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An Estimation of Compliance of the Fisheries of
Bangladesh with Article 7 (Fisheries Management) of the
UN Code of Conduct for Responsible Fishing
by
Ganapathiraju Pramod and Tony J Pitcher
This evaluation of compliance with Article 7 (Fishery Management) of the UN Code of Conduct for
Responsible Fishing (FAO 1995) is a ‘living document’ and may change with time. It is one of 53 such
country evaluations covering the top 96% of the world fish catch. Using a wide range of cited source
material, the document represents the best attempt by the authors at presenting a fair and objective
evaluation of compliance using 44 questions derived from the Code. Questions are divided into six
evaluation fields, (Management Objectives; Framework (data & procedures); Precautionary Approach;
Stocks, Fleets and Gear; Social and Economic factors, and Monitoring, Control and Surveillance): the
derivation of the 44 questions is described in Pitcher (1999). The first three fields cover intentions of a
country’s legislation to adhere to the Code; while the last three evaluation fields are intended to rate
actual performance. Full details of the methods are published in Pitcher, Kalikoski and Pramod (2006).
This evaluation has been subjected to several internal cross-checks and, where stated, has been
validated by experts familiar with the country concerned. Uncertainty in assigning each score is shown
explicitly. However, the authors are aware that omissions and errors of interpretation may still remain
for some countries. An open protocol has therefore been adopted for all country compliance
evaluations, and the team remains open at any time to comments, corrections or adjustments. Updated
versions are made available online as necessary (ftp://ftp.fisheries.ubc.ca/CodeConduct).
FAO (1995) Code of Conduct for Responsible Fisheries. FAO, Rome, 41pp.
Pitcher, T.J. (1999) Rapfish, A Rapid Appraisal Technique For Fisheries, And Its Application To The
Code Of Conduct For Responsible Fisheries. FAO Fisheries Circular No. 947: 47pp.
Pitcher, T.J., Kalikoski, D. and Pramod, G. (eds) (2006) Evaluations of Compliance with the UN Code
of Conduct for Responsible Fisheries. Fisheries Centre Research Reports 14(2).
General
Ranked 35th in world catch 1999 309,797 tonnes (FAO)
NOTE: Bangladesh, with a coastline of 710 kms and EEZ area of 166 000 km2, derives only 20% of its
total fishery production from marine capture landings with the bulk of landings coming from vast
network of perennial rivers flowing into coastal areas of Bangladesh. The country “has an internal
estuarine water area of 7,325 sq. nautical miles upto 10 fathom depth baseline, and territorial waters
of 2,640 sq. nautical miles from the baseline” (Kamal, 1994). The status of Least Developed Country
(LDC) has led to fisheries sector acting as buffer for poor performance of other sectors like
agriculture, and natural catastrophes like annual floods (Most of coastal areas in Bangladesh are
below sea level leading to seasonal flooding of several low lying areas during monsoon season). The
2
fisheries sector is 1also impacted by shortage of trained manpower, lack of concrete management
policy, inadequate infrastructure and monetary allocation to scattered fishing centres. Fisheries sector
has served as a major source of employment for large section of population in coastal areas with a
growth rate of 3.9 per cent during 1984-1999. According to Ministry of Fisheries and Livestock, with
regular influx of new fishers employment in the fisheries sector grew from 123,562 in 1984 to 916,539
in 1999, showing a 14.3 per cent growth rate during 1984-1999 (GOB, 2001).
Article 5 of the FAO Code of Conduct dealing with special requirements of developing countries states
that in order to “…support its effective implementation, countries, relevant international
organizations, whether government or non-governmental and financial institutions should give full
recognition to the special circumstances and requirements of developing countries, including in
particular the least-developed among them and small island developing countries….” (FAO, 1995).
Full consideration has been given to above issues during the assessment in this document both for
scoring and data gaps.
“The Agreement on Subsidies and Countervailing Measures in the Uruguay round has a number of
provisions relating to “special and differential treatment” for developing countries (Article 27).
According to these provisions as an LDC, Bangladesh is not required to phase-out export subsidies
and enjoys “special and differential treatment in the form of fewer commitments and protracted period
of compliance.
Stricter controls in domestic fisheries through mesh size regulations and banning of destructive fishing
practices like push nets and bag nets is necessary if Bangladesh intends to rebuild the existing fish
stocks. More efficient use of by-catch and discards in industrial trawl fishery is necessary to prevent
wastage of the resource that can provide cheaper source of protein to a largely impoverished
population. The increased cultural preference of people towards freshwater fishes will mean that there
is less demand for marine fishes except for some marine fishes like Hilsa in the domestic sector. The
industrial fisheries can be regulated to large extent as the country possesses thriving shrimp
aquaculture industry to boast its export revenue. These actions can not only augment marine stocks but
also provide safe haven for fish stocks to recover from overfishing taking place in nearshore waters.
