United against Malaria?

May 5, 2005

By Sani Garba Mohammed

'FG to spend N350m on treated bed net' is a captioned story in the New Nigerian
of 22/4/05; this was disclosed by Ministry of Health Prof Eyitayo
Lambo in this year malaria day tagged 'United against Malaria'. The
plan is expected to provide 12m net in the next 5yrs to pregnant women
and children, not withstanding that in the last 5yrs he said they were
only able to provide 4m nets.
What baffle me is, for how long shall we be wasting our energy, time
and resources in buying a net that is hardly being used and
unavailable, despite continues claim of the government that it is
supplying net. Every health worker, irrespective of his profession,
knows that malaria is an environmentally based disease, hence its
total prevention and control lies in environmental management than
nets and drugs. The issue of nets does not even constitute up to 2% of
malaria. Mosquitoes, that caused malaria is attracted by stagnant
water in our drainages, abandoned cans and tin, old tyres, un clearing
of weeds and grasses, and failure to evacuate waste we are generating
daily to lay it eggs and survive there.
Therefore, to me, wasting time on only nets and drugs as a measure to
roll back malaria is not only a window dressing but also unfortunate.
Neglecting and failure of the government to invest much in the
environment, which favours the survival of the vector causing the
disease is un-called for. Instead, it paid more attention in ACT and
nets which is more profitable and attractive to the government and
even the donors.
Recently, National Environmental Sanitation policy was formulated
which covers all aspect of environmental health control, yet because
the attention of government is more to politics, nothing has changed.
Instead, the pre-occupation of Federal Ministry of Health is in the
curative measures than preventive. This is also more favourable to the
promoters of the nets and the drugs, whom are raking interest in the
process, as a result, prevention is [was] downplayed.
If we really want, achieve the theme of this year malaria day –'United
against Malaria', then all hands must be on deck from environmental
health perspective to pharmaceutical health angle. In addition,
environmental health practitioners [aka sanitarians] must be
incorporated in any move of diseases prevention and control to play
their roles, or the mission will remain a mirage.

The abuse drainage and building regulations in Kano

April 24, 2005
By Sani Garba Mohammed
Drainage is a sewerage network that rid away liquid waste from
residential, commercial or industrial areas to either water treatment
plant or a body of water. Drainages help in making all the liquid
waste we generated from one or more of the above areas above, thus
making our environment better, clean, attractive and a desirable to
live.
However, nowadays, the story is different; wherever you go the
opposite is the case. Instead, it is now turn in to dumping depot of
all kind of waste ranging from waste soil, stones, polythene, and
others, relative to the kind of waste being generated at the place
from occupational residue. You hardly find a good and free drainage
within Kano city and it environs. Walking round the city will reveal
to you that our drainages are in shambles, neither authority nor
individuals are playing any roles to clear all the refuse within, are
evacuated. Though some philanthropist are doing it, nevertheless,
immediately the waste is out, it will be allowed there, and later goes
back to it former position. No wonder, in our living environment, we
are being disturbed by noxious and offensive odour as a result,
precisely during rainy season which do even cause flooding.
All our drainages are full with all sort of garbage, nylons and
dangerous waste, but it seem both the government and the public are
paying lip service in making sure the trend is reversed. Is it we did
not value our health any more [considering the danger such pose to
us], or are we big enough to clear our drainage? Everybody [in most
cases] has drainage network from his house to the common drainage that
will convey liquid waste to it final destination, yet to even instruct
his son to clear it, seems impossible.
I learnt that evacuating and maintaining of drainage is a duty of
KASEPPA, but the questions is, does it live up to it expectation, I
doubt much. Many roads within Kano city has no provisions of
drainages, why does KASEPPA allow building in areas where drainage is
not provided, in some areas, building are so overcrowded that drainage
cannot be constructed and it is watching. Many questions need to be
answered by KASEPPA as per drainages and building, but still nothing
to write home about, there are many drainages that need to be
evacuated as they are blocked with many waste, yet nothing is taking
place.
The same thing with building or built environment; housing situation
in Kano state is nothing to write home about, as houses are built
haphazardly, as if no regulations exist. In a bid to meet the
increasing demand of accommodation, property owners and developers
have turned many places into squatters. Due to this, houses are built
without toilet, bathroom etc; people defecate any where [e.g. trade
fair complex field, around old city wall, inside drainages etc] and
channelled their waste water from bath and cooking activities to the
open, thus providing breeding places for mosquitoes and flies as well
causing nuisances to the public.
Conceptually, the built environment includes all of the physical
structures engineered and built by people--the places where we live,
work, and play. These edifices include our homes, workplaces, schools,
parks, and transit arrangements.
Our built environment also affects individual mental health as well as
population-wide well-being. Housing type and quality, neighbourhood
quality, noise, crowding, indoor air quality, and light have all been
linked to personal mental health. Indirectly, the built environment
may influence development and maintenance of socially supportive
networks within a community.
Now houses are built unplanned with little or no paying attention to
the effect that will have on the occupant and the environment. The
factors being considered at site before building like nature of the
soil; moisture content; natural lightning and air movement; location
from possible sources of nuisances; topography of the site etc are now
neglected. Houses are just springing up in any plot whether or not the
place is suitable.

