Original Article

Exploring policy compliance of the South Africaninformal milk-producing segment

Mike Agenbaga, Ryk Luesa,* and Liezel Luesb

aProgramme Environmental Health, School for Environmental Development andAgriculture, Private Bag X20539, Central University of Technology, Bloemfontein,Free State, 9300, South Africa.E-mail: rlues@cut.ac.za

bDepartment of Public Administration and Management, Faculty of Economic andManagement Sciences, PO Box 339, University of the Free State, Bloemfontein, FreeState Province 9301 South Africa.

*Corresponding author.

Abstract Our study assessed whether municipal health services were informedabout and exerted adequate control over the informal milk-producing sector inSouth Africa. The results indicated that municipal health services had limitedcontrol. Only one municipality was authorised to allow the sale of raw milk in itsarea. In most metropolitan and district municipalities, the distribution of raw milkcontinues, even where no statutory investigations assessed the ability to control thepractice. The national and provincial government should recognise and supportcapacity building to enable municipalities to exercise power and perform theirfunctions regarding informal milk distribution, part of the informal sector that hasprovided opportunities for employment and additional income. This constitutes achallenge particularly in monitoring and control of high-risk foods.Journal of Public Health Policy advance online publication, 19 January 2012;doi:10.1057/jphp.2011.59

Keywords: informal milk production; milk hygiene; policy; environmental healthservices; municipal health services

Introduction

The informal milk trade

Food safety remains a major public health concern. It has influenced thepolicies of many countries,1–3 regarding responsibility and accountabil-ity.3–5 Although producers may be partly responsible, food safety is ashared responsibility, involving government, industry, and consumers.3,6

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According to Fairman and Yapp,7 the primary motivation to improvefood safety in small and micro-businesses was intrinsic, but originatedfrom external enforcement agencies, such as the environmental healthservices that metropolitan and district municipalities offer.

In developing countries, migration from rural to urban areas owing tounemployment has led to more livestock farming around towns and peri-urban areas, where the majority of households keep cattle.8–12 Althoughmost households have milk cows that they milk principally for their ownuse, many non-livestock-owning households obtain milk from suchcattle owners.9,11 In developing countries, the informal sector constitu-tes the main source of milk, marketed predominantly through informaloutlets (hawkers/informal street vendors, unregistered brokers, and soon).5,10,12,13 In fact, the entire milk industry may depend on small-scalefarmers (1–3 cows per farmer), confirming the vastness of informal milkproduction.13 Milk quality – raw milk, in particular – from the informalsector is a public health concern, because of the health of cows andimproper milking practices. The latter often fail to comply with goodmanufacturing practices, and thus enable zoonotic and other infec-tions.5,9,14–15

The South African regulatory landscape

Although the scale of the unregistered milk trade is limited, informalmilk producers in metropolitan and district municipalities in SouthAfrica pose a challenge to regulatory authorities with limited resou-rces.9–11 Both formal milk producers and commercial retailers objectto the inadequate control over the informal sector by local governmentand the Department of Health.5,14,16 They see the informal sector havingan unfair advantage.

The South African government has recently implemented theAccelerated and Shared Growth Initiative for South Africa17 to speedeconomic growth. The government targets emerging producers (includ-ing informal milk producers), linking them with bulk buyers such asschools, hospitals, and correctional services.12,18–23 The South Africangovernment expects its organs to assist the informal sector becomeaccountable, legal, and integrated in the mainstream economy.17,24

In South Africa, the national government implements laws andpolicies enacted by the parliament. Several departments only exist atthe national level and deal exclusively with issues that concern the

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country as a whole (for example, Defence, Foreign Affairs, and so on).Provincial and local governments operate within national legislativeguidelines. Nine provincial administrations are responsible for provin-cial regulation and budgeting within certain departments: Treasury;Cooperative Governance, Traditional Affairs, and Human Settlement;Economic Development, Tourism, and Environmental Affairs; Educa-tion; Health; Social Development; Police, Roads and Transport; PublicWorks; Sport, Arts, Culture, and Recreation; and Agriculture and RuralDevelopment.

The Provincial Department of Cooperative Governance, TraditionalAffairs and Human Settlement coordinates, monitors, and supportsmunicipalities. Each of South Africa’s local municipalities has its owngovernance structure, consisting of political representatives (council)and municipal officials. The Council manages an annual budget andimplements services following integrated development plans (IDP).