Vessels in both mechanised and non-mechanised sector need to be licensed in accordance with
Amendment 92 of the Marine Fisheries Ordinance, 1983. “The fisheries sector was responsible for
approximately 3% of the total employment level in the country. The real wage rate of the fishers
increased at the rate of 2.28% per annum. The export value of fish grew at the highest rate of 25.17%
per annum between 1972 and 1996. Moreover, the share of fish and fish products in total export value
has been increasing over a period of 24 years” (Khan and Haque, 2003).
1 While assessing Code of Conduct for Bangladeshi fisheries, we were faced with several limitations in assessing fisheries stocks since
there is no clear dichotomy between fresh water, brackish and marine fisheries resources. So, some fish resources exploited in the vicinity
of mangroves and coastal waters with brackish water influence were reported as freshwater stocks in many instances. Hence, in the
present study areas subjected to marine water influence during high tides, including mangroves fringing the seaward side were treated as
marine for convenience. There is also large underreporting in small scale and subsistence fisheries on south eastern section of the coast,
where catches caught in marine jurisdiction are landed far inland, resulting in underreporting from the marine jurisdiction. The nation
also does not possess an accurate inventory for number of fishermen and fishing nets in subsistence and small scale fisheries making
current enumeration of total landings erroneous.
3
Bangladesh: Code Score Profile
0
2
4
6
8
10
reference points
capacity
small-scale
biodiversity
restore depletions
habitat impacts
bycatch restricted
ecosy stem linkages
environment
all life stages
compatible jurisdictions
long-term objec tives
all stakeholders
decisions transparent
statistics collected
sustainability evaluated
precaution explic it
uncertainty quantified
target ref points
limit ref points
environmental emergency
fishing emergency
management review
no take areas
protect ecosys tem links
capcity reduced
methods harm ful
bycatc h minimized
discards minim ized
ghost fishing
juvenile catc h
depleted stock s rebuilt
conflict minimiz ed
indigenous people
local com munities
cost-effectiveness
social im pact
industry funding
observers
catch ins pection
vessel monitoring
illegal fishing
enforcement IUU
flags of convenience
Score and Confidence Limits /10
1 MANAGEMENT OBJECTIVES 2 FRAMEWORK 3 PRECAUTIONARY PRINCIPLE 4 STOCKS & GEAR 5 SOCIAL & ECONOMIC 6 MCS
Note: Scores for Q6.4 and Q6.6 have been flipped in the above figure to show fisheries compliance
Field 1: Management Objectives
1. Are formal reference points for the fish stock in fisheries identified using best science
available?
Score: 2
Score Range: 1-4
Marine landings data collection is inadequate.
Yes, reference points are estimated for a few commercial fish stocks but not on a regular basis. The
reference points estimated include MSY, CPUE and growth parameters for some estuarine and marine
fish stocks. Parameters K, Z, M, F, E and Lc are estimated for two species of shrimps and nine species
of fin fishes. Population parameters L∞, K, M, F, and Lc are calculated for important commercial
finfish and shellfish species in the Estuarine set bag net fishery (Khan and Latif, 1997). However, there
are several gaps in analysis, with inadequate coverage of all fish landing centres and less frequency of
landings being monitored. The Department of Fisheries under Ministry of Fisheries and Livestock is in
charge of stock assessment in Bangladesh. Limited data is available on a regular basis through
exploratory surveys. Comprehensive evaluation of stock size and other parameters is not done regularly
both for demersal and pelagic fish stocks. On the whole, data assessment is irregular and not done on a
yearly basis. Lack of financial and human resources restricts the capability of scientific staff to conduct
regular scientific assessments of fish stocks in its entirety for the marine ecosystem.
2. Is present fleet capacity calculated and are there plans to reduce it?
Score: 3
Score Range: 2-4
Yes, fleet capacity is calculated. But, no measures are currently in place to reduce capacity. The fleet
size has remained stagnant at 3317 mechanized vessels and 14014 non-mechanized boats from 1987 –
4
1998. The number of trawlers decreased from 67 in 1984 to 49 in 1992 with an increase thereafter
reaching 60 in 1998. Mechanized boats generally go on multi-day trips lasting 8-10 days while non-
mechanized boats go on single day trips (Khatun et al, 2004). No fleet statistics are available during
1999-2000 and between 2001-2006 making it difficult to estimate fleet capacity for the last five years.
In 2001 there were a total of 21,830 mechanised boats, 28,707 Non-mechanised boats engaged in
fishing. In addition there were 67 trawlers engaged in industrial fishing, of which 48 were engaged in
shrimp fishing and 19 in other fishing practices (GoB, 2001).