More worrisome is the work of Environmental health officers [EHOs]
hijacked by Engineers and town planners at places like KASEPPA and
others. The aspect that law authorised them [EHO] to look into
include: size of the plot; size and area of the building that is going
into the plot applying the appropriate building regulations; the
dimensions of the rooms to determine their sizes in compliances with
the building regulation; the positions and areas of window and doors
to ensure that the house is properly lighted and ventilated; the
availability and adequacy of sanitary facilities within the structures
e.g. kitchen, toilet, bathroom and store; the total area covered by
the building is checked to ensure that the plot is not overbuilt; the
necessary ,allowance maintained between the proposed building and
buildings on the adjacent plot and the distance between the proposed
building line etc and other consideration etc.
Even though it not KASEPPA alone that has responsibility over building
and drainages, local government unit of environmental health is not
playing any roles similar to the ones I stated above [which they have
power and authority within their area of jurisdiction], so also the
public are not co-operating to help government in discharging its
duties.
Whatever it is, the fault is of KASEPPA, Environmental Health Officers
at local government levels and the public. KASEPPA [perhaps] is not up
to expectation due to logistic problems, inadequate manpower
competency and lack of fund; the local government Environmental health
unit is either docile in exercising it power toward the control of
building and drainages or succumbing to the Nigerian factor-corruption
by allowing people to build nay way they like; and the public are
further compounding the situation by their failure to adhere to
building regulation and making effort in evacuating their drainages,
instead, they are expecting government to do for them.
Above all, even if the government agencies cited above are performing
expectedly, there is also problem where by our so-called 'big men',
'elite', 'politicians' and others power that be, that are either
building on the drainage or even regard some parts of the road[s] that
cover the drainage[s] as theirs, which is unfortunate indeed! If you
try to do your job accordingly, you are bound to see an order from the
above restraining you from further action, that is the end, this is a
nation where we have two types of laws, one for the poor and the other
for the elite.
Also, the failure of KASEPPA in some aspect may not unconnected with
it having no any Environmental Health Officer in it staffs who can
guide them on many issues they do not know ,for they are either
engineers , town planners, administrators etc. Nevertheless, the issue
of environment encompass many sector which need multi sectoral
approach, hence having environmental health officer in it various
positions will help.

Lastly, there should be a collaboration between KASEPPA, REMASAB,
Local government environmental health units and the public in making
sure all hands are on deck to not only help in making our drainage
better, but also our building to conform with the laid down rules and
regulations, and also to make sure the waste we are generating is
disposed up accordingly.

