oil products

that clearly indicate a high level of non-compliance or, potentially worse, oil

and oil products whose quality was sufficiently poor (PV and FFA) that any

added vitamin A has been oxidised and rendered nutritionally useless.

Recommendation 1

As NaFeEDTA is water soluble the probability exists that adapting the

methodology used with iCheck IRON could be used as part of the monitoring

system

Recommendation 2

Use iCheck Chroma3 to monitor vitamin A

Recommendation 3

Use FoodFatLab22 to determine PV and FFA

Recommendation 4

The degree of hydrogenation carried out in the production of

Vanaspati/banaspati needs to be monitored

Recommendation 5

Revisit the existing standards for wheat and oil to see if they are stringent

enough to make fortification viable. The oil quality standards on PV are not

ideal and industry should be capable of producing low PV oil and oil products.

Recommendation 6

YOU MAY WANT TO DELETE THIS

22




Subject the laboratories involved in the testing of vitamin A, PV and FFA to

proficiency testing. Sample tested by iCheck, Potsdam University and SGS

Germany (latter 2 laboratories used HPLC) had reasonable correlation but

differed entirely with the Pakistan results. This puts the analysis of PV, in

particular, in question. Iron analysis was as expected though some samples

look questionable (low iron content)


Annex 1 A TOR International consultant

Wheat Flour Industry

a) General tasks:

To conduct a detailed assessment at each of the selected flour mills and Chakki mills in Pakistan in order to determine their respective equipment and premix requirements, recommend protocols that can be adopted within the

current manufacturing process that can ensure fortification requirements can be consistently fulfilled and determine the training requirement for

production personnel if applicable. b) Specific tasks:

Develop a checklist and questionnaire and assessment methodology. Conduct meetings with Pakistan Flour Mills Association, Food

Department, Health Department, Punjab Food Authority, Planning Commission, development partners and any other important stake holders to seek their inputs.

Stratify large scale, medium and small scale flour mills and chakkis for assessment based on the production and geography.

Visit all selected flour mills and meet with the designated production personnel and management staff. (Expected number of mills to be assessed is 90 (7% of total), stratified based on production and

geography) Visit all selected Chakkis and meet with the designated production

staff and owner. (Currently there is no source of information available providing exact number of chakkis. It is expected that a total of 48

Chakkis, stratified province/region wise would be required to be visited)

Estimate the production capacity and actual production achieved by

each of the producers and based on this provide projections for premix requirements

Based on the plant layout, design and capacity, develop a detailed equipment list and/or process changes that would be required to fortify at an appropriate quality. The specifications should be detailed

enough to enable procurement of appropriate micro-feeders. The consultant should also provide a list of potential suppliers of such

equipment and estimated costs of process upgrades that are proposed. Document production protocols in place at each of the manufacturing

plants and provide recommendations of appropriate QA/QC protocols

that would have to be adopted to produce fortified products in accordance with National standards.

Observe technical capacity of production personnel and in consultation with plant managers provide an objective brief on extent and type of training that would be beneficial/required.


Identify wheat flour consumption pattern and variations among different provinces, which could impact on required level of

fortification.

Oil and Ghee Industry

a) General tasks: To conduct a detailed assessment at each of the selected Oil and Ghee mills

and unregulated producers, in Pakistan in order to determine their respective equipment and premix requirements, recommend protocols that can be adopted within the current manufacturing process that can ensure

fortification requirements can be consistently fulfilled and determine the training requirement for production personnel if applicable. Generate

evidence for level of Vitamin A and D in the oil and ghee available in different parts of the country.

b) Specific tasks: Develop a checklist and questionnaire and assessment methodology.

Conduct meeting with Pakistan Vanaspati Mills Association, Pakistan Standards and Quality Control Authority, Health Department, Punjab Food Authority, Planning Commission, development partners and any

other potential stake holder to seek their inputs. Stratify large scale, medium and small scale Oil and Ghee Mills and un-

regulated producers for assessment based on the production and geography.

Visit all selected Oil and Ghee Mills and meet with the designated

production personnel and management staff (Total expected mills to be visited with geographic distribution is 16 (15% of total).

Visit all selected un-regulated producers of the oil and ghee, stratified based on geography from all provinces and regions. (the total

expected producers will be 10) Estimate the production capacity and actual production achieved by

each of the producers and based on this provide projections for premix

requirements Based on the plant layout, design and capacity, develop a detailed

equipment list and/or process changes that would be required to fortify at an appropriate quality. The specifications should be detailed enough to enable procurement of appropriate dosing equipment. The

consultant should also provide a list of potential suppliers of such equipment and estimated costs of process upgrades that are proposed.

Document production protocols in place at each of the manufacturing plants and provide recommendations of appropriate QA/QC protocols that would have to be adopted to produce fortified products in

accordance with National standards.


Observe technical capacity of production personnel and in consultation with plant managers provide an objective brief on extent and type of

training that would be beneficial/required. Collect sample and provide analysis of level of Vitamin A and D in Oil

and Ghee from different sources and parts of country by having a representative sample. (48 samples to be collected)

Annex 1 B TOR Local consultant a) General Task

To co- lead the detailed country wide industrial assessment for flour mills,

chakki mills, oil and ghee mill in Pakistan. The assessment shall provide an

in-depth analysis of the current state of equipment and industrial processes

for wheat flour production. The analysis shall provide guidelines for the

development of industry and human resource capacity building for large scale

fortification. This may include buy not limited to the premix requirements,

fortificant supply chain mechanisms currently in place and current human

resource capacity. Conclusively recommend protocols that can be adopted

within the current manufacturing process to ensure mandatory fortification in

country.

b) Specific tasks:

Provide technical inputs on study design, checklist, assessment

methodology and questionnaire.