Mechanised Trawlers (1972-2001)
0
10
20
30
40
50
60
70
80
1972
1975
1977
1979
1981
1983
1985
1987
1989
1991
1993
1995
1997
1999
2001
Year
Number of vessels
Table. 1. Showing the number of mechanised trawlers operating in Bangladesh marine waters.
Source: Government of Bangladesh, 2001; Khatun, 2004; Rahman, 2004
Artisanal Fishing Boats (1972-1998)
0
2000
4000
6000
8000
10000
12000
14000
16000
1972
1973
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
Year
Number of Vessels
Mechanised boats
Non-mechanised boats
Table 2. Showing the number of mechanised and non-mechanised boats operating in small-scale
fisheries. Source: Government of Bangladesh, 2001; Khatun, 2004; Rahman, 2004
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3. Are small-scale fishers considered in plan and are there institutional structures for ongoing
consultation?
Score: 3
Score Range: 2-6
Some channels for communication exist but no formalized institutional structure exists for consultation
with small scale fishers.
Small scale fishers are given limited priority in allocation of rights to fishery resources through Marine
Fisheries Ordinance, 1983 which has special provisions allocating coastal waters upto 50 metres depth
exclusively for small scale fisheries. 80% of total fisheries landings come from brackish water and
freshwater areas exploited by small scale sector. In Bangladesh the extent of freshwater and brackish
water fisheries is high compared to marine fisheries due to large volume of freshwater runoff from
numerous rivers emptying through Bangladesh into Bay of Bengal extending the freshwater influence
farther into the Territorial zone. Most of the fresh and brackish water resources are allocated to fishers
through periodic licensing system.
“The basic mechanism for managing fishery resources in inland open-waters of Bangladesh has been
based on allocation of fishing rights through periodic leasing. The Ministry of Land directly owns the
rivers, their tributaries and seasonal as well as perennial wetlands. For the sole purpose of revenue
generation, the Ministry of Land leases out stretches of rivers and wetlands, called jalmahals, to
intermediaries, called Ijaradars, i.e., leases through auction. In the auction process, the lease is given to
the highest bidder. The river fisheries and the seasonal beel fisheries are normally leased out for a term
of one year while the permanent beels are leased out for a 3-year term. The lease period commences on
the first day of the Bengali Year and terminates on the last day of the same year. Some beel fisheries
and group fisheries are leased out to the same lessee for 6 years and in rare cases, up to 9 years”
(Parveen and Faisal, 2000).
Khatun et al, (2004) state that small scale fishermen do not have access to credit facilities provided by
the government. Further, they state that absence of procurement centres has forced fishermen to sell
their catch at low prices to middlemen who provide fewer benefits to fishermen.
4. Impacts of fishery on biodiversity allowed for in plan and are mitigation measures in place?
Score: 3.5
Score Range: 2-4
No, impacts of fishery on biodiversity are not taken into consideration both in fisheries legislation and
existing management structure in Bangladesh.
5. Does the management plan aim to restore depleted stocks in this fishery?
Score: 2
Score Range: 1-4
No, the management plan has no concrete plans to restore depleted fish stocks or manage existing
stocks in a sustainable manner. The open access fisheries coupled with lack of monitoring has resulted
in overfishing and resource depletion along several areas of the coast. The widely scattered and discrete
mangrove belt in the southern part of Bangladesh makes it difficult for the limited personnel to enforce
6
fishery regulations along Bangladesh coast. Lack of clear distinction for brackish water and marine
stocks is resulting in discrepancy in data for fisheries management in Bangladesh.
Species composition for commercial fin and shell fish has under gone rapid change with reports by
FRSS since 1981 showing decline of percentage of white shrimp and increase in percentage of brown
and smaller categories of shrimp in landings (Kamal, 1994). This is understandable given that 99 per
cent of shrimp post larvae are collected and discarded leading to both recruitment and growth
overfishing creating continuous loss of spawning stock biomass over the years.
The low costs associated with initial capital investment for estuarine set bagnets has made them among
the most popular destructive fishing nets in use among coastal fisherfolk along Bangladesh coast.
Moreover, the composition of fishing gear used by fishing communities shows that “41 per cent of the
total number of units of gear are set bagnets, 38 per cent are Hilsa gillnets and the rest belong to the
‘other gear’ category, which includes trammel nets, longlines, other gillnets, beach seines etc” (BOBP,
1990).