Sani Garba writes in from Zaria Road, Kano

Management of Primary Health Care in Local Government in Nigeria: Between Community and Environmental Health Officers

June 1,2008
The term ‘Primary Health Care’ was used to mean the care given to the patient by the health worker who saw him first. It was also called ‘first contact care’; but if the patient was referred to the hospital it was called ‘secondary care’.
Following this in May 1978, an international conference was headed by World Health Organization [WHO] member states in town in former USSR [now Russia ] called Alma-Ata , where 134 nations including Nigeria declared that Primary Health Care [PHC] is the key to attaining health for all.
At the conference, it was agreed and concluded that Primary Health Care [PHC] is essential health care made universally accessible to individuals and acceptable to them, through their full participation and at a cost the community can afford [WHO/UNICEF 1978].
Bamigboye [2001] see PHC as people oriented service built on the axiom of health of the people, by the people and for the people, and [Lambo 2005] not perceived as the exclusive prerogative of health professions. Its components include Maternal and Child Health [MCH]; provisions of essential drugs; appropriate treatment of common diseases; prevention and control of locally endemic diseases; food nutrition, dental health; environmental health; and health education.
Any discerning listener will quickly realized that there is more to the issue of interpreting correctly the definition and concept of PHC than its implementation. There are underlying disagreements over how PHC problems are defined, their degree of seriousness, who is responsible for solving them, and how amenable they are to solution.
In Nigeria , every health worker talks about PHC, but if you ask them to define or explain the term, they often offer funny explanations. This shows that as important as the programme is, it is still not well understood even by those expected to plan and implement the programme [Ojewale 2003]. Instead of the stakeholders to work as a team, they tend to fight each other on professional bias.
Recently PHC programme clock 30 years, and Nigeria, under Health Reform Foundation of Nigeria [HERFON] reviewed Nigerian Health [System] Review 2007 titled, ‘Primary Health Care in Nigeria: 30 years after Alma ata’, which according to herfon.org touches issues as the historical review of the major milestones in the development of PHC in Nigeria from the pre-colonial period to the recent attempts at health reforms; overview of the essential concepts and features of PHC and a review of the major challenges confronting and constraining its implementation in Nigeria; and analyses of the social, cultural, economic and political issues which affect the functioning and performance of PHC in Nigeria and suggests measures for bringing about change and improvement. It also x-rays the challenges presented by human, financial and material resource constraints; weaknesses and deficiencies in specific elements of PHC including services for women and children are examined in several chapters; role of important stakeholders in achieving national PHC objectives; and vital managerial issues which must be confronted if equity, effectiveness and efficiency are to be achieved in the provision of PHC in Nigeria.


Though I do not have the book, but got some information in the HERFON website on the last year review of Nigeria Health Review, this writing will look at one silent issue which is being bypassed and regarded as non issue at all [perhaps it was not touched in the book], which is critical to the success of PHC programme, but inadvertently is adversely affecting the smooth running of Primary Health Care programme at local governments level, which is the backbone of its implementation at grass root level. This issue is non other than professional conflict or bias that is blinding many health practitioners to regard themselves as the alpha and omega in Primary Health care, which if not them no one knows anything. Though this is common [but bad] within health practitioners, nevertheless my main concern here is at the local government level, where the main practitioners that held sway are Community and Environmental Health Officers, with few others.
The conflict is arising over which practitioner [between Community and environmental Health Officers] shall occupy the position of Primary Health Care Coordinator/Head of Department, and the role[s] each should play in the discharge of their duties. These disagreement run deep, they are either based on different professional training, moral principle, or different values, different assumptions and even personal egocentrism. I will use Kano state as a case reference, where these inter-professional conflict is more pronounced, to the extent that some Community Health Officers see Environmental Health Officer as an enemy that must be eliminated or incapacitated and vice versa, so that they alone leads and determine what becomes the priority needs of Primary Health Care at local government level from their professional perspectives. More so, what is happening in Kano is also happening in most or all states of Nigeria . This writing is not done to hurt anybody, but just to raise awareness on the implication of professional conflict of health practitioners toward rendering their services to the public; and it is not an attempt to write what happened since 1978 to date, but to gives an insight of this problem which had shaped and still shaping the way PHC programme is implemented by usinf recent instances.
Before then, let us know who is an Environmental Health Officer [EHO], and the Community Health Officer [CHO], their duties, limitation and others.