Co-lead and facilitate meetings of assessment team with key

stakeholders (PFMA, PVMA, Food Department etc)

Gather available literature, data, and other information to facilitate the

in country work of international consultant.

Recruitment of six data collectors in collaboration with Project Manager

for food fortification as per qualification and experience specified by

GAIN.

Arrange and co-facilitate training of data collection team including

logistic arrangements, field orientation and pretest of questionnaire.

Supervise the data collection team, data collection process, and cross

verification of randomly selected 5% data of the team.

Manage collection of samples of wheat grain, wheat flour, edible oil

and ghee as per study design.

Identify and assist in selection of laboratory for analysis of samples

and coordinate with selected laboratory for managing analysis of

collected samples.


Analyze the results of sample reported by the laboratory and data

collected by the data collection team, and shape it for using in the

assessment report by the international consultant.

Provide support and inputs to international consultant for report writing.


Annex 2A Wheat Industrial assessment for wheat flour in Pakistan for food fortification

Flour Mill Organization Profile

Name of Flour Mill: ________________________________________________________________

Address:

________________________________________________________________

CEO: _____________________________________________________________

___

Telephone: ______________________________

Contact Person: _______________________________

No of Workers: ______________________________

Area of Flour mill: __________________________________

Is there any food technologist? __________________

Milling Capacity: ___________________________________ Storage Capacity: _________________________________________

Flour Production & Quality

Question Answer Remarks

Grinding Capacity….Ton per

24 hrs. 3 Shifts?

Grinding per unit of electricity? (Normal 20kgs per unit)

Extraction percentage of Atta

Extraction percentage of

maida

Extraction percentage of Sugi

Extraction percentage of Bran

Types of flour



Export potential of wheat product?

Do you suggest any change in food laws?

Types of flour

Export potential of wheat product?

Do you suggest any change in food laws?

What do you know about the National Food Fortification

Program in Pakistan?

Role of food department?

How often are you inspected by the authorities, which ones and what do they do?

Wheat cleaning equipment‟s

No. of break roll bodies

No of reduction roll bodies

Which sifters are being used

in your mill?

What are tempering conditions

What kind of package material is used for flour packaging?

What process do you use to mill your grains?

Is the mill environmentally

friendly?

What is the shelf life of

different products produced here?

Is there any product recall process?

If you are to adopt flour fortification, what kind of

assistance would you like?

Where do you get your raw

material from? (farmers/traders/own



farm/contract farms, Govt)

Installed capacity

Actual production

Extraction rate

Operating hours – hours per day, days per week, weeks

per year

Reason for not fully

operational

Total production in last year

Schematic Wheat: Inspect the mill and sketch

the factory layout with approximate dimensions and note the following:

a. Mill type: b. Country of

manufacture: c. How many mills are

installed in parallel? (take photos if permitted):

Which analysis regarding the composition of flour?

Location of the current fortification point

Pest control method

Is there any fortificant used

at the mill

Food safety issues in the mill

ISO/HACCP Certified?

Who fortifies and what QA/QC checks

Laboratory facilities – basic to good

GMP status

Suitable place to store premix

Current buying price of raw



material

Variation in price during the year – how much?

Variation in price during the year – how much

How wide a distribution area?

Types of storage

Storage capacity

Marketing strategies

Remarks ------------------------------------------------------------------------------------------------------------------------------------------------------------------

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

------------------------------------------------------------------------------------------------------------------------

Critical remarks (only filled by Surveyor)-------------------------------------------------------------------------------------------------------------------------------

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------

-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Suggestions:------------------------------------------------------------------------

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------

----------------------


Name of the resident person Surveyor provided information

Date:____/_____/_____


Annex 2B Oil Title: Industrial assessment for wheat flour and edible oil in Pakistan for food fortification

Objective:

To conduct a detailed assessment at each of the selected Oil and Ghee mills and unregulated producers, in Pakistan in order to determine their respective equipment and premix requirements, recommend protocols and fortification

process with special reference to vitamin A & D

Section 1

Organization informations

1. Name-----------------------------------------

2. 2. Location------------------------------------------------- --

3. Mailing address---------------------------

4. 4. Contact informations-------------------------------

5. History---------------------------------------

6. 6. CEO-----------------------------------------------------------

7. Total no of employees ----------------------------------------------------------

8. Non-technical--------------------------------

9. Technical personals--------------------------------------

10.Average Education of Non-technical employees --------------------------

----

11.Average Education of technical employees--------------------------------

----

12. Total no of Food technologists---------------------------------------------

----

Section 2

Equipment and Protocols

1. What kind of equipment‟s are utilized (Local machinery or Imported plant)------------------------------------------------------------------------

------------

2. When you last update your plant-----------------------------------------------


3. Age of the plant ----------------------------------------------------------------

4. Production capacity---------------------------------------------------------

----

5. Current production ---------------------------------------------------------

----

6. Source for oil and ghee-----------------------------------------------------

----

7. What is your acceptance and rejection criteria--------------------------------

8. What kind of Pre-processing analysis you are perform for raw materials---------------------------------------------------------------------