The IDP is a 5-year strategic planning tool linked subsequently to theannual implementation plan (Service Delivery and Budget Implementa-tion Plan, SDBIP). The latter integrates the budget and performancemanagement system with the planned outcomes. The municipal admin-istration headed by the Municipal Manager organises the activities of themunicipality.

South Africa has three kinds of municipalities: metropolitan, local,and district. Their functions include: electricity delivery; water forhousehold use; sewage and sanitation; storm water systems; refuseremoval; fire fighting services; municipal health services; decisionsaround land use; municipal roads; municipal public transport; streettrading; abattoirs and fresh food markets; parks and recreational areas;libraries and other facilities; and local tourism.24 In accordance with thepowers and functions allocated to the local government, metropolitanand district municipalities are responsible for Municipal Health Services(environmental health services), which includes, among others, foodcontrol.

Defining the problem

Currently, no registration system exists for informal milk producers,which hampers information transfer between the producers and theauthorities,9,11 making it difficult to determine the extent of informalmilk production, the quality of milk, and the economic impact of the

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sector. Furthermore, it is illegal in South Africa to sell milk from anunapproved milking shed without a certificate of acceptability (CoA) orprovisional certificate of acceptability (PCoA). In fact, the sale of milk(or any food product) that poses a risk for consumers is illegal.25,26 Inprinciple, the Ministry of Health enforces food control legislation viamunicipal government whose environmental health practitioners reg-ulate the informal milk-producing sector. Yet, at the time of our study,many municipalities had no authorisation to do so under Section 231 ofthe Foodstuffs, Cosmetics and Disinfectants Act (Act 54 of 1972).

We designed our study to learn whether designated authorities wereaware of informal milk producers in their jurisdictions, and whether theauthority had control over the hygiene of milk from the informal sector.We describe the extent of the informal milk production in metropolitanand district municipalities, as well as compliance with legislation. Arelocal governments allowing the sale of raw milk in accordance withthe Foodstuffs, Cosmetics and Disinfectants Act, 1972 (Act 54 of 1972)?The ultimate purpose of our study was to inform authorities and tofacilitate increased standardisation of milk quality across all sectors, andeventually contribute to a safe product, irrespective of the source.

Materials and Methods

Backdrop

For purposes of this study, informal (unregistered/unauthorised) milkproduction refers to raw milk from an unregistered milking facility offeredto the public.25–28 An unauthorised milking shed is a structure where milkis produced for human consumption without a CoA or PCoA, from therelevant local government under Section 2 of Regulation 1256 of 27 June1986. These producers vary from commercial to subsistence farmersoperating on commonages (common holdings) and smallholdings aroundtowns. The latter group may supply milk to individuals and families, aswell as to small retail enterprises, street vendors, and cafes.8–12,20,29

The survey instrument

Before the study, we obtained consent from the National Department ofHealth: Directorate Food Control, the South African Institute ofEnvironmental Health and the Health Professions Council of South

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Africa: Professional Board for Environmental Health Practitioners, andothers. We used a structured, coded questionnaire to acquire informa-tion about management and control of milk hygiene (focussing on milkfrom cows). Our focus was on the control of informal milk producers.We used closed and open-ended questions,30,31 including 67 questions inEnglish, divided into five categories.

K Section A: affiliation of the individual reporting on behalf of themunicipality – position, responsibility, and residency;

K Section B: resources and systems – human resources, transport,equipment;

K Section C: milk production practices – applicable legislation, registra-tion, record keeping, compliance, and so on;

K Section D: distribution of milk – monitoring, sampling, and qualitycontrol; and

K Section E: general knowledge, attitudes, and beliefs of the respon-dents.

We piloted the questionnaire on environmental health practitioners withexposure and knowledge in the field. They did not partake in the actualsurvey. Our pilot study was to ensure that questions were complete,relevant, and unambiguous.31

Sampling and data collection

South Africa has 231 municipalities including 46 district and sixmetropolitan municipalities. (A seventh, Mangaung, recently added,did not exist at the time of our survey.)32 The study populationcomprised the entire municipal health services management cohort of46 district and six metropolitan municipalities. We targeted municipalhealth services managers or individuals directly responsible for milkquality monitoring and control. Where district municipalities had notyet assumed responsibility or appointed a full-time municipal healthservices manager, we asked an environmental health practitioner con-cerned with the coordination of municipal health services to completethe questionnaire.30,31 The study team e-mailed or faxed the question-naires to the respondents, with telephone follow-up. We receivedcompleted questionnaires via e-mail, facsimile, or post. Coding ofquestionnaires enabled tracing for consequent telephonic follow-up.