Environmental Health Officer

I quoted "Preventing disease through proper environmental management in the 21st century in Nigeria" [2001], published by the then Professional Association of Environmental Health Officers of Nigeria [PAEHON] and now Environmental Health officers Association of Nigeria [EHOAN].
"This cadre of public health workers came into existing during the colonial era, their statutory function was purely sanitary inspection then as sanitary assistants to the colonial masters.
"In the 19th century, the colonial masters who executed the sanitary duties of our environment in Nigeria were known as sanitary inspectors while the African/Nigerians attached to them were known as sanitary attendants. These attendants acted as aides to their masters to discharge various sanitary inspection activities like marking of tall trees, service of abatement notice etc. under their masters’ directives and close supervision.
"As time went on these sanitary attendants were given more responsibility such as routine sanitary inspection, collection of water samples, survey for breeding places of mosquitoes, as well as acting as guides and interpreters.
“During the early 20th century, with improved educational background, these attendants gathered enough experience from their colonial masters, they were assigned duties such as cutting down tall trees that were close to the residential buildings, identification of infectious disease cases, disinfection and disinfestations, liaison between the colonial masters and villagers, verification of notices issued by their colonial masters [sanitary inspectors], retention of daily, weekly and monthly returns.

1920s-1980

"Dr Isaac Ladipo Oluwole brought about changes in the status of Nigeria health workers. In the 1920s, when Dr. Isaac came back from Britain as public health physician, he was the first African Medical Officer of Health [MOH] in the Lagos colony. He pioneered with vigour, school health services using the then sanitary attendants, including inspection of schools and vaccination of schoolchildren in their school. He started the first Nigerian School of Hygiene at Yaba Lagos in 1920, where qualified persons from all over the Nigeria trained as sanitary inspectors and obtained the Diploma of the royal institute of health [RIH] London, which was later, changed to Royal Society of Health {RSH} diploma, London.
"The first problem that faced the modern day Nigerian sanitary inspectors as early as the 1920 was the outbreak of bubonic plague in 1924. The professional was actively involved in the control of the plague epidemic. Dr. Oluwole revamped port health Duties and made sanitary inspection a vital instrument for the control of communicable diseases using entirely the Nigerian sanitary inspectors.

"All these brought recognition to the sanitary inspectors among other cadre of health workers in Nigeria . They were referred to as "Wole-wole" among Yoruba’s, "Nwaole-ala" among the Igbo’s and "Duba-Gari" among the Hausas. They were a force to reckon with in that colonial era in the area of preventive health services in Nigeria .
"In the 1930s, the educational qualification and training of sanitary inspectors had greatly improved. Thus, the colonial government assigned them the following statutory functions: routine sanitary inspection of houses, markets, schools and communities; waste disposal and environmental sanitation, pollution control and industrial sanitation; water sampling and sanitation; port health duties [air, land and seaports]; ccontrol of communicable disease [infectious diseases].
Other duties were, building and urban planning; vvector and pest control e.g. Malaria control; pprosecution of public health offenders in the court; meat and food inspection; the disposal of the dead [corpses]; ooccupational health and factory inspection; vvaccination/inoculation of both schoolchildren and adults; and health education on personal and public hygiene was also included.
“The establishment of the World Health Organization [WHO] in 1948, brought about changes in the profession, thus many people with higher educational qualification were recruited into the profession and enhanced curriculum to accommodate the need of the society.
“This was evidenced in their immense role in the eradication of Yaws and Smallpox in the late 1940s and early 1970s respectively.

The 1980- to the present day

“In 1988, the name of the profession was changed to Environmental Health officer [EHO] in line with the internationally accepted name of practitioners of the profession and also to accommodate members of the profession who graduated from the university with a degree in public health, environmental health and epidemiology.
“Apart from the general environmental health duties which had hitherto been mentioned this cadre of officer has been very useful in the implementation of primary health care services in the country at all level of government [federal, state, and local government]”.
There are 3 categories of practitioners within the profession in order of superiority, Environmental Health Officer [EHO], Environmental Health Technician [EHT], and Environmental health Assistant Technician [EHAT], so where I used Environmental Health Practitioners [EHPs], I mean all of them, and or EHO, I mean in particular.
Their work include but not limited to the following; administration, inspection, education and regulation in respect of Environmental health; surveillance over health related environmental conditions, including necessary monitoring activities………; act as a public arbiter of environmental health standard, maintain close contact with community; carry out the well established duties of Sanitarian, including inspection of housing and food hygiene, monitoring and control of new hazards due to intensive industrialization; and application of professional standard in his work in relation to non-professionals involved in environmental health, and relate professionally with other health professionals [Journal of Environmental Health June 2006].
The profession has council that regulates it by virtue of act no 11, 2002.