------------------

9. Are you periodically update your protocol for production-----------------

----

10. Which catalyst you are using during hydrogenation----------------------

----

11. What is its concentration-------------------------------------------------------

12. Are you carried physical or chemical refining---------------------------------

13. What are the Operating hours – hours per day, days per week, weeks per year----------------------------------------------------------------------

--------

14. If the plant is running in under capacity? Please elaborate the

reasons---------------------------------------------------------------------------------------

15. What is your last year production-------------------------------------------------------------------------------

16. Please provide the information regarding the different chemicals which are utilized for degumming, refining and etc.----------------------

---------------------------------------------------------------------------------------------------

17.What is the Temperature of oil after final chiller---------------------------------------------------------------

18.What is the diameter of pipework going to the tank farm----------------

----


19.What is the approximate distance from final chiller to tank farm that the oil actually travels ------------------------------------------------------

-----------

20.Total no of finished products---------------------------------------------------

Section 3

Fortification

1. Are you fortifying the oil and ghee for vitamin A & D---------------------

----

2. Which sources you are utilized for Vitamin A------------------------------

----------- & D-------------------------------------------------------

3. What concentration for vitamin A & D is used----------------------------

----

4. Which protocol are you adapting for the fortification-------------------------

5. Is there any periodic improvement in your protocol of fortification-------------------------------------------------------------------------------------

--------

Section 4

(Certifications & Documentation)

1. Have you obtained any certification regarding ISO and HACCAP---------------------------------------------------------------------------------------

---------

2. What is your company food safety policy---------------------------------

---------------------------------------------------------------------------------------

3. What kind of documentations are usually prepared--------------------------

4. Is there any traceability system for your products---------------------------

5. Any other specific documentation------------------------------------------

----

Section 5

Lab and analysis facilities


1. Do you have laboratory---------------------------------------------------------

2. If yes than what is the capacity of the lab---------------------------------

----

3. Analysis performed in the lab----------------------------------------------

----

4. Do you have facility to analyze Vitamin A and D--------------------------

----

5. If no how you claim the concentration in your final product-----------------------------------------------------------------------------------------------------

6. What is the qualification of the lab in charge------------------------------

----

Section 6

Training of the employees

1. Is there any policy of the company regarding the employees training----------------------------------------------------------------------------------------

--------

2. What is the level of training---------------------------------------------------

-------------------------------------------

Remarks ----------------------------------------------------------------------------

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------

----------------------------------

Critical remarks (only filled by Surveyor)-------------------------------------------------------------------------------------------------------------------------------

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------

---------------------------


Suggestions---------------------------------------------------------------------------------------------------------------------------------------------------------------

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------

-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Name of the resident person Surveyor Provided information


Annex 3 – Stakeholder Inputs

Pakistan Flour Millers Association (PFMA) – Punjab Zone

PFMA Punjab estimated the total number of mills to be approximately 1,200

flour mills 23 and provided the consultancy team with a list of 843 members.

The PFMA (Punjab) are very positive towards fortification and during the

2007 -2010 fortification initiative PFMA had external teams checking on

participating mills every 15 days with the spot test (indicating a high level of

industry self-regulation).

PFMA advised they have their own laboratory 24 with a qualified analyst that

provides analysis free of charge to its

members. Analysis is believed to consist

of protein, moisture, ash, gluten, water

absorption on wheat and wheat flour

In the opinion of PFMA – Punjab - the market for wheat flour varies from a

movement to whole wheat

Atta flour in specific areas

with whiter (more refined)

flours being preferred in

Karachi. The general

movement was towards whiter flours. PFMA advised, however, that the

market was subject to strong competition due to being in an oversupply

situation.

Grain prices are fixed by the Federal Government prior to the harvest and

food security (Federal Government) is ensured by the Food Department

(discussed later). As prices

are strictly controlled (see

Wheat price commentary

later) the ability to pass on

the cost of fortification to

the consumer was a

constant discussion point

within the membership.

Consultant Randall was

advised that this issue had

been taken up with the

Food Department and the

23

The consultants identified 1171 Sindh has 139 mills on the list but the PFMA Sindh region say it is 198 24

Not seen by the consulting team

Identified risk factor - believed to be carried

out using NIR or NIT technology such as the

‘Chopin Infraneo’

Identified risk factor – high phytic acid in whole wheat

Atta and low nutrition content in more refined flours

Identified risk factor – the cost of fortification needs to

be incorporated or severe resistance/non-compliance

from industry will be a significant issue. It is unclear,

however, why feeder amortisation is included (double

entry in accounts as this is automatically claimed) and

why external monitoring needs to be funded by the

fortification programme itself – Government (Federal

and Provincial) are responsible for food monitoring not

the consumer.


cost of fortification (premix, internal monitoring and micro feeder

amortisation) was being considered for inclusion in the floor price for wheat

and wheat flour.

Wheat quality was recognised as a point of concern especially in the area of

moisture content and impurities (which frequently exceed 3%). This area is

a long standing one which relates to the use of a „fair average quality‟ criteria

coupled with a „no loss policy‟. This

catastrophic combination of policies

combined with poor timing of key

decisions (price in particular) and

implementations has already been

more than adequately covered by Kansas State University 25, Storage

Technology and Transfer, December 1989.

Brand registration and recognition is strong making monitoring and recall

possible.

PFMA reported no major issues with fortification during the 2008 to 2011

period but several claims were made by other parties that:

PFMA coordinated the procurement of micro feeders to the project

The micro feeders were of Turkish origin

The micro feeders were not suitable for direct use in the programme

but required the premix to be diluted prior to use (confirmed by

consultant Randall).