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We achieved a 90.38 per cent overall response rate (n¼ 47), whichincludes all metropolitan municipalities.

Data analysis

We coded and analysed questionnaires in collaboration with theDepartment of Biostatistics at the University of the Free State usingthe SAS 9.1.3 Service Pack 3. The results were presented in tables withfrequencies and summary proportions.

Results and Discussion

Informal milk suppliers

In general, the respondents thought that the estimated number ofinformal milk producers in their jurisdiction was notable when com-pared with formal milking parlours (Figure 1). The minimum andmaximum number of informal milk producers varied between 0 and200, and the formal milking parlours between 0 and 402. We estimatedthat one informal milk-producing source existed, on average, for every69 166 people, compared with one per 30 953 for each milking parlourwith a CoA or PCoA. There are about twice as many informal per capitaas registered milk-producing units.

200 400

Informal milkproducers

Milking parlourswith CoA/PCoA

45

50

35

40

25

30

15

20

5

10

0

NU

MB

ER

Figure 1: The ratio of informal (unregistered/unauthorised/illegal) milk production sources

compared with formal milk production sources (each box plot represents the 25th and 75th

percentile with the median, and the whiskers indicate the minimum and maximum values).

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Control by metropolitan and district municipalities

Of the 55.3 per cent of the respondents aware of informal sources of milkin their area, only 20.0 per cent reported that they were controlling suchsources (Table 1). Of these, 60.0 per cent were doing so mainly bysampling and analysis, 40.0 per cent by legal action, and 20.0 per cent byregular inspections and outreach. Were municipalities actively lookingfor informal milk producers? Only 57.4 per cent (n¼ 27) replied in theaffirmative. The respondents reported using area surveys (96.3 per cent[n¼ 26]) information/complaints from communities (55.6 per cent[n¼ 15]), plus advertisements in newspapers and sampling surveys todraw attention to the issues.

More than half of the respondents indicated awareness of unregisteredmilk-producing sources, but 76 per cent of the district municipalities

Table 1: Awareness of unregistered milk-producing sources and the control thereof by local spheres

of government

Frequency Percentage

Knowledge of unregistered milk production sources in area (n=47)Yes 26 55.3

No 7 14.9Don’t know 14 29.9

If yes, do you have control over them? (n=25)Yes 5 20.0No 19 76.0

Don’t know 1 4.0

If yes, specify what kind of control (n=5)Education 1 20.0

Sampling 3 60.0

Regular inspection 1 20.0Court cases/legal action 2 40.0

Do you try to detect other informal sources of milk production? (n=47)Yes 27 57.4No 20 42.6

If yes, please specify (n=27)Routine inspections/area surveys 26 96.3Information from communities/complaints 15 55.6

Advertisements in local newspapers 1 3.7

Sampling 2 7.4

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reported no control over them (Table 1). At the time of the survey, therewere no registration systems for informal milk producers, making itdifficult to determine the real extent of this sector. Difficulty inmonitoring may have been exacerbated by geographic dispersal and byproducer timidity about reporting. Despite evidence of their existence,many respondents (42.6 per cent) indicated making no attempt to traceadditional informal milk producers.

Authorising municipalities to permit the sale of raw milk

For the local government to permit the sale of raw milk, they mustapply to the Ministry of Health to be listed in Annexure C of Regulation1555 of 21 November 1997, providing proof of capacity to control thesale of raw milk. Before South Africa mandated metropolitan anddistrict municipalities in 2004 to render municipal health services,including food control, local municipalities could be listed in AnnexureC. Some district municipalities opted not to take on the municipal healthservices function, even though they were statutorily required. For thisreason, we asked the respondents to tell us the number of authoritieslisted in the annexure. Table 2 shows the number of local municipalitiesper district municipal area compared with the number of local munici-palities, metropolitan, and district municipalities listed, plus the numberof local spheres of government formally allowing the sale of raw milk.