Community Health Officer

According to The Accessible, the publication of Community health practitioners association of Nigeria , Kano chapter Vol. 1 no 1, the history of community health started around 1943. It continues “A missionary medical officer in western part of the country started training community health personnel in part of Ile-Ife present Osun state to take care of some medical problems of its members in order to augment their man power need”.
Community health practice comes as a result of yawning gap in those that will man the Comprehensive Health centre [CHC], Primary Health Centres [PHC] and Local health Centres [LHC] built during Gen Yakubu Gowon.
At that time an attempt was made to put basic health services in the 3rd national development plan [1975-1980], the aims of the scheme was a], to increase the proportion of the population receiving health care from 25-60%; b] to correct the imbalances in the location and distribution of health institution between preventive and curative medicine; c], to provide the infrastructure for all preventive programme such as control of communicable diseases, family health, treatment of minor ailments, nutritional health and others; and d], to establish health care system best adapted to the local conditions and to the level of health technology.

According to National Health Review 2006, “Under the Plan, each local government in the country was to build 25 physical health facilities consisting of one comprehensive health centre, four primary health centres, and 20 health clinics, as well as own and operate five mobile clinics. Different cadres of auxiliary health workers were to be trained, including four levels or types of generalist health workers (community health aids, assistants, supervisors and officers), as well as laboratory, dental and environmental health workers. However, the Plan became financially impossible and difficult to execute in the different parts of the country”.
The 4th National plan succeeded the 3rd plan, which covered the period of 1981-1985. It was during this during period that health as a sector receives a paltry 5% of the national budget and makes Primary Health Care to at least make an impact. Also, “……..at that time, the range and training of the generalist auxiliary community health workers was
reduced to three, the junior and senior categories, the community
health extension workers and community health officers (CHOs).
and many of these were produced……’ [National Health Review 2006].
All these plans and the ones that followed them gave rise to the emergence of community health practitioners in Nigeria .
The community health worker is rural based, as s/he is expected to spend 50% of his time on community based functions and 50% in the clinic.
His/her community based functions are, but not limited to the followings: explain to the community the primary health care approach of the Nigerian health system and his role as a member of the health team to link the community with health care system; carry out community mobilization for health action; participate in, and supervise primary health care house numbering and placement of home-based records; initiate and work with the community and other health workers to carry out general community survey, social and cultural characteristics of the community; and work with other health workers and the community to identify major health problems of the community.
The clinic based functions include: provide integrated primary health care services, collect and collate monitoring and evaluation data for the National PHC from the community and health facility and forward to the district; and carry out day to day administration of health services in the target population.
Right now, there are 3 categories of practitioners in community health in order of superiority, Community Health Officer [CHO], Senior Community Health Extension Worker [SCHEW], and Junior Community Health Extension Worker [JCHEW], all of them are called Community Health Practitioners [CHP]. It has board which regulated its activities under the supervision of department of public health, federal ministry of health, Abuja .