‘The Ministry of Land directly owns the rivers, their tributaries and seasonal as well as perennial
wetlands. For the sole purpose of revenue generation, the Ministry of Land leases out stretches of rivers
and wetlands, called jalmahals, to intermediaries, called Ijaradars, i.e., leases through auction. In the
auction process, the lease is given to the highest bidder. The river fisheries and the seasonal beel
fisheries are normally leased out for a term of one year while the permanent beels are leased out for a
3-year term. The lease period commences on the first day of the Bengali Year and terminates on the
last day of the same year. Some beel fisheries and group fisheries are leased out to the same lessee for 6
years and in rare cases, up to 9 years. This pattern of dividing the rivers into segments and leasing them
out to middlemen lease holders or ijaradars have encouraged over fishing of fish stocks. The situation
in the seasonal beels is worse, where every year, during the dry season, the last fish is taken out by
draining the beels. The situation in permanent beels is not much different. In such beels, brush shelters
are placed in deeper regions to create safe haven for mother fish stock. Unfortunately, fish taking
shelter in these deeper pockets are caught annually even though this is not legally allowed. At the end
of the lease, all fish are extracted and that leaves no room for survival of both large and small fish”
(Parveen and Faisal, 2000).
6. Are human impacts (pollution, waste) on the fishery habitat identified and mitigated?
Score: 3.5
Score range: 3-6
Yes, human impacts on fishery habitat have been identified but not mitigated. Further, there are still
gaps in identifying the impact of pollutants on animals in coastal habitats. The high influx of freshwater
run off it has the potential to disperse pollutants very farther into the sea. Petroleum Act, 1974 provides
for control of spillages and interference with natural resources and the environment. Bangladesh
Marine Pollution Control Ordinance provides regulations for controlling oil pollution. Water Pollution
Control (Amendment) Order 1973 and Environment Pollution Control Ordinance 1977 broadly cover
all types of environmental pollution.
“More than 900 polluting industries directly or indirectly discharge their untreated liquid and sold
wastes into brackish water bodies. The Karnaphuli and the Rupsa-Bhrab rivers, which receive effluents
from 309 industries in Chittagong and Khulna are major carriers of industrial contaminants like
Ammonia, chromium, Mercury, Phenols and DDT. Reports are available of direct fish kills and the
toxic effect on mortality of post-larvae and juveniles in the nursery grounds. Coastal cities and towns
7
do not have waste treatment facilities and hence release sewage and domestic wastes directly into the
Sea. Since 1977, the use of agrochemicals both fertilizers and pesticides has been increased by about
400 per cent” (Mahmood et al., 1994). Oil pollution from Chittagong and Mangla port is also reported
due to absence of waste reception and treatment facilities. Ship breaking operations from Chittagong
and Kulna also discharge potentially noxious compounds like asbestos, oil and other endocrine
disrupting and carcinogenic compounds into coastal habitats. No mitigatory processes are currently in
place to phase out these activities.
“Bangladesh strategic review notes that half of the 900 industrial firms identified as polluting belong to
the leather and textile industries” (Rahman et al., 2003)
7. Is fishing gear mandated by the management plan to avoid by-catch of non-target species,
environmental and habitat damage?
Score: 0
Score Range: 0-2
No, fishing gear is not mandated by law to avoid by-catch of non target species. Marine Fisheries
Ordinance 1983 requires each shrimp trawler to bring 30% of its total catch of white fish to the shore,
but operators are not reported to comply with the same.
Moreover, Bangladesh is perhaps one of the few countries in South Asia where there is a exclusive
target fishery for post larvae of shrimps and fish juveniles for aquaculture purposes leading to massive
destruction of nursery grounds and very high recruitment overfishing all along its coast.
8. Are ecosystem linkages with this fishery made explicit in the management plan and are
adverse effects minimized?
Score: 0
Score Range: 0-2
No, they are not recognized.
Brackish water hydrology is largely affected by a prolonged low-saline regime during the monsoon and
post monsoon seasons. Salinity increases with tidal effect, with the reversal of currents influencing
circulation and productivity of water. A huge discharge of freshwater runoff from numerous rivers is
dominant feature of the coastal marine environment. Oxygen deficit zone is prominent in subsurface
layer of outer shelf area (FAO, 1968). Further, several rivers have been diverted, barrages and dams
constructed, and mangroves cut for aquaculture adversely affecting migration and spawning of several
commercial fish stocks, with some stocks declining as low as 99 per cent (Hilsa) (Mahmood, 1995).
9. Are environmental influences on this fishery made explicit in the management plan and are
adverse effects minimized?
Score: 1
Score Range: 0-2
No, environmental influences on the fishery are not made explicit in the management plan or
legislations.
Field 2: Framework (data & procedures)
8
1. Are total and complete removals from the stocks over the whole stock area and over whole life
cycle accounted for in assessment?
Score: 0
Score Range: 0-2
No, stock removals through exploitation are not accounted for in stock assessment. Moreover, the data
collection is scanty and very few landing centres are regularly monitored regularly making data
assessment highly erroneous on the long run.
2. Are management measures compatible with those of other jurisdictions concerned with the
stocks?
Score: 0
Score Range: 0-0
Not as far as we can determine .