Although a municipality is not obliged to allow the sale of raw milkwhere it lacks resources and control mechanisms, unofficial distributionof raw milk does occur in most. On average, 1.3 authorities per metro-politan and district municipality are listed in Annexure C as authorisedto allow the sale of raw milk. The listing includes more than themetropolitan and district municipalities, as required by law. Disestab-lished municipalities or local municipalities without legal responsibi-lities also appear in Annexure C. As further shown in Table 2, on averageone municipality per metropolitan and district municipality formallyallowed, as per council resolution, the distribution and sale of rawmilk. A value 41 suggests that more than one authority (local, metro-politan, and district municipality) per metropolitan and district islisted. Annexure C of Regulation 1555 of 199725,33 confirmed the actuallistings. Only one district municipality (West Coast District Municipal-ity, Western Cape Province) is listed under its latest name in Annexure Cto allow the sale of raw milk in its entire area of jurisdiction.33 Apart

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from this municipality, none of the other municipalities is correctlyauthorised, as only metropolitan and district municipalities can beauthorised to allow the sale of raw milk.

Were local spheres of government not listed in Annexure C aware that ifthey continued to allow the sale of raw milk without being listed they couldbe accused of dereliction of duty and could also be open to consumer legalaction? Fifteen or 34.9 per cent of the respondents said they were unawareof their non-listing (Table 3). Another 27.9 per cent (n¼ 12) reported beingunaware that their non-listing could have implications, if they continued toallow the sale of raw milk without being listed.

To help authorities determine their capacity to deliver a municipalservice, including municipal health services that also encompass foodcontrol, the authorities can perform a Section 78 (S.78) assessment(investigation) in accordance with Sections 76 and 77 of the MunicipalSystems Act, 2000 (Act 32 of 2000). In fact, the Act makes it compulsoryfor authorities to conduct such an assessment, for a new service or when

Table 2: Listing of local government in Annexure C of Regulation 1555 to allow the sale of raw milk

in their respective areas of jurisdiction

Mean Median 25thpercentilea

75thpercentileb

Standarddeviation

Minimum Maximum

How many local municipalities are there within the area of jurisdiction of the district municipalitythat you are reporting on? (n=43)

4.9 5.0 4 6 1.9 2 10

How many of the authorities (local, metropolitan, and district municipalities) in your area ofjurisdiction are listed in Annexure C in accordance with Section 3(2) of Regulation 1555(21 November 1997) of the Foodstuffs, Cosmetics and Disinfectants Act, 1972 (Act 54 of 1972) toallow the sale of raw milk in your respective areas of jurisdiction? (n=34)

1.3 0.5 0 2 1.8 0 6

How many of the authorities (local, metropolitan, and district municipalities) formally (according

to a council resolution) allow the distribution and sale of raw milk in your area of jurisdiction?(n=29)

1.0 0 0 1 1.7 0 6

How many of your authorities (local, metropolitan, and district municipalities) are listed inAnnexure C under the latest names (that is, Ukhahlamba District Municipality or Senqu Local

Municipality) of the authorities? (n=25)0.4 0 0 0 1.3 0 6

a,bThe 25th and 75th percentiles are the respective scores below which 25 and 75 per cent of the

observations may be found.

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a service is expanded significantly. The assessment is an evaluation, via astandardised capacity analysis, of their ability to deliver a municipalservice effectively. Table 3 shows that only 25 per cent (n¼ 7) of themunicipalities had completed S.78 assessments at the time of the survey.Another 25 per cent of the respondents indicated that their metropolitanand district municipalities had completed some part of the assessmentprocess (Table 3). A more recent study revealed that approximately64 per cent of the district municipalities that had commenced S.78assessments had completed an S.78 report,34 yet in some provinces,none, at the time of the study, had begun S.78 investigations.34,35

Discussion

We knew little about the extent of the informal milk supply in SouthAfrica.8,9,36 Only the number of informal farmers in South Africa was

Table 3: Local spheres of government’s awareness of their listing in Annexure C and their Section 78

assessment in accordance with the Municipal Systems Act, 2000 (Act 32 of 2000)