PHC is a programme set to provide health services at the door step of the communities, which encompassed ten components which no any profession [alone] can claim it has the exclusive power or competence to determine who, where and how the programme should run; this is because, among the principles of the programme, there is multisectoral approach, which requires the joint effort of health sector [of which it is an integral part] and other health related sectors, viz education, food and agriculture, social welfare, animal husbandry etc.
But in Nigeria , medical practitioners [precisely doctors] at federal and state levels, and community health practitioners at local governments level regards themselves as alpha and omega of PHC. Anything[s], no matter how good it is, if it does not comes from them or from the perspective they believe, will not scale through, whoever you are, whatever your health qualification, as if you have no input in the programme, whether or not it is within the territory of their professional discipline.
Community health practitioners have been in the forefront at local governments’ level in making sure all other health practitioners are relegated to the background unless you have a certificate in community health course. They are doing all they can, with their collaborators at National Primary Health Care Development Agency [NPHCDA], to stop every health practitioners in becoming Head of Department, Primary Health Care at local government without being a ‘Community health Officer’.
Their effort in making their ambition to be fruitful was further boosted, when NPHCDA compounded the situation by releasing a circular stating those eligible to head PHC departments in local government in Nigeria; the circular was dated 10th August, 2005 with ref no NPHCDA/380 and signed by Dr Shehu Mahdi, the then Executive director. The circular limit those that would be PHC head of department to either be a qualified medical practitioner, qualified nurse/midwife with certificate in public health, qualified nurse/midwife with community health certificate, and community health officer. It also added professionals like environmental health officers, health educators, have a place in the health team but cannot lead the team. This where the partiality of NPHCDA comes, as it considered the other professionals whom are also stakeholders in PHC programme as too inferior to head PHC department at local government.
Kano, considering it has the highest number of environmental health practitioners; the circular can be said has created a crisis which only compounded the already frosty relationship that exists between them and community health practitioners. As at the time the circular was released, some states like Katsina, Edo, etc were said had implement it, and all covert and overt moves are going place in Kano to make sure the enemies-environmental health practitioners are nail and removed, by their supposedly brothers at work-community health practitioners. In fact, Kano members of the later profession went as far as Katsina to jubilate with their colleagues over the new development, and hoping to get the same in Kano .
When the above circular was released, Environmental Health Officers Registration Council of Nigeria [EHORCN]-a regulatory body of environmental health practice, got wind of it; it visited the then minister of health informing him of the development, and the minister claims ignorance, and promised to reverse the circular.
As the above struggle is taking place, Kano community health practitioners were happy and in good mood over the opportunity they have been yearning for long [to push environmental Health practitioners to irrelevancy], now that it is available and emanated from Abuja , they fine tune their strategy to act more aggressively. In fact, they had gone extra mile in preparation to the implementation of the circular by Kano state ministry for local governments, but unfortunately, environmental health practitioners discovered the move, hence they put pliers and unscrew the entire bolt and nuts they screwed, hence the circular was not affected. This coupled with the moves earlier stated of EHORCN which makes sure the circular was render irrelevant and of no effect at all.
Also when it comes to issue of immunization, CHP see themselves as the only people to provide the service, while in an ideal situation, the work is collaborative between preventive health practitioners as epitomize by EHP, and curative health practitioners as represented by other health practitioners. That is why in any local government area where the HOD is CHP, he tends to favour his professional members in all undertakings, to the disadvantage of others.
Considering the role of environmental health in determining the health status of a community, state or nation, on assumption of Ibrahim Shekarau to office as governor Kano state, he ordered for the employment of environmental health workers [aka sanitary inspectors] in each local government in the state. The circular was dated 10th January, 2005, with ref no MLG/OR/CIR/26/vol 1/131, and for record purposes it only stated that graded sanitary inspectors are the ones to be employed in the ratio of 50 in the eight metropolitan local governments and 30 in the remaining 38 local governments.
Though the circular specified who shall be employed, no sooner had it reaches local governments secretariat, than the HODs, whom are over 50% CHP, disregard it and favour their professional members to the disadvantage of those whom the circular meant for, it took a long time battle before the issue was resolved with the intervention of EHP that government should consider others, and the government made a provision, that other health practitioners should be employed. Yet instead of CHP to appreciate the gesture and accommodation of EHP, they re-sharpen their sword for the battle ahead.
These inter fighting is not only in Kano, but applicable in most Nigerian states, where they have substantial number of the practitioners, but only differs in nature, context and perhaps vision [if any].
But if I should ask, when does even community health practice come into being? Who were at local government’s level providing health services before their coming? Do they really know the historical evolution of public health in Nigeria ? Are they the only health practitioners in Nigeria ? Why their arrogance and proud more prominent? Are they indispensable in PHC programme? When PHC does become synonymous with community health workers? The questions are endless.
Even though PHC programme need every profession’s participation [not only CHP], nevertheless, the challenge of EHP in PHC implementation is more daunting than any other profession. By ignoring the artificial but loose boundaries created between the components earmarking them for specific health cares, it is obvious that ‘environment’, i.e. the total sum of the conditions within which organism live directly, or by implication embraces all the components of PHC, as such, it is logical to assert that all the components are source of challenge to EHP.
As health is defined by world Health organization [WHO] as ‘state of complete physical, social and mental well being of person, not merely absent of disease or infirmity’, many see this definition as an idealistic goal rather than realistic definition. There are other definitions from various perspectives, like biomedical, ecological and others, as such, no one or any profession can provide health to anybody alone.
No single person can deliver the entire range of health care services to the people. The practice of modern public health service has become a joint effort of many groups of workers, both medical and non-medical, viz, physicians, nurse, social workers, public health engineers, sanitarians, and host of others. Hence, no any profession is island unto itself, medical doctors need pharmacist, microbiologist/laboratory scientist, nurses, labourer, as much as they need him, hence, community health practitioners, nutritionist need environmental health practitioners, as much as he also need them in his services.