3. Does the management plan have clearly stated long-term objectives?
Score: 1
Score Range: 0-2
No, very less priority has been afforded to management of marine and brackish water fish stocks in a
sustainable manner.
4. Are all the stakeholders in this fishery resource identified and considered?
Score: 2
Score Range: 0-2
No, socio-economic needs of coastal communities are fulfilled to a very limited extent, and the sector
does not possess effective planning strategy for long term management of the resources.
The Bangladesh Fisheries Development Corporation (BFDC) was established in 1964 by the
government of Bangladesh to promote marine fishing industry. The corporation operates several
trawlers, fish landing centres and fishing net factories. The government also provides assistance to
coastal communities through micro-credit programmes and training in aquaculture.
5. Are data, management processes and decision-making open and transparent, including any
international aspects?
Score: 2
Score Range: 1-4
No, to a very limited extent. Fishery legislations are not amended regularly. The Marine Fisheries
Ordinance, 1983 has not been updated and new changes have not been incorporated to bring fisheries
management on par with international legislative changes that took place within the last two decades.
Further, in spite of the phenomenal increase in landings from marine sector in the last five decades the
government has not invested in cold storage and procurement facilities making the sector highly
volatile and susceptible to external influence from private sector and middlemen. The decision taking
process is also not open and transparent over the years since the development of the sector in mid
eighties.
9
6. Are timely, complete and reliable statistics collected and verified?
Score: 2
Score Range: 1-3
No, to a very limited extent
The Department of Fisheries under Ministry of Fisheries and Livestock is entrusted with the
responsibility of collecting and compiling fishery statistics. “The department of Fisheries appointed one
survey officer, reporting through District Fishery Officers who collects catch and effort data of
different fishing gears. They provide all information to the Fishery Resource Survey Systems (FRSS)
to compile the official fishery statistics. Catch and effort are sampled by gear type and species are
collected mostly from some selected landing sites in each district. The survey officer visits landing
centres in district and collects for 11 species of marine artisanal fisheries: Hilsa, Bombay duck, Indian
Salmon, Pomfret, Sharks ands Rays, jewfish, snapper, mackerel, large and small shrimp. Catches are
recorded in weight (kg). Other data include the number of fishermen on board, type of gear, number of
days per trip, number of trips in the preceding fortnight, number of days at sea during the period and
the number of set bagnets. In the marine industrial fisheries catch and effort data are collected from
commercial trawlers for four shrimp species and total catch of finfish in tons” (Kamal, 1989).
7. Are social, economic and institutional factors related to sustainability evaluated with data?
Score: 2
Score Range: 1-3
No, only to a limited extent through co-management projects and micro-credit programmes supported
by international donors, local Grahmeena banks and support agencies.
An assessment of socio-economic conditions of estuarine fisherfolk who are the prominent fishers in
coastal waters reveal that certain social features/relations (family size, participation of family members
in fisheries, fishery-related and non-fishery jobs, distribution and ownership of fishing assets, sharing
of catch value etc. have affected the living standards of these fisherfolk. Survey also revealed that
fishing households in Bangladesh have a higher family size than the national average (Bangladesh
Bureau of Statistics, 1990). Fishing villages are characterized by a high rate of illiteracy, low female
participation in fishery-related and non-fishery activities, high dependency on earning members in
villages, shortage of facilities for higher education, which may force the younger generation to the
same old activities and increase human pressure on resources (BOBP, 1990).
Field 3: Precautionary Approach
1. Is precaution explicitly enshrined in legislation, and is it applied to management of fishery
stocks?
Score: 0
Score Range: 0-0
No, precaution is not explicitly stated in the legislation.
2. Is uncertainty, including lack of appropriate information, quantified and used to restrain
fishing that might otherwise occur?
10
Score: 0
Score Range: 0-0
No, uncertainty is not used to restrain fishing of fish stocks; very limited measures have been taken to
completely quantify fishing effort.
3. Are stock-specific target reference points estimated and employed?
Score: 0
Score Range: 0-0
No, target points are not estimated in Bangladesh marine fisheries.
4. Are stock-specific limit reference points estimated and employed?
Score: 2
Score Range: 1-4
Few limit reference points like FMSY, BMSY, and Yield per recruit are calculated for some commercially
important finfish and shellfish stocks, although not on a regular basis.
5. Are there viable contingency plans to restrict fishing in the event of an environmental
emergency?
Score: 0
Score Range: 0-0
No, the government does not possess either the financial or manpower to handle environmental
emergencies.
6. Are there viable contingency plans to restrict fishing in the event of an unforeseen emergency
caused by excess fishing?
Score: 0
Score Range: 0-0
Not as far as we can determine.
7. Are management instruments under continuous review?
Score: 1.5
Score Range: 1-4
No, to a very limited extent. Most of the fisheries laws have not been amended to meet the current
requirements.