Frequency Percentage

Are the authorities that are not listed in Annexure C in your area of jurisdiction aware that if theycontinue to allow the sale of raw milk without being listed, they can be accused of dereliction of dutyand may also be open to legal action by consumers who become ill due to the consumption of rawmilk? (n=46)

Yes 16 37.2

No 12 27.9

I am not aware of their non-listing 15 34.9

Is it compulsory for a metropolitan and district municipality to do a Section 78 assessment formunicipal health services in accordance with S.78 of the Local Government: Municipal Systems Act,2000 (Act 32 of 2000)? (n=46)

Yes 28 60.9

No 4 8.7

Don’t know 14 30.4

If Yes above, has your metropolitan and district municipality done or initiated a Section 78assessment for municipal health services in accordance with S.78 of the Local Government:Municipal Systems Act, 2000 (Act 32 of 2000)? (n=28)

Section 78 assessment in planning stage 4 14.3Section 78 assessment o50% completed 1 3.6

Section 78 assessment 450% completed 2 7.1

Section 78 assessment completed 7 25.0Nothing has been done 11 39.3

Don’t know 3 10.7

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known. Informal milk producers are not limited to small-scale farmersin informal settlements, as they include medium-scale dairy parloursin predominantly marginal-urban settlements. De Waal,8 Jansen9 andDovie et al11 concurred that most informal farmers in the provinces ofthe Free State and Limpopo consume their own milk, but Jansen9

reported that 39.6 per cent of the respondents sold milk to other families.According to Dovie et al,11 44 per cent of non-livestock-owning house-holds obtained milk from small-scale livestock owners. Jansen9 reportedthat in the settlement of Monyakeng in central South Africa, farmersowned on average six cattle per household. De Waal8 in a survey of peri-urban livestock owners concurred. Dovie et al11 suggested that milk wasthe main reason owners kept cattle and that cattle-owning householdskept between two and 67 cattle, mostly dairy cows.11 Jansen 9 also foundthat the cows produced between 1 and 5 litres of milk per day, less thanhalf of what is expected from a healthy cow. This allows one to estimatethe volume of milk produced in the informal sector.

According to Steenkamp,37 milk production increases by 20 per centwhen protocols are changed from milking twice daily to three timesdaily, but according to Jansen9 the majority (69.8 per cent) of therespondents milked their cows only once a day, suggesting that thevolume of milk from the informal sector could grow. We believe an adap-tive environmental health approach – from policing to development –should go a long way to getting more participation from the informalsector.38 Local governments are not required to apply to the Ministry ofHealth to be listed in Annexure C33 unless the individual municipalitywants to allow the sale of raw milk and possess the capacity to control it.Since July 2004, only metropolitan and district municipalities can applyfor such listing.39 However, the sale of raw milk across the countrycontinues to be a common practice, irrespective of the legislativestipulations.14,16,40–47

Conclusion

Our results underline the importance of local governments using theirauthorities to ensure milk hygiene monitoring. They may integrate foodmonitoring into their IDPs, SDBIPs, as well as into managers’ perfor-mance management indicators. Because budgets must be linked with theIDP and SDBIP, it is unlikely that funds will be allocated to programmesnot listed in the IDP or part of the annual revised SDBIP.48 Where a

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municipality provides proof to the Ministry of Health of its capacity tocontrol the sale of raw milk by means of a council resolution, this haslimited value if not supported by an approved Section 78 assessment andevidence that milk hygiene monitoring and control constitute a priorityin the key performance areas of the council.48

About the Authors

Mike Agenbag, MTech, is currently the Head of Environmental HealthServices at the Ukhahlamba District Municipality in the Eastern Cape,South Africa. He has served on professional boards and advisorycommittees at the national and provincial level in the field of environ-mental health. The study was part of his Master’s dissertation inEnvironmental Health at the Central University of Technology, FreeState, South Africa. E-mail: mike@jgdm.gov.za

Ryk Lues, PhD, is Professor and Director of the School of Agricultureand Environmental Sciences at the Central University of Technology,Free State. He supervised this study, which is Mike Agenbag’s Master’sdissertation. E-mail: LuesL@ufs.ac.za

Liezel Lues, Doctor in Public Management, is an Associate Professorand Head of the Department of Public Administration and Managementat the University of the Free State, South Africa, and specialises instructures, legislation, and functions across the three spheres of govern-ment: National, Provincial, and Municipal.

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