No guidance (or incorrect guidance) was given on correct positioning

of the micro feeders (confirmed by consultant Randall).

Pakistan Flour Millers Association – Sindh Circle

The consultants had originally been provided with a list of 139 members of

the Sindh PFMA but were advised on meeting the Association that the

membership now stood at 198 with the majority in the region of >200MT to

280MT

As with the Pujab Chapter the Association was very positive towards

fortification and had been extensively involved in the 2008-2010 initiative.

Price control (as discussed above) was a major point of concern for PFMA –

Sindh – and the Chairman was not convinced that the Food Department

would incorporate fortification costs into the wheat pricing equation. Wheat

quality was not an issue.

Another concern was the question of Chakki mills, especially in rural areas,

that the Association estimate account for circa 50% of the wheat flour milled.

25 http://pdf.usaid.gov/pdf_docs/Pnabb925.pdf

Identified risk factor – wheat supply is on a

‘quota’ system for 7 to 8 months of the

year. Could be used as a leverage point.

http://pdf.usaid.gov/pdf_docs/Pnabb925.pdf


The Association did, however, recognise that Chakki mills presented multiple

problems not least of which were:

Being able to identify where they were

Majority provided a milling service not commercial flour

Logistics in getting premix to the relevant millers

Consumer awareness and acceptance

Monitoring and quality control

PFMA willingly agreed to facilitate meetings with members and cooperate in

any way possible.

Pakistan Vanaspati Manufacturers’ Association (PVMA)

Interview led by Mr Faiz (GAIN) and proved to be the antithesis of the

meeting with the PFMA Secretary General.

The PVMA indicated that noncompliance was extremely high and that even

those who do add vitamin A and D 26 do not do so all of the time – this,

allegedly applies to even the best known brands (difficult to reconcile with

the heavy marketing the top brands indulge in).

Passing compliance testing was achievable by a certain amount of collusion

with the authorities and an awareness of the distribution of the product into

areas more likely to be subjected to verifiable testing (would not expand

further). A common approach is also to charge for „analytical fees‟

(laboratories do not charge their respective compliance officials).

In deep rural areas vegetable oil and vanaspati/banaspati is frequently

adulterated with used cooking oil (most of which is being imported for the

soap industry and „leaking‟ into the market) and with chicken oil (made from

the offal etc. of chickens). Blending in 5-10% of each into regular oil and oil

products and the adulterant „disappears‟. Customs Intelligence apparently

estimated that 63,000 MT of „adulterant‟ leaked into the system in 2013.

According to PVMA „everyone‟ knows about this as it is frequently in the

media –“but competition rules” -and that in Karachi the authorities are being

intimidated as even the low cost of fortification generates millions of Rupees

due to the scale of operations. Under filling is also alleged to be common as

is the use of mineral oil 27, most often in so called “loose oil”.

26

Vitamin D is not required by either a Pakistan Standard or any Government legislation. Refineries where not aware of the reason they were adding vitamin D – which is probably because vitamin A +D is the most common oil fortificant worldwide and is, usually, cheaper and more readily available than vitamin A on its own. 27

This form of adulteration is highly toxic.


Approximately 350 brands are licensed in Pakistan.

Karachi has 11 major refineries who are “interdependent” and usually

involved in joint ventures with operations in Malaysia.

Pricing is highly dependent on the world market and 60-70% of the

membership have a minimum base price they will not fall below which goes

someway to explaining consumers accepting knowingly adulterated oil which

can sell at Rs85-90/Kg against a commercial product at Rs160/Kg 28. An

example was given of a domestic worker taking home used cooking oil from

their employer as it was better than what they could get at home.

Adulterated oil is most commonly used in manufacturing/lower end

restaurants and street food i.e. indirect consumption. Purchasing power is a

significant factor with 70% of population apparently living on less than USD

1/day.

PVMA declined to facilitate

any meeting with members

nor would the Secretary

permit Mr Faiz speak directly to Board members at a future Board meeting –

but if Mr Faiz put in writing what he wished to put before the Board the

Secretary would study it to see if warranted the Boards attention.

Food Department – Punjab

A group of approximately seven managers of the Food Department attended

the meeting and advised they took the NNS 2011 very seriously and the

Director stated they were fully committed to this initiative and would be

willing to cooperate in whatever way they could.

The Food Department has multiple inter-linked functions:

Approve the wheat release price and set the wheat flour price

Purchase of wheat whilst the millers are taking up all they can procure

(available finance being the limiting factor followed by storage)

Procurement takes place during harvest period (mid April to mid June)

Procurement protects the farmers against the financial impact of a

bumper crop

Develop strategic wheat stocks

o Strategic reserve is circa 3.7m MT and

o Release a similar quantity during September to April

Monitor, and enforce, the price of wheat flour to ensure price stability

28

Later in the interview these numbers changed to Rs120 and Rs200 respectively (in line with supermarket prices seen).

