Food safety is an important component of any effective nutrition policy. In Pakistan, provincial governments are responsible for ensuring the safety of domestically produced foods, in accordance with Pakistan’s 18th constitutional amendment. This amendment devolved specific government functions to its provinces, including the health and agriculture sectors. However, despite legal frameworks that mandated the existence of Food Safety and Halal Food Authorities since 2010, many provinces did not have functioning authorities until a couple years ago. It is in this context that Muhammad Aslam Shaheen, the SUN Focal Point in Pakistan, reached out to Nutrition International to request technical assistance (TA), to help establish such authorities in Khyber Pakhtunkhwa province in 2018-2019, and Azad Jammu and Kashmir (AJK) in 2019-2020. Nutrition International provided the technical assistance to these two provinces through TA providers Shahid Fazal and Dr. Zaffar Mehmood.

The assistance focused on the technical elements of food safety in production, processing and distribution. As the assistance progressed, it became increasingly apparent that the TA also needed to support the development of financial sustainability mechanisms for the authorities. Financial and audit regulations were needed to underpin technical regulations, namely a fees and fines structure to provide enforcement power and a costed operational plan for each authority. These financial and audit regulations became an important deliverable of the TA in Khyber Pakhtunkhwa. In Azad Jammu and Kashmir, the rules of business developed to include licensing processes and penalties for non-compliance. The TA in AJK went even further, supporting the development of a proposal requesting funding for the establishment of a food control laboratory in the province. In the conversation below, Shahid Fazal and Dr. Zaffar Mehmood discuss their experiences working on these projects.

What were the needs of the authority in Khyber Pakhtunkhwa around financing and resource mobilization? How did you help them address those needs?

Shahid Fazal: The food safety regulations we developed in 2018 included important financial elements that enabled the operationalization of the authority in Khyber Pakhtunkhwa. As part of developing the food safety regulations, we developed a fees and fines structure that not only enabled the regulations to have “teeth”, but also to generate revenue for the authority to fund its activities. Those fees and fines generated revenue of PKR 55M (approximately CAD $445,000) in 2019-2020 for the authority, however it is insufficient to meet their budgetary needs, and the Government of Khyber Pakhtunkhwa supplements it through an annual grant. Following the development of the regulations, we created the strategy and operational plan for the authority, and supported the team to develop an annual budget (PKR 406.9M or CAD $3.2M for FY 2020-21).

The deliverables are quite comprehensive. Does the authority still need to be further strengthened?

Shahid Fazal: Findings from a 2020 progress assessment conducted by NTEAM indicated that this TA was valued by the provincial authorities and is still being utilized over a year after it was developed. Notably, interviews conducted as part of the progress assessment highlighted the need to balance revenue generating activities (charging fines) with ensuring compliance through awareness, outreach and education activities by the authority. The progress assessment ultimately recommended prioritizing compliance and receiving industry buy-in. The authority is in an expansion phase which requires funding to establish laboratories and improved IT systems. It is thus reliant on government funding to support their budget, in addition to the fees and fines it charges. Longer-term, the authority hopes to become financially independent through the revenue it generates.

What about in AJK? Was it a similar experience?

Dr. Zaffar Mehmood: I provided similar assistance to AJK’s authority in 2019 as Shahid Fazal did in Khyber Pakhtunkhwa, helping them develop their rules of business and comprehensive food safety standards and regulations. This also included a fee structure for business registration. We were able to learn from Nutrition International’s experience in Khyber Pakhtunkhwa and followed a similar consultation and drafting process. The onset of the global COVID-19 pandemic also occurred during the provision of this TA. To respond to the emerging health needs, I supported the development of a separate standard operating procedure (SOP) for business operators, and referenced national and international guidelines for food safety as they relate to COVID-19 transmission (personal hygiene, personal protective equipment, food handling, dealing with illness in the workplace, etc.). We also provided training to all 150 field officers, which included COVID-19 specific guidelines.

You also worked on a funding proposal for the AJK authority. Can you tell us about it?