8. Are no-take areas of sufficient size to work, established, policed and monitored as an
insurance?
Score: 2
Score Range: 1-3
Limited marine protected areas exist along Bangladesh coast, but there is virtually no enforcement to
protect the reserve areas.
11
Several sections of the coast have been declared as marine protected areas, but they are not adequately
policed and monitored to achieve the desired conservation goals. Many of these protected areas are
prone to poaching, over exploitation and destruction through conversion of mangrove areas into
aquaculture ponds.
Directorate of Fisheries under Ministry of Fisheries and Livestock is responsible for protection of
marine fisheries and coastal ecosystems. Environmental Pollution Control Board (EPCB) was
established in 1977 and assists in formulating environmental policy and makes recommendations
pertaining to environmental legislation.
Current Marine Protected Areas include Char Kukri-Mukri Forest Reserve and Wildlife Sanctuary (40
ha), Sundarbans Forest Reserve (571,508 ha, ESCAP, 1988) and east Wildlife Sanctuary (5,439 ha),
south Wildlife Sanctuary (17,878 ha) and west Wildlife Sanctuary (9,069 ha), Chakaria Sundarbans
Forest Reserve, and Teknaf Game Reserve (Pernetta, 1993).
“Bangladesh Wildlife Preservation Order 1973 promulgated under Presidential Order No. 23 in March
1973 and subsequently enacted and amended as the Bangladesh Wildlife (Preservation) (Amendment)
Act, 1974 provides for the establishment of national parks, wildlife sanctuaries and game reserves, and
for the establishment of a Wildlife Advisory Board. Species protected under this act include
Balaenoptera musculus, Balaenoptera acutorostrata, Platanistagangetica, Delphinus delphis,
Neophocaena phocaenoides, Elephas maximus, Macaca fascicularis, Aonyx cinerea, Lutra
perspicillata, Panthera tigris, Panthera pardus, Pelecanus philippensis, several sea birds, Leptoptilos
dubius, Leptoptilus javanicus, Tringa gutti$era, Haliaeetus leucoryphus, and the reptiles Trionyx
nigricans, Crocodylus palustris, Crocodylus porosus, Gavialis gangeticus and three Varanus species.
Marine Fisheries Ordinance 1983 provides for the establishment of marine reserves for fauna and flora,
covering all aquatic animals and requires the licensing of all fishing vessels, domestic and foreign; the
total number of trawlers is limited to 40, there are controls on their structure, and recommendations for
mesh size and size limits for shrimp have been drawn up. No regulations protect small-scale fisheries”
(Pemetta, 1993).
9. Are plans in place to restrict fishing if species linked through the ecosystem to the target(s) of
this fishery become threatened?
Score: 0
Score Range: 0-0
No such plans are in place currently to replenish fish stocks.
Field 4: Stocks, fleets and gear
1. Is excess fleet capacity being reduced?
Score: 0
Score Range: 0-0
Not as far as we can determine.
2. Are fishing methods known to be harmful to habitats, to create by-catch problems, or whose
high fishing capacity is difficult to control, being phased out?
Score: 0
12
Score Range: 0-0
None of the destructive fishing gears targeting by catch have been phased out in Bangladesh fisheries.
3. Is by-catch of non-target species minimised?
Score: 1
Score Range: 0-2
No, very limited measures are in place to reduce by-catch of non target species due to lack of storage of
storage facilities and usage of smaller mesh size nets in both coastal and offshore fisheries.
“The beach seine fishery is operated along the coast of Chittagong and Cox’s Bazar. This fishery
catches mostly juvenile fish and shrimp. As a consequence they fetch very low prices and are seldom
transported elsewhere and are usually marketed fresh. The drift gillnet fishery uses mainly two types of
nets: viz. the small-mesh drift-nets for catching Hilsa and the large-mesh net for catching Indian
salmon and large croakers. A large quantity of fish caught by the shrimp trawler is thrown overboard
because it is of low value or the crew has little time to handle the catch or there is a lack of space in the
fish hold. It is assumed that the amount of discards may be up to 80% of the actual catch, which is
equivalent to 30 - 35 000 t annually. The freezer trawlers refrigerate the fish in gunny bags that are
stacked one upon the other in the fish hold. These fish get crushed under their own weight and hence
fetch low prices. More than 2 035 million post-larvae of Tiger shrimp (P. monodon) are collected
annually by push-net, which is only a little over one percent of the total catch of the push-net fishery
(Paul et al., 1993). The rest of the catch is thrown on the sand to die, which is equivalent to about 200
billion post-larval shrimp, and fish larvae and zooplankters. This is serious growth over-fishing. Annual
production of the beach seine fishery was estimated at about 7 320 t. of which most of the catches were
pre-juveniles and juveniles of jewfish, anchovies, clupeoids and penaeid and caridean shrimp. As a
result all the catches by this net do not get a chance to join the spawning process” (Rahman, 2003).