Identified risk factor – PVMA Secretary antagonistic


The latest pricing in the Food Department indicates:

Purchase price Rs 1,200/40Kg (Maund) 29

Overheads and storage take price to Rs 1,520 – 1,580/40Kg

Selling price Rs 1,330 to 1,340/40Kg

Difference is Federal Government subsidy circa 10-15%

The Food Department admitted that wheat quality was a weak area (from

poor yields to poor milling characteristics). Standards are set using the „Fair

Average Quality‟ (FAQ) system though implementation is “weak” except for

on the moisture which is “strictly kept” 30 at 10 -11%. Impurity levels in the

grain was “not so strictly

implemented” 31 and whilst

up to 3% was the norm the

Food Department would accept up to 5% to favour the farmers as this was

an “environmental factor” [80% of wheat is grown under irrigation but out

dated practises apparently result in a 25% loss of water before reaching the

fields]

Pakistan has no mechanical driers so grain is spread in the fields to dry 32;

the grain is then stored under cover and “checked weekly” with fumigation

on a reactive basis (due to regular checks fumigation is rarely required)

Current storage capacity (according to the Punjab Food Authority) in the

country for the strategic reserve is inadequate at circa 50% (2m MT) in silos

and the rest in bags under tarpaulin – though the storage areas are mainly in

the production areas.

The Food Department has no real idea of the number of farmers in Pakistan

(or Punjab) but the approximately 4m MT they collect comes from circa

300,000 farmers. It is a political policy that the Food Department

target/support small farmers (80% of farmers in Punjab farm on < 2

hectare).

The wheat price is set in February/March and is arrived at after considering:

Inputs from the Provincial Governments

Incentive to produce to the farmers

Cost including inputs

Impact on the flour price

29

Traditional unit of mass. Formed basis of metrication in India and Pakistan and is defined as exactly 37.3242Kg 30

The milling industry would disagree with this statement 31

It can be argued that is a direct cause of having a FAQ and a No Loss policy with poor quality management – leads to deliberate addition of impurities to maintain a zero loss of grain on the books 32

Once dry soil and stones can be ‘accidently’ swept up with the grain

Identified risk factor – wheat grain supply and quality


The Federal Government does take into account the export parity but it

should be borne in mind only Government can export wheat.

Despite the „bias‟ towards the producers the main source of complaint comes

from the farmers

themselves and, as a

result, the farmers

have a tendency to

grow for themselves and not for the commercial market.

According to the Punjab Food Department of the 19m MT produced circa 4m

MT is taken up by them, about 1.5m MT by Pakistan Agricultural Storage and

Services Cooperative (PASSCO), circa 2m MT is traded at harvest time and 8-

9m MT is retained. From the crop some 70% of the crop is being retained at

village level, some for seed 33 (circa 10%) and the rest for own use and/or

later trading. Visual inspection of the wheat indicates that it is a spring type

wheat but the agricultural practise is a winter wheat protocol.

The Food Department Punjab advised they have three (3) laboratories

through its nine (9) Divisions and samples are sent to the nearest laboratory

with the results submitted to Lahore to be checked against the Standard.

The Food Department expressed they were 99% satisfied with the quality

and recognised that most deviations (from the moisture maximum) was in

December and due to the seasonal rains.

Recently the Food Department has started to become stricter on supply times

from the farmers who, having been contracted to sell at a fixed price to the

Food Department, find the spot market price is higher renege on the

contract. Additionally „middlemen‟ are buying from the smaller small farmers

to generate a consolidated consignment for the millers – this invariably

means that the producer is not benefiting from the price control system (as

the price the miller is prepared to pay is the limiting step).

Food Department - Karachi

Sindh Food Department was thought to store circa 1.5m MT and PASSCO a

small uptake meaning Government total wheat holdings approximate 7.5 to

8m MT

Policy and Strategic Planning Unit (PSPU) – Lahore

PSPU described the NNS 2011 as “alarming” and that a multi-sectorial plan

was being developed integrating the sectorial plans of both Health, Food and

Agriculture – in the light of probable (as in the reason for this assessment)

fortification initiatives these plans would need tweaking to ensure maximum

impact.

33

Continuously keeping part of the crop back for next years seed is a major factor in the poor yields being achieved

Identified risk factor – if grown on a semi subsistence basis the

wheat will be Chakki milled and extremely difficult to fortify


PSPU has the main coordinating role – but seemed unsure of what and how

to coordinate – and recognised consumer awareness of nutrition and

fortification in particular was an

unknown and, according to

PSPU, a local study should be

commissioned (by the donors!!)

and that a deeper

understanding of the supply

chain was required (ditto).

PSPU noted that it was recognised Pakistan Standards and Quality Control

Authority (PSQCA) had outdated Standards that were not being used and in

need of review. According to PSPU legislation could be ready in a month.

Mr Munawar (GAIN) advised the Punjab Food Authority is working on revision

of standards of fortified wheat flour and fortification could be made

mandatory through amendent in the rules as an alternative to legislation. As

per Punjab Food Authority, enforcement of revised standards would require a

lead time of 12 months. For M&E an Egyptian model was being investigated

and it could potentially be replicated in Pakistan.

Planning & Development Department (PND) – Government of Punjab

Interview led by Mr Munawar and Prof Anjum.

Prof Anjum provided the scope of the assessment whilst Mr Munawar

requested support into understanding why the low level of compliance in the

vegetable oil industry and how to address industry practises and gain a

knowledge of industry insights.

PND asked if fortified and unfortified products would be both available and it

was reiterated (from the scope already given) that there would be a grace

period of 12 months in which capacity would be built

The advice of PND was to seek industries‟ opinion of legislation and overcome

their (industries) fears 34 etc. rather than change legislation; then contradict

themselves with advice to go to the

Provincial Governments and institute

separate legislation or alter the Food Rules

to incorporate wheat. PND could give strict

instructions to adopt the fortification

amendments.

