To the Presentation On Audit on implementation of environmental Policy &

2. To the Presentation On Audit on implementation of environmental Policy & Role of SAIs in promoting national sustainable development. Presented by SAI Bangladesh Team.

3. About SAI-Bangladesh The Office of the Comptroller and Auditor General (OCAG) is responsible for auditing government receipts and public expenses. The CAG is appointed by the President of the Republic. The Constitution provides the CAG with complete independence. Main thrust of CAG audit is financial and compliance. CAG certifies Finance Accounts of the Republic and Appropriation Account.

4. Vision & Mission of the OCAG Attainment of Accountability and Transparency in public financial management to contribute towards achieving good governance. • Mission : It Conducts effective audit of public sector operations for optimum utilization of public resources . It provides the stakeholders with reliable and objective information to assist in establishing accountability and transparency in government activities • Core Values : Professionalism, Reliability, Objectivity, Accountability, Credibility, Transparency, Integrity, Viability and Ethics. • Vision:

5. Environmental Audit Environmental audit is a general term that can reflect various types or evaluations intended to identify environmental compliance and management system implementation gaps, along with related corrective actions. SAI Bangladesh has started its journey in this field a few years ago. Work so far done in the field of environment audit in Bangladesh include: Performance Audit on “Bio diversity of Saint Martin Island” (FY 2006-07); Ministry wide System Based Audit on Ministry of Environment and Forest(FY 2007-08); Performance Audit on Forest Management. (FY 2011-12); Performance Audit on Harvesting of Sundarban (FY 2010-11). Performance Audit on Illegal use of Formalin and Calcium Carbide in Food (FY 2013-14 & 2014-15).

6. Contd----- • We (SAI Bangladesh team) Will try to highlight some points on the Performance Audit/Environment Audit on Illegal use of Formalin and Calcium Carbide in Food. • This Audit was conducted with the help of SPEMP-B Project in FY 2013-14 & 2014-15.

7. Importance of the topic • Food safety is an important public health concern in Bangladesh and unsafe food represents a major threat to public health. • Unsafe and contaminated food causes many acute and life-long diseases ranging from diarrheal diseases to various forms of cancer, Kidney disorders, birth defects, bouts etc. • In Bangladesh due to weaknesses in existing laws and regulations, absence of monitoring and strong enforcement, and low level of awareness among consumers, there is evidence of widespread food adulteration with harmful chemicals and other toxins. 7

8. Audit Objectives • Assess the effectiveness of government policies/initiatives for tackling illegal use of formalin and calcium carbide in food in order to ensure food safety. • Make recommendations for improving the current system. 8

9. Adopted Methods • Document review and analysis. • Interviews with appropriate officials. • Extensive field visit. • Random collection of fruits & vegetables for formalin and calcium carbide contamination. 9

10. Audit Scope • Find out the threats to food safety from two chemicals: Formalin & Calcium Carbide . • Applicability of relevant legislation by the different key ministries. • Larger City Corporations were included. • Evidence collected from field visits of twenty eight different markets & forty nine separate units were covered. 10

11. Three main Issues From the information and knowledge gained in the survey phase, the audit team decided to focus its investigation in the following three main issue areas: 1:Does the Government have appropriate laws and organizational setup for addressing the issue? 2: Are the current laws governing food safety being implemented effectively? 3: Does the Government have appropriate technical capacity for addressing the issue? 11

12. Laws Implemented By several Ministries and their subordinate bodies. 12

13. Result Of The AuditIssue-1 Finding 1:Problems of multiple laws dealing with food safety. Finding 2:There was no central body responsible for ensuring the safety of the food chain. Finding 3:Existing laws had limitations. Finding 4:There was lack of clarity about what could be the acceptable limit of formalin in food. 13

14. Result Of The AuditIssue-2 Finding 1:The MOC was not able to control the importation of Formalin and Calcium Carbide effectively. Finding 2:Lacked an adequate field level organizational structure and budget for enforcing the Act effectively. Finding 3:Laws entitling consumers to lodge complaints were not user-friendly and imposed a cost burden on consumers. 14

15. Result Of The AuditIssue-2 Finding 4:Committees of officials were not functioning properly. Finding 5:Performance of BSTI field officers was limited by resource and other constraints. Finding 6:Fisheries Inspectors lacked adequate technical support to carry out comprehensive inspections on domestically consumed fish. Finding 7:Inspection of imported foods to detect formalin and others by inspectors was superficial, totally inadequate and lacked credibility. 15

