Review and Assessment of Policy Frameworks Applicable to the Hygienic Production of Fish Products in Africa's Great Lakes

(2020) Review and Assessment of Policy Frameworks Applicable to the Hygienic Production of Fish Products in Africa's Great Lakes. [Report]

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Executive summary Access to adequate WASH and food safety services is critical for good health and wellbeing, and has been prioritised by the global community and national governments as a key public health intervention. The Sustainable Development Goals (#SDG 6.2) seeks to "achieve access to adequate and equitable sanitation and hygiene for all and end open defecation, paying special attention to the needs of women and girls and those in vulnerable situations" by 2030. Despite the prioritisation and general improvement in access to WASH services, many people in low-and middle-income still lack access to adequate services. Most of the countries that disproportionately lack access to WASH services are in sub-Saharan Africa, where the number of people practising open defecation actually increased from 204 million in 2000 to 220 million in 2015. Even within sub-Saharan African countries, rural and other special populations such as refugees and fishing communities are particularly marginalised. Inadequate access to WASH services presents a greater health risk in fishing communities because it increases the risk of contaminated fish sold and consumed both locally and internationally. This risk is particularly greater in the Great Lakes of Africa region which is serves as an important source of fish in Africa and the global market. The objective of this review was therefore to assess the policy and regulatory frameworks for the hygienic production of fish in five countries of the Great African Lakes region—Kenya, Malawi, Tanzania, Uganda and Zambia. In addition to reviewing policies and laws in the five countries, the study also conducted interviews with key stakeholders in Malawi and Kenya as case studies to understand the barriers to policy implementation and for recommendations on the necessary steps to address these challenges. The policy analyses found key similarities in the policies and legal framework for sanitation, hygiene and food safety in the five countries. All the countries had laws and policies that sought to regulate different aspects and players in the food chain, from manufacturing through distribution to consumption. However, with the exception of Zambia which recently passed a Food Safety Act, none of the countries has an overarching policy that coordinated the implementation of food safety in the different sectors by government institutions and the private sector. The lack of an overarching food safety law or policy resulted in the duplication of functions and conflicting roles among government agencies. A major barrier to implementation is the absence of an elaborate implementation plan and criteria for monitoring and evaluating food safety and quality standards and guidelines implemented by the multitude of institutions overseeing different aspects of the sector. Another major barrier is the lack of adequate funding for the WASH sector especially as it relates to food safety. The budget for the WASH sector in almost all the countries is less than 1% of GDP, with most funding coming from donors and development partners. In addition, many of the agencies particularly at the sub-national level do not have the capacity to undertake critical services such as laboratory testing and analysis, daily inspection and surveillance to guarantee food safety. In spite of the existing barriers to implementation, there are opportunities for policy reform and prioritisation of WASH and food safety in the five countries. A key opportunity at the regional level is the recent African Union policy and reform strategy for food safety in fisheries. The AU reform calls on member states to invest in appropriate technology, infrastructure and capacity development programmes to enhance fish safety and quality. All the five countries are member states of AU and can advantage of this regional reform strategy to reform their own policies and strengthen existing programmes and institutions of food safety in the fisheries sector. At the country level, important policy changes have occurred in Malawi and Zambia that can spur progress in those countries and also learning in Kenya, Tanzania and Uganda. In Malawi, the government has introduced a budget line for sanitation and hygiene, an important step to bridge the funding gap in the WASH and food safety sector. In Zambia, a comprehensive Food Safety Act has been passed to ensure coordination and clarity in the implementation of food safety standards and guidelines by various actors. Given the barriers to the implementation of WASH and food safety standards and guidelines, a number of policy actions and strategies have been recommended in this study to address those barriers and improve food safety in the five countries: Prioritise the enforcement and implementation of existing WASH policies and food safety standards and guidelines particularly targeting fishing communities and small-scale fishers and vendors. Accelerate efforts and encourage Malawi, Kenya, Tanzania and Uganda to develop an overarching food safety policy or law to address the uncoordinated food safety activities of different institutions and stakeholders. Increase domestic resource mobilisation and develop a comprehensive costed plan for the implementation of policies and guidelines on WASH and food safety. Review policies and regulations on fisheries safety that are out of date to conform to recent policy changes at the African Union. Strengthen the capacity of WASH and food safety agencies and personnel to enforce standards and guidelines. This includes strengthening the capacity of institutions to conduct laboratory analysis, inspection and surveillance.