PND advised that a media campaign would be required targeting millers and

consumers -but took the point no further.

34

Industry has no fear of the current legislation as it is either not enforced (oil) or is not in place and required (wheat).

Identified risk factor – May require being ‘advised’

on what coordination is desirable/required. The

health department was keen to determine their

role for wheat flour and Oil and Banaspati

fortification initiative.

Identified risk factor – appear

weak and may require being

‘advised’ on what planning is

desirable/required


Of major concern was that early in interview PND was firmly of the opinion

that fortification would (not

might) change the sensory

attributes of wheat flour. When

asked for the evidence supporting

this assertion PND was more

circumspect and admitted this was something that they had been advised

about but had not seen any evidence for or against the sensory change.

Consultant Randall has provided Prof Anjum and Mr Munawar with peer

reviewed publications over a number of years supporting the position that no

sensory changes occur when fortification is carried out within scientifically

accepted norms (as are proposed for Pakistan) and/or at levels of inclusion

significantly higher than those proposed for Pakistan (Nigeria 40 ppm iron as

NaFeEDTA). These publications have been forwarded to PND by Prof Anjum

and Mr Muawar

PND also cautioned that misperception was a problem in Pakistan citing the

Polio issue (linked with contraceptives) and consumers insisting on being able

to access non-iodised salt. PND, however, had no suggestions as to how

these „bad‟ messages were originating or being disseminated.

Nutrition Planning Commission NPC – Islamabad

NPC is the Stepping Up Nutrition (SUN) focal point.

NPC was of the opinion that the oil industry was not cooperating despite the

fact that in 1965 when fortification of oil was made mandatory the price was

adjusted to accommodate fortification 35. This, NPC, believe was due to lack

of monitoring and in 1998 advised that 50% of tested samples had no

vitamin A and 10% were inadequately fortified.

NPC advised that costing, on both vehicles was a significant issue with pricing

of staple foods being regularly raised in the Supreme Court – with the

intention of keeping prices down. Prices do, however, vary between cities

and provinces.

Supplementation, fortification and bio fortification are all programmes

fortification that Pakistan is putting

considerable faith in – particularly the

zinc wheat bio fortification (discussed

later).

NPC also consider dietary diversification to be an attainable goal.

NPC advice is that consumers are

aware of nutrition factors from the

35

Mr Faiz (GAIN) advised the Government also paid for the necessary changes to the label.

Identified risk factor – zinc efforts placed

almost entirely on bio fortification

Identified risk factor – PND appears not to

require substantive evidence before proceeding

with action and/or policy

Identified risk factor – contradiction in level of

consumer awareness


label but consumer awareness was a matter constantly under discussion.

They also advised that it would be necessary to deal with “top people very

carefully”.

Pakistan Standards and Quality Control Authority (PSQCA) - Karachi

Discussions held with the Director (Agri & Food) Standards Development and

Director Quality Control Center (South).

PSQCA covers >30,000 Standards (72 mandatory) of which 565 related to

food items (42 food

products are mandatory).

Of importance is that:

PSQCA is Federal

Imports and Exports must follow the relevant PSQCA Standard (if

existing) 36

Samples are only taken if

o The Standard is mandatory or

o The Standard Mark is being used

Standards are adopted from ISO, IEC, CODEX (most Standards are

harmonised with Codex)

Should CODEX be updated the national Standard remains in place until

the Standard is updated 37

ISO/IEC Guide 21 has been adopted in Pakistan

Approximately 800 food samples were analysed in the past calendar year by

the laboratory that serves two „masters‟:

Conformity Assessment Division –compliance testing

Quality Control Center – providing an analytical support to industry on

a pay for service basis

PSQCA provides results to the relevant party without interpretation but do,

importantly, provide analytical uncertainty at 95% confidence.

Vitamin A is tested on a qualitative basis (basically the short Carr Price

reaction with Antinomy trichloride) only and they have had very few failures;

36

Theoretically this could create a Technical Barrier to Trade (TBT) as imports must follow PSQCA whereas local companies could argue they are following Provincial (which is in its own right a Government under the 18

th Amendment of the Constitution) law i.e. Punjab Food Rules 2011. Opinion is divided on whether

the Punjab (Provincial Government) Food Rules, for example, take precedence over National (Federal Government) Standards though they the different pieces of legislation do try to be complementary 37

Alteration of a Standard can take between 3 and 12 months depending on the complexity

Identified risk factor – many Standards outdated, in

conflict with CODEX and with Provincial legislation


whereas Peroxide Value (PV) and Free Fatty Acids (FFA) are accredited under

the Pakistan National Accreditation Council (PNAC) 38

Pakistan Standards and Quality Control Authority (PSQCA) – Lahore

This visit was primarily to gain access to some refineries in the area. PSQCA

– Lahore confirmed that Peroxide Value (PV) and Free Fatty Acids (FFA) are

accredited under the Pakistan National Accreditation Council (PNAC) and the

reason it was not on the PANC website is that “it has not been put up there

yet”.

Advised that PSQCA have a quarterly visit schedule (inspection plans exist

but not seen), the qualitative test is used for vitamin A – 70 samples tested

in the last year with no failures.

Standing Committee Commerce & Investment – Punjab Assembly

Introduced by GAIN Country Director Sajjad Imran. Ramesh Singh Arora,

Chairman of the above Committee indicated he was aware of many of the

issues relating to fortification and the problems a National Programme was

facing. GAIN was more than welcome to approach him personally as a

means to expediting any nutritional intervention and he would see that the

matter was brought before the Committee as appropriate.