16. Result Of The AuditIssue-2 Finding 8:Public Analysts of Food were not been appointed and Food Courts had not been established. Finding 9:Lacked of cold chain infrastructure encouraged use of formalin and calcium carbide. Finding 10:There were weak monitoring, absence of coordination, insufficient awareness creation, and insufficient punishment of offenders. 16

17. Result Of The AuditIssue-3 Finding 1:Laboratories had lack capacity and equipment for testing full range of foodstuffs and tests were expensive. Finding 2:Lab test results of different laboratories to detect formalin in the same sample were inconsistent. Finding 3:Only two types of kits for detection of formalin were available, these had serious limitations, and even these were not used properly. Finding 4:Public Procurement Rules were not followed and the improper machine for detection of formalin was procured. 17

18. RecommendationIssue-1 • GOB should develop a comprehensive Act. • The MOF should take immediate steps to finalize the Rules & Regulations related to the Food Safety Act, 2013 and establish the National Food Safety Advisory Council and other committees. • Concerned ministries should take actions to amend the Acts and laws as necessary. • The MOC should take immediate steps to resolve the confusion about the official acceptable level of formalin in different foodstuffs. 18

19. RecommendationIssue-2 • MOC should take immediate steps to stop the importation of formalin in all its forms. • DCRP should simplify the grievance process. • MOC/DCRP should monitor, supervise and receive feedback from upazilla and other committees. • BSTI should make availability of the staff needed, provide transport and ensure adequate procedures for aseptic collection and transportation of samples. • DOF should provide adequate number of digital meters. 19

20. RecommendationIssue-2 • Department of Customs should ensure proper land testing labs. • Concerned authorities should take immediate steps to appoint Public Analysts of Food and establish Pure Food Courts as required. • GOB and importers/exporters should invest in the development of cold chain infrastructure for food processing. • Monitoring should cover the whole food chain and try to make better coordination among the different agencies. 20

21. RecommendationIssue-3 • BCSIR, BSTI, and IPH/NFSL should develop or import technology for detection of calcium carbide in food, provide incentives for undertaking research, have a policy for continuous development, develop a total quality management system. • The different testing laboratories should standardize their testing methods. • Ensuring available kits which provides reliable results and that the cost of testing is not prohibitive. • The Procuring Entity should be held to account for violation the PPR Act. 21

22. Impacts • Positive initiatives taken by various government institutions. • Reducing use of formalin and carbide. • Increased awareness about use of formalin and calcium carbide. 22

23. Experiences & Challenges • Lack of environmental data. • The relative newness of environmental problems and environmental policy issues. • Sustainability being one core dimension, but is difficult to address. • Cost-benefit analysis of long term benefits of environmental engagements is crucial but difficult. • Coordination of international and interdisciplinary nature of environmental issues. 23

24. Experiences & Challenges • The challenge in finding audit criteria, and particularly in persuading governments to adopt international criteria. • The increasing focus of many audits on future as opposed to retrospective issues. • Expanding the pool of environmental auditors and providing them with proper training. • Planning audits, particularly in choosing topics and focuses amidst the vast array of options. • Lack of awareness about the environmental auditing practice among the public and politicians. 24

25. SAI’s role in promoting national sustainable development • Launching Environment Audit: SAI Bangladesh has already conducted five environmental audits and identified some weaknesses such as, gaps between policy on paper and policy in practice, complexities and lack of mutual cooperation, inadequate departmental functions and operations, weak financial management and data collection weakness. • Participating Capacity Building Program: Government Officials are trained on environment audit by ASOSAI, iCISA and IDI. Three of them obtained diploma in environment audit. 25

26. SAI’s role in promoting national sustainable development • Initiatives to build and establish relationships with elected assembly, governments, their colleagues, and external stakeholders by launching media cell, organizing workshops and observing Audit Day. • Integrating environment and sustainable development by audit practice. • Reducing office waste and energy consumption, creating paperless office by launching AMMS and also introducing electronic working papers. • Audit of Climate Fund. 26

27. Conclusion SAIs are committed to good environmental governance and accountability. Therefore, SAIs can play a vital role in informing and supporting efforts to achieve sustainable development by doing quality Environment Audit. So SAI Bangladesh has a particularly important role to play to ensure that our government is accountable, responsible and responsive to ensure environmental sustainability and promote national sustainable development. 27

28. THANK YOU