The impact that stricter hygiene and other food safety requirements have had on landing beaches and the success of efforts to enhance capacity must be viewed in the context of the prevailing physical and management infrastructure along the shores of Lake Victoria. Generally, fishing communities are characterised by severe infrastructural constraints, whilst efforts to effect sustainable management of the fishery in a manner that is inclusive of local interests have been largely ineffective.
Box 5. Costs of compliance for Plant 3:
This plant is owned by a company that also operates bakeries and hotels. It started processing Nile perch in 1992 and currently operates one facility with a capacity of nine tonnes per day. This is currently operating at five tonnes per day for four days per week because of problems obtaining a sufficient supply of fish. The facility currently has 75 permanent employees.
Fish is sourced through agents that operate on five beaches. The Company provides a truck and ice to ensure reliable transportation of fish to the processing facility. Agents are paid an agreed price at the factory. Periodic checks are made at the beaches to ensure the price being paid is ‘reasonable’. Agents that have been used for a long time are provided with funds to purchase fish, although to a maximum of 50 percent of the purchase value.
Prior to the restrictions on exports, 70 percent of exports were to the EU, with other less important markets including Japan, United States, Latin America, Middle East and China. However, since the ban it has not attempted to export to the EU and major markets are now Japan, China, Middle East and the United States.
The Company has had to make significant changes to its processing facility in order to comply with current hygiene requirements. These include the installation of partitioning and revisions to the layout of the factory to ensure segregation of operations, new tables and other equipment, up-grading of the laboratory, recording thermometers and on-line chlorination. Further the costs of implementing HACCP and staff training have been significant. The total cost is estimated to be US$26,800.
The Company has also made changes to its production process, including new sanitation regimes. More quality control staff have been employed (there is now a quality control manager and five supervisors) and processing staff have been assigned to particular operations for which they have been trained, reducing flexibility. The speed of work has also declined because of the need to implement and monitor temperature controls. Further, more samples are required that are sent to KEBS for analysis. Overall, the increase in costs of production is estimated to be 5 percent.
Overall, the management of the Lake Victoria fishery has been characterised by ineffective institutions and poor enforcement and implementation of legal controls under the Fisheries Act (McCormick and Mitullah, 2002). Further, in general Fisheries Department staff is poorly paid and there is a lack of an enabling environment in which they can undertake their duties (Geheb,
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1997). Whilst attempts have been made to implement more effective management, these have tended to lack co-ordination and frequently multiple institutions have co-existed that overlap and even conflict in their responsibilities and actions.
It is evident that the ban on exports of Nile perch to the EU has served to focus attention on the need for better management of the fishery and, in particular, the importance of co-management in which local communities have an integral role. Indeed, the Kenya Development Plan issued in 2002 has co-management as a priority (GOK, 2002). Further, fishers are increasingly seen as central to the development of infrastructure and the effective management of both the fishery and landing beaches, even amongst fish processors.
The capacity of fishing communities to up-grade capacity has further been compromised by the lack of fundamental infrastructure at most landing beaches, in turn reflecting lack of investment over the longer term (Ong’ang’a, 2002). Access roads are frequently in poor condition or missing altogether, limiting access to alternative markets and creating quality problems as a result of the considerable period of time taken for trucks to get from landing beaches to processing facilities. In most cases there are is little or no access to running water and toilet and other sanitation facilities are rudimentary at best.
In all of its inspection reports the European Commission has identified weaknesses in hygiene standards at landing beaches (European Commission, 1998; 1999; 2003). Key infrastructural requirements include toilets, potable running water, perimeter fence around the banda where fish is traded, and paving from the edge of the lake to the banda. Ideally, fish would be landed onto a jetty to avoid contact with water along the shoreline which is invariably polluted. In its most recent report, the Commission requested written assurances on beach improvements and a specified timeline during which these would be implemented.
Initially, the Fisheries Department established a Landing Beach Development Committees (LBDC) to plan and co-ordinate improvements at each landing site with a view to achieving acceptable standards (Fisheries Department, 2002). These included District Fisheries Officers, Public Health Officers, Beach Leaders and/or community chiefs, and representatives of fish processors. However, LBDCs did not work well, most notably because of a lack of effective representation of fishers and attempts to impose solutions to capacity problems on local communities.
More recently, the Fisheries Department has established a Lake Victoria Beach Improvement Committee that has identified priority beaches (see below) and the required improvements to meet EU hygiene standards. Currently, this has officials from the Fisheries Department and representatives of industrial fish processors, but not local fishing communities. For each of the identified beaches a Beach Improvement Unit (BIU) has been established under the leadership of a fisheries officer. The Fisheries Department has also trained 20 beach inspectors to manage handling of fish and ensure good hygiene on a day-to-day basis. Efforts have also been made to sensitise fisher-folk in the importance of good hygiene and management of the fishery.
The Fisheries Department has identified a number of minimum basic facilities that allow hygienic handling of fish at each beach:
• Paving and provision of proper drainage at sorting sheds and loading zones.
• Perimeter fencing to exclude animals and human activities not related to the fish business.
• Provision of potable water.
• Improvement of sorting sheds, with adequate fish sorting tables. • Provision of adequate sanitation facilities.
• Provision of adequate insulated fish boxes, with ice for fish collection. • General cleanliness of the beach.
• Provision of anaerobic digestor toilets.
A series of further improvements has also been identified that would ensure standards of hygiene are compliant with EU requirements and otherwise promote good standards of hygiene and quality in the supply chain:
• Provision of electricity and water. • Construction of landing jetties.
• Modernization of fish reception bandas. • Improvement of access roads.
• Construction of ice plants/cold rooms.
Figure 27. Improved banda at Dunga beach:
Various estimates have been made of the cost of beach improvements to meet the standards of hygiene required by EU standards. For example, McCormick and Mitullah (2002) suggest the cost is as great as US$1.2 million. However, it is evident that there has been a tendency to over- estimate these costs, perhaps as part of efforts to attract more significant donor support. However, the Fisheries Department and/or AFIPEK estimate that the cost of basic beach improvements to be around US$99,000 per beach and a further US$225,000 for extended
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improvements (Table 12). Perhaps the scale of the required funding (and the magnitude of the estimates) explains why only limited progress has been made to date. Indeed, the Fisheries Department has identified the need for an integrated approach involving funding from the Government of Kenya, fish processors, local communities and donors (DF, 2001). A draft joint proposal by stakeholders representing BICs, BMUs and the Fisheries Department on Infrastructural Development of Fish Landing Sites in Kenya has subsequently been developed. A number of investments have been made in beach improvements, although these have not always been co-ordinated effectively and have proceeded in a piecemeal fashion with funding through a variety of donors. Box 6 and Figure 27 provide illustrations of some improvements that have been made to date and confirm the widely varying standards that remain across individual landing sites.
Table 12. Estimated average cost of landing beach improvements:
Improvement Cost
(US$)