Dr. Zaffar Mehmood: Prior to beginning the TA, the provincial Department of Food (who oversees the authority in AJK) had drafted a technical and funding proposal (called a PC-1) to establish a central food control laboratory for the province. But they did not have the technical capacity to finalize it, and requested my assistance as NTEAM’s TA provider to fill in the gaps that had been highlighted by the provincial Planning and Development Department who had been hesitant to approve and release funds. We revised the PC-1 to include a detailed budget of PKR 98.9M (approximately $790,000 CAD), technical specifications of the laboratory premises and equipment, human resource requirements and the details of the types of lab tests that could be performed. This PC-1 is a required step in the process for obtaining the funding required from the Planning and Development Department to set up the lab. In the end, we modified the proposal to cover three mobile food labs and training for authority staff, to ensure a quicker response to immediate testing needs, rather than building one centralized lab. The AJK government is now in the process of approving the funding which will be a significant achievement towards ensuring effective enforcement of food safety regulations.

What a success! Did the TA encounter any challenges?

Dr. Zaffar Mehmood: Despite the success of mobilizing resources for food safety in AJK, this TA was not without its challenges. During the time of our TA provision, there was some staff turnover within the government and food safety jurisdictions were being clarified. We needed to advocate for support for the establishment of the authority. Food manufacturers and distributors were initially opposed to the creation of the authority, for fear of corruption (bribery) and additional costs to comply with regulations. All of these experiences also led to demotivation among staff within the newly formed authority. To overcome these challenges, I worked with authority staff to develop an advocacy strategy, targeting government officials, the food industry and the general public. We involved higher level authority figures in meetings and workshops to solidify their commitment to the authority, which also helped motivate staff. A number of actions helped develop a sense of responsibility and urgency among stakeholders. We involved stakeholders in meetings and in the development of SOPs, and worked to sensitize stakeholders about the realities of food safety and the consequences of substandard food on wellbeing. The strategic use of local language, discussing local problems and data in simplified, non-technical terms helped get buy-in from food vendors and create more awareness about hygiene standards. Communicating that food safety is not only the authority’s role but everyone’s responsibility and benefit was highly useful in converting hostile discussions to more agreeable approaches to tough decisions. Removing registration fees in the first phase of AJK’s roll-out was also a helpful compromise to get initial buy-in.

Gender equality is a key component of all of NTEAM’s TA. How did you mainstream gender equality in these TA engagements?

Shahid Fazal: Gender equality was considered in both of our TAs. In Khyber Pakhtunkhwa, I revised human resources processes to ensure equal consideration of both men and women in the staff recruitment process. Ultimately five women were hired to the authority in Khyber Pakhtunkhwa province during the roll-out phase. Though insufficient to ensure equal representation of men and women among authority staff, this has been an important first step for gender equality in a male-dominated industry and conservative culture.

Dr. Zaffar Mehmood: In AJK, recruitment of women was limited by government directives to absorb existing staff from the Department of Food, to ensure nobody lost their jobs in the process. However, I intentionally wrote the authority operational plans, including the human resource protocols and job descriptions, in gender neutral language, and successfully advocated for the authority to agree to a 10% quota for female staff in all future hiring.  All of these recommendations were included in the new rules of business.

There were similar objectives for the TA in Khyber Pakhtunkhwa and AJK – to develop food safety regulations and rules of business for the authorities – however each province had unique challenges and particular needs that defined how best to approach their objectives, especially around financing. What should our readers take-away from your unique experiences?

Shahid Fazal: In Khyber Pakhtunkhwa, we prioritized getting industry buy-in, coordination with other departments and relevant expert bodies and promoting compliance over revenue generation and financial independence in the initial phase. The authority will be reliant on government funding in the short-to-medium term, but de-prioritizing revenue generation is crucial to build trust with stakeholders.

Dr. Zaffar Mehmood: In AJK, the bureaucratic shifts in the Department of Food and overlapping roles with other institutions meant that clarity in responsibilities and a focus on staff morale were prioritized. Acquiring funding for the mobile labs and working with field staff who help generate public acceptance have contributed to the positive momentum. This work has been extremely satisfying to both of us, and we are proud to have contributed to the authorities, knowing they play a crucial role in the health and nutrition of the populations of Khyber Pakhtunkhwa and AJK.

Thank you for your contributions to the Food Safety and Halal Food Authorities in Khyber Pakhtunkhwa and Azad Jammu and Kashmir.

For more information about NTEAM’s TA to the Khyber Pakhtunkhwa Food Authority, read about the importance of strengthening institutional and human capacity to improve food safety and the role of gender equality in Nutrition International’s work in Pakistan.