4. Are discards minimised?
Score: 0
Score Range: 0-0
No, discards are very high in Bangladeshi fisheries even when compared with other Asian nations.
Most of the trawlers operating in Bangladesh are purchased second hand and inadequately equipped
with cooling facilities. Moreover, lack of infrastructure facilities in ports and harbours force boat
operators to discards large amount of cheap fish at sea. It is also a common practice to discards low
value fish when high value fish are caught in subsequent hauls Khatun et al., (2004).
“Discard rates in the order of 80% lead to discards of over 50,000 tonnes in Bangladesh’s shrimp and
finfish trawl fisheries while estuarine pushnets collecting penaeid larvae discard 90% of the catch.
Fisheries with high discard rates include the offshore finfish trawl in Bangladesh. Pushnets exhibit a
wide range of discard rates from 90% for those collecting penaeid post larvae (Bangladesh) to 0-1% for
those operating in the Gulf of Thailand and South China Sea” Kelleher (2004). Further the report states
that Bangladesh has one of the highest discards in non-shrimp fisheries in the world in industrial finfish
trawling targeting Saurida, Upeneus, Sepia species. The average discard rate was 17%, with 64,578
tonnes discarded for 314,966 tonnes of landed catch which is very high when compared to other
maritime countries in the Bay of Bengal. According to the Bangladesh Frozen Food Exporters
Association 35,000 to 40,000 tonnes of low value fish are wasted every year due to lack of
infrastructure facilities in landing centres.
13
“Finfish landed by the trawler fleet is in the range of 8 000 - 12 000 t, which is only 20% of the actual
catch, while 80%, equivalent to 35 - 45 000 t (White and Khan 1985), is discarded at sea” (Rahman,
2003). Estimates from 1980-1990 by Bangladesh Fishery Development Corporation reveal that post
harvest losses from discard by Bangladeshi trawlers were estimated to range between 30,000 to 40,000
MT per year (Kamal, 1994). BOBP (1991) reports that everything except for shrimp less than 20 cm is
discarded by shrimp trawlers. However, the discards might have reduced over the years with increasing
demand for these fish in shrimp feed industry. But, no current reports exist to substantiate the same.
5. Is gear designed to minimise ghost fishing if lost?
Score: 0
Score Range: 0-0
No measures are in place to restrict ghost fishing in Bangladesh waters.
6. Is the fishing of juveniles and spawners restricted to safe levels?
Score: 0
Score Range: 0-0
No, in fact the discards of juvenile shrimps and fish are more than the bigger sized fish that are landed
in Bangladeshi fisheries. The presence of big sized fish has been very much reduced over the years due
to indiscriminate recruitment overfishing preventing new recruits to the adult stock.
“…..show that industrial fishing in Bangladesh has already exceeded the maximum sustainable yield
(MSY) level. The recent trend in coastal fishing shows omens of bad harvests and finally extinction of
marine fishery resources in the Bay of Bengal. All fishers whom we interviewed in four sample sites
reported declining fish catch in their daily fishing trips” (Khan and Haque, 2003).
7. Are depleted stocks being rebuilt?
Score: 0
Score Range: 0-2
No, only to a very limited extent. The “Sunderban mangrove forest” due to its large extent offers
limited protection to marine fish and shrimp resources.
Field 5: Social & Economic
1. Is the fishery managed so as to minimise conflict among different sectors?
Score: 2
Score Range: 1-5
To a limited extent the government has managed to reduce conflict between artisanal and industrial
sector by limiting licenses given to industrial vessels and by delineating waters below 50 m to small
scale fisheries.
“Fish trawlers catch a number of species which the small scale fishery also catches. Prominent among
them are ribbonfish, Jew fish, croaker, and Hilsa. Shrimp trawlers also catch some fish and discard a
part which would otherwise have been available to the small scale fishery. Now that both these trawler
14
types are fishing in near-shore waters, they catch all species. They destroy nets set by small scale fish-
ers and sometimes steal these nets. Such incidents have been increasingly reported in recent years. The
Coastal Fishermen Coordination Committee, an organization of the fishers in our study site at
Chittagong, has reported that 200 such cases took place in the first two months of fishing in the 1999
season. Physical assault on small fishers is also a common feature. All this has implications for the
costs of fishing by the small scale fishers and increases their risks” (Khan and Haque, 2003).
2. Are Indigenous Peoples rights and needs in fisheries being met?
Score: 5
Score Range: 5-5
No indigenous people are known to exist in coastal areas in Bangladesh. However, there are several
indigenous tribal’s living in Chittagong plains inland. The government does not recognize these people
as indigenous tribes. The tribes have fiercely resisted attempts by government to rule or allow people
from other areas to settle in their areas. However, it is not known whether any of these groups are
engaged in fisheries in coastal areas.