Conclusion

Based on these, we can understand that, PHC, which is the centre point of health care in Nigeria, it is not a prerogative of anybody or profession, there should be a joint support for the programme to succeed, as such all the fighting on whom control PHC at local government is uncalled for and unfortunate.
The essence of any health services be it preventive, curative, promotive or rehabilitative is to ‘attain the goal of an acceptable level of health that will enable every individual to lead a socially and economically productive life’ [WHO 1981], hence, this should be the guide line, not personal interest.
Even though inter professional conflict could not be eliminated at all, nevertheless, CHP should understand they are not, and can not alpha and omega in PHC, they should regard each other as partner toward the upliftment of health services; their bias and hatred, enmity toward EHP should be stop, for if environmental health services would be given much attention by all the levels of government, the load on curative health services [which CHP are integral part of], would be reduced and in some instances, eliminated.
CHP should also know that, without environmental health control, no any progress of any health service can scale through, that is why due to the relegation of the later by PHC coordinators at LG level, whom are more of CHP, and medical practitioners at state and federal levels, policy makers inclusive, the progress achieved in the last 30 years of PHC programme is not satisfactory.
The open battle of NPHCDA to delist EHP and others from heading PHC departments in our local governments was unfortunate, bias and selfish. Instead of the organization to carry every profession along, they rather become partial and do injustice. It is even flabbergasting that a supposedly regulatory body is doing what is causing a great havoc towards the running of smooth PHC programme, which at last, those that the services is meant for, are the one affected.
NPHCDA should be alive to its responsibilities, by siding with truth and carrying everybody along, for it is not only the ones it likes that has something with PHC, all have roles to play. The issue of PHC is not only building PHC centre, provision of drugs and those that will man them, but each center, should at least have all the necessary professionals to make it fully operational.
What stated in this article notwithstanding, medical practitioners, CHP, EHP, Pharmacist, etc are all partners in the delivery of health services, as no one is an island unto himself; the inter fighting would only further deviate them from doing their works, which the people they supposedly work for are the ones affected. As such there should be understanding, collaboration and commitment, so that these intra fighting be eliminated.

Sani Garba writes from Karaye local government area, Kano state.