Pakistan Council for Scientific and Industrial Research – PCSIR

Discussions held with the Director in charge of the laboratory and the

Director General.

Most of the laboratories at PCSIR have achieved ISO 17025 accreditation

since 2003 on at least some methods. In total PSCIR has 278 accredited

analytical methods. To date these do not include vitamin and mineral

analysis though the Director General was willing to look at applying for an

„extension of scope‟ which would then bring vitamins and minerals under ISO

17025 (some technical and financial support may be required). Interest was

expressed in getting involved as a service provider from fortification to

complementary foods.

PCSIR run training programmes capable of being applied to 1 to 250

delegates and boast 20 lead auditors in various aspects of ISO 17025 as well

as 50 highly trained in in ISO 17025.

Originally under Norwegian Accreditation PCSIR now falls under the Pakistan

National Accreditation Council (PNAC) which was launched during the year

2001. PNAC achieved a milestone of Mutual Recognition Arrangement (MRA)

with International Laboratory Accreditation Cooperation (ILAC) and Asia

38

No reference to PSQCA could be found on the PNAC website http://www.pnac.org.pk/index.php?PageId=87

http://www.pnac.org.pk/index.php?PageId=87


Pacific Laboratory Accreditation Cooperation (APLAC) in 2009 and MLA status

in 2013. Pakistan is now included in the list of countries having equivalent

status for accreditation of testing & calibration laboratories and certification

bodies for QMS & EMS all over the world.

PSCIR expressed interest in immediately procuring iCheck Chroma3

(information on system provide to PCSIR via Prof Anjum)

A suggestion from the Director General was that implementation, within

Pakistan, would be best carried out using local NGO‟s etc.

METRO Superstore Discussions with the floor manager of a local superstore in Lahore indicated

the store carried up to 130 different types/brands of combinations including

their own two brands. On wheat flour they only carried their own brands.

As a typical major superstore they have their own laboratories and food

technologists (most from under Prof Anjum tutelage) and they do conduct

extensive audits on their own label products and have their own quality

specifications. Metro has not experienced any problems with vitamin A in

their labelled products.

Within the store it was noted that labelling used terminology such as “added”

and “enriched” with some declaring quantities on the label. Common

labelling practise was 33 IU/g vitamin A, 2.6 IU/g vitamin D and some also

claiming 60µg/Kg of vitamin E. Sometimes this would be accompanied by

nutritional claims such as vitamin A 45%

RDI, vitamin D 50% RDI and vitamin E

15% RDI. Additional to this products

frequently used the claim “0% cholesterol” or “cholesterol free” compounding

the observation that serious attention needs to be spent on labelling laws

and nutritional claims.

Current Prices Consumer Groceries Pakistan

On-line shopping provides some indication of current food prices

http://www.pakistangrocery.com/send-grocery-to-pakistan162.htm

Jamia Tur Rashaid

Use of „role models‟ and „people of influence‟ is common in fortification

advocacy – the above Institution is dedicated to multi-disciplinary studies of

Shariah based on Halaal awareness and combines religious studies with

„conventional‟ higher education (accounting, business studies etc.) and is well

respected internationally. The institution charges no fees (even provides

Identified risk factor – labelling laws

http://www.pakistangrocery.com/send-grocery-to-pakistan162.htm


students with a small stipend) and has a current student base of circa 2,500

most of whom are in residence. Funding is from private donations.

The institution would be highly influential in any communications campaign.

The institution also has its own publications 39, targeting women and children 40, called „The Truth‟ and expressed interest in disseminating nutritional

messages 41 suitably written for the intended age group. They also have a

Facebook page and a worldwide computer network.

Of great significance is that senior executives of the Institution suggested

that Friday prayers could include components which corrected misperceptions

and/or discuss the benefits of fortification.

During discussion with faculty members it became clear they recognised the

lack of awareness, belief that millers/refineries were impacting on quality

(negative connotation), profit was a prime motivator and that demand

creation would have to be addressed; and that they would be willing to

participate within the jurisprudence of their faith.

TechnoMight Engineers – Faisalabad

Local company that has been involved in the wheat fortification programme

since the beginning as millers and then became involved in studies (some of

which were under Prof Anjums‟ leadership) in Chakki mill fortification and

designed small scale micro feeders, which, according to them, worked „well‟,

for the project.

Currently they have a conventional size micro feeder which is a „reverse

engineered‟ version of the one supplied by American Ingredients to a few

(very few) millers originally involved. This micro feeder is commercially

available but sales have been very low.

During discussion with the engineers modern concepts in micro feeder

technology were discussed and the company undertook to taken them into

consideration (feeder requirements for Pakistan are discussed later).

39

Gallop estimate readership to be 1.8m for the women’s magazine and 2m each for the children’s magazine in English and Urdu 40

http://www.thetruthmag.com/ 41

Consultant Randall was requested to write suitable ‘stories’ for the magazine – which he look to do – but only to be published when the advocacy campaign starts. Editor understood the importance of timing.

http://www.thetruthmag.com/


Annex 4 – Mean Squares Statistics Dr. Farhan Saeed; Assistant Professor; Department of Food Science; Institute of Home and Food Sciences; Government College University,

Faisalabad-Pakistan, observed, using mean squares the following:

Iron

The iron content in flour and grain samples of different chakkies and mills

regarding different regions have been presented in Table 1. Mean squares depicted that iron content varied significantly among different regions. In

addition, interaction among flour and grain was also found significant. The iron content in flour of different chakkies in various regions ranged from 39.43 to 43.86 ppm while it ranged from 45.57 to 47.54 in grain samples of

different chakkies.