3. Are the needs of local fishing communities being met?
Score: 3.5
Score Range: 2-5
Yes, to a very limited extent. Although the government has allocated scanty resources to fisheries
management in coastal and inland areas, soaring population growth has further aggravated the situation
leading to rise in fishery production by increasing fishing effort and using unsustainable fishing gears
endangering the very resource on which the populace depend. The government has not incorporated a
precautionary approach leading to decline of forestry (mangroves) and several commercially important
fish stocks in coastal waters over the past five decades.
“The Bangladesh Fishermen Cooperative Society is the association of fishers in both marine and inland
fishing sectors. All government assistance to fishers is channeled through this organization. Like coop-
eratives in other sectors, the representation of fishers and their participation in it is not deemed satisfac-
tory. The boat owners in the marine sector have their national association with their head office at
Chittagong. There are owners’ associations in different parts of Bangladesh” (Khan and Haque, 2003).
4. When a change to the management of the fishery is made, is its cost-effectiveness evaluated?
Score: 3.5
Score Range: 2-5
No, given the limited financial options available for the government with priorities mainly based on
developing agricultural land or near coastal resources. Limited information on cost effectiveness of
small scale and industrial fisheries is available in Khan and Haque (2003).
5. When a change to the management of the fishery is made, is its social impact evaluated?
Score: 4
Score Range: 2-5
No, social impacts of management change are not evaluated.
15
Very few changes have been made in fisheries management in Bangladesh either through new
legislations or by incorporation of new management strategies. However, government takes cognizance
of changes occurring in small scale fisheries and gets funds for improving livelihoods for education,
infrastructure development, building new boats through many international donors and agencies every
year.
6. Is funding for the research and the MCS programme obtained by cost recovery from the
industry?
Score: 0
Score Range: 0-0
No, monitoring coasts are entirely funded by the federal government.
Field 6: Monitoring, Control & Surveillance (MCS)
1. On a ten-point scale, how effective is the observer scheme?
Score: 1
Score Range: 0-2
Very poor monitoring
The capability of Bangladesh to monitor and restrict foreign vessels or their national fleets is restricted
to port state control for vessels entering and exiting their ports like most developing countries in Asia.
At sea capabilities are very limited. Lack of infrastructure and trained personnel further restricts their
MCS capabilities. Presently the priorities are focused on aquaculture as opposed to management of its
coastal and offshore fishery resources. Marine resource management laws are not regularly updated.
The country does not have an at-sea boarding and inspection capability and uses only port inspections
with lack of formalized procedures for inspection reports and absence of a data management system
with cross checks on catches and landings (Flewwelling, 2001).
“To patrol the EEZ, the DOF procured two modern gunboats and placed them under the operational
control of the Bangladesh Navy” (Islam, 2003)
2. On a ten-point scale, how effective is the catch inspection scheme?
Score: 1.5
Score Range: 1-3
Very poor.
Marine resource management laws are not regularly updated. The country does not have an at-sea
boarding and inspection capability and uses only port inspections which lack formalized procedures for
inspection reports and data management system with cross checks on catches and landings
(Flewwelling, 2001).
3. On a ten-point scale, how effective is the vessel monitoring scheme?
Score: 0
Score Range: 0-1
16
The capability of Bangladesh to monitor and restrict foreign vessels or their national fleets is restricted
to port state control for vessels entering and exiting their ports like other countries in Asia. At sea
capabilities are very limited. Lack of infrastructure and trained personnel further restricts their MCS
capabilities. Presently the government’s priorities are focused on aquaculture as opposed to
management of its coastal and offshore fishery resources.
Pirates are also known to hijack trawlers along the Bangladesh coast regularly demanding ransom in
return for release of trawlers. In a recent report 70 Bangladesh fishermen were held hostage from seven
trawlers demanding a ransom of approx. 1,587 dollars from vessel owners (Zeenews, 2006).
4. Are vessels fishing illegally in fisheries?
Score: 7.5
Score Range: 5-10
Vessels from Bangladesh do not have the capability to fish beyond EEZ waters and are not engaged in
illegal fishing in the High Seas. Reports from HSTF (2006) confirm the same. However, local fisheries
include much unreported and illegal catches.
5. On a ten-point scale, how effective is control of access in stopping illegal fishing?
Score: 0
Score Range: 0-2
Very ineffective given few trained personnel, poor infrastructure and shortage of financial support for
monitoring beyond coastal waters.
6. Are vessels that really derive from this jurisdiction reflagged in states of convenience, generally
to avoid reporting or other fishery regulations?
Score: 0
Score Range: 0-0
Gianni and Simpson (2005) report that no vessels from Bangladesh are reflagged to fish illegally in
high seas or foreign waters.
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