The iron content was recorded significantly high in wheat flour sample of chakki existed in Baluchistan region (43.86 ppm) followed by flour of chakki

present in South Punjab and Sindh regions (39.92 ppm) but with non significant differences for iron content among North Punjab (39.43 ppm),

central Punjab (39.43 ppm) and KPK regions (39.63 ppm). Moreover, the iron content in grain samples of different chakkies regarding different regions varied significantly and found highest in grain samples of Sindh region (47.54

ppm) and South Punjab region (47.54 ppm) followed by grain samples of North Punjab region (46.08 ppm), Central Punjab region (46.08 ppm) and

KPK region (45.57 ppm). The grain samples did not procure from the chakkies existed in Baluchistan region. It is also obvious from the results that iron content in flour and grain samples of different flour mills regarding

different regions was found significant and interaction among flour and grain samples was also explicated momentously. The iron content in flour samples

of different flour samples regarding different regions ranged from 38.86 to 46.10 ppm and it varied from 42.47 to 52.94 ppm in grain samples of Flour mills. The iron content was observed significantly high in flour sample of

different flour mills existed in Baluchistan region (46.10 ppm) followed by flour of mills present in North Punjab (43.28 ppm) and North Punjab regions

(43.28 ppm) but with non significant differences for iron content among Sindh region (41.01 ppm), South Punjab (41.01 ppm) and KPK regions (38.86 ppm). Furthermore, the iron content in grain samples of different

flour mills regarding different regions varied significantly and found highest in grain samples of both Central Punjab and North Punjab region (52.94 ppm)

followed by grain samples of South Punjab region (50.02 ppm), and Sindh region (50.02 ppm). The iron content was explicated lowest in grain samples of flour mills collected in KPK region (42.47 ppm). The wheat flour containing

higher amount of iron content is beneficial to the population suffering with anemia which may help to alleviate iron deficiency anemia (IDA). Iron

deficiency anemia reduces a person‟s ability to perform physically demanding tasks and anemic laborers have demonstrated productivity.

Phytic Acid


The phytic acid content in flour and grain sample of different chakkies and mills collected from different regions of Pakistan have been presented in

Table 1. Mean squares depicted that phytic acid content assorted significantly among different regions. In addition, interaction among flour and grain was

also found momentous. The phytic acid content in flour of different chakkies in various regions ranged from 0.82 to 0.86% while it ranged from 0.82 to 0.99% in grain samples of different chakkies.

The phytic acid content was recorded significantly high in wheat flour sample of chakki existed in Baluchistan region (0.86%) followed by flour of chakki present in South Punjab and Sindh regions (0.85%) but with non significant

differences for phytic acid content among North Punjab (0.83%), central Punjab (0.83%) and KPK regions (0.82%). Moreover, the phytic acid content

in grain samples of different chakkies regarding different regions varied significantly and found highest in grain samples of Sindh region (0.99%) and South Punjab region (0.99%) followed by grain samples of KPK region

(0.94%), Central Punjab region (0.83%) and North Punjab region (0.82%). The grain samples did not procure from the chakkies existed in Baluchistan

region. It is also obvious from the results that phytic acid content in flour and grain samples of different flour mills regarding different regions was found significant and interaction among flour and grain samples was also explicated

momentously. The phytic acid content in flour samples of different flour samples regarding different regions ranged from 0.78 to 0.88% and it varied

from 0.90 to 1.03% in grain samples of Flour mills. The phytic acid content was observed significantly the maximize in flour sample of different flour mills existed in KPK region (0.88%) followed by flour of mills present in

South Punjab (0.84%) and Sindh regions (0.84%) but with non significant differences for phytic acid content among Baluchistan region (0.83%), North

Punjab region (0.78%), and Central Punjab (0.78%). Furthermore, the phytic acid content in grain samples of different flour mills regarding different regions varied significantly and found highest in grain samples of Baluchistan

region (1.03%), followed by South Punjab (1.02%), Sindh region (1.01%). The iron content was explicated lowest in grain samples of flour mills

regarding KPK region (0.90%) and Central Punjab (0.90 %).

Table 1: Iron and Phytic acid contents of flour and grain samples of chakkies and flour mills regarding different regions

Iron Content (ppm) Phytic Acid (%)

Regions Chakki Flour Mills Chakki Flour Mills

Flour Grain Flour Grain Flour Grain Flour Grain

Baluchistan 43.86 0 46.10 48.19 0.86 0 0.83 1.03


KPK 39.63 45.57 38.86 42.47 0.82 0.94 0.88 0.98

Central Punjab 39.43 46.08 43.28 52.94 0.83 0.83 0.78 0.90

North Punjab 39.43 46.08 43.28 52.94 0.83 0.82 0.78 0.90

Sindh 39.92 47.54 41.01 50.02 0.85 0.99 0.84 1.01

South Punjab 39.92 47.54 41.01 50.02 0.85 0.99 0.84 1.02

Draft FIVE Wheat and Oil Industry Pakistan Page 80 of 80

Figure 1: Iron and Phytic acid contents of flour and grain samples of chakkies and flour mills regarding different regions

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