POLICY GUIDELINES ON MARKET AND ABATTOIR SANITATION

DEVELOPED BY
FEDERAL MINISTRY OF ENVIRONMENT
ABUJA
JULY 2005


PREFACE
The National Environmental Sanitation Policy aptly identified Market and Abattoir Sanitation as one of the key policy issues to address the enormous problems of Environmental Sanitation in Nigeria. Examples of overwhelming sanitation problems in markets and abattoirs include, but are not limited to, improper refuse disposal, inadequate water supply, and gross inadequacy of sanitary facilities that result in open defecation and urination, overcrowding and exposure of food and meat to flies, rodents and contaminants.
The identified reasons for these problems as highlighted in the National Environmental Sanitation Policy are improper planning of markets and abattoirs; the springing up of illegal markets and abattoirs (including slaughter slabs); lack of provision of adequate facilities such as potable water; inadequate road networks, institutional regulations, enforcement and monitoring; and above all, corrupt and sharp practices by the supervisors of markets and abattoirs.
It is in the light of these that the Policy Guidelines has been produced. It is presented in a comprehensive manner, taking into account concerns ranging from institutional roles, through strategies to be adopted and the sources of funding to address these issues. It must be clearly stated that attention was paid to the various responsibilities of all Stakeholders i.e. Government at all tiers, the Civil Society Organizations, market/ abattoir men and women, etc. The Policy Guidelines recognizes the significant role of the market/abattoir men and women in identifying and finding solutions to the various problems of markets and abattoirs.
It is also pertinent to note that the cross sectional linkages between this sector and others have been given thorough consideration so that the Policy Guidelines works in consonance with other sectors. Due cognizance has also been given to the cultural diversity and religious beliefs that play important role in our national life.
Above all, the Policy Guidelines seeks to promote and protect the health of all Nigerians by ensuring the highest standards of sanitation within and in the surroundings of all markets and abattoirs throughout the country, through the establishment and enforcement of adequate standards of sound sanitation in markets and abattoirs.

Col. Bala Mande (rtd.)
Honourable Minister of Environment
July 2004

1.0 INTRODUCTION
1.1 Markets occupy an important position in the lives of Nigerians particularly the women folk. Markets usually attract large gathering of buyers, sellers and especially pre-school children who have accompanied their mothers to markets. The coming together of buyers and sellers in markets provide opportunities for the spread of communicable diseases with considerable potential to reach epidemic dimensions.
1.2 Activities involved in buying and selling generate large quantities of solid waste. It is quite common to observe mountains of refuse at market places. The heaps of refuse provide excellent breeding grounds for vectors of communicable diseases including rodents, insects, etc. They may also pose fire hazards apart from being eyesores and sources of unpleasant odour. Very frequently, refuse is dumped in drainages or canals and along watercourses with impunity. All these have unpleasant environmental consequences.
1.3 Another common feature of markets in Nigeria is the gross inadequacy of sanitary facilities including potable water, toilets, and bathrooms, refuse disposal bays, etc. Open urination and defecation is widespread and the resultant contamination of the environment contributes to environmental degradation. Furthermore, poor supervision of markets by ill-trained, ill-equipped and corrupt officials have led to overcrowding, trading on access roads within and outside the markets – all adding to dangers that traders face. Blockade of access roads within the market and its surroundings, sometimes lead to unnecessary loss of lives and properties in event of emergency evacuation as is required during fire accidents.
1.4 There are two types of markets in Nigeria- Traditional and Modern. Both may hold daily or periodically on specific days. In terms of impact on the environment, markets in Nigeria may be classified as small, medium or large. Small markets usually serve local communities and may consist of just a few stalls. They are usually easy to keep clean at the end of the day’s transactions. Medium markets on the other hand serve a number of neighbouring communities while large markets are usually central, contain many stalls and promote inter-township trade. Adequate provision of sanitary facilities is required in medium and large markets.
1.5 Markets and abattoirs are built without proper layouts, and where such layouts exist, they have been distorted. Abattoirs share similar sanitary problems with markets. Lack of sanitary facilities such as adequate water supply, toilets, refuse disposal bays, incinerators and proper drainage, all increase the chances of contamination of meat meant for human consumption.

1.6 Transportation of meat from the abattoirs in passenger vehicles or motorcycles is a common practice in most towns and cities. It is also a common practice to see meat hawked on the streets. These practices expose the meat to contaminants such as dust, flies and other pathogens in the environment.
1.7 In most abattoirs, ante mortem (pre-slaughter) inspection of animal is rarely done. The abattoir workers usually lack necessary tools and equipment resulting in undue exposure to zoonotic infections
1.8 The proliferation of cooperative slaughter slabs and illegal slaughter houses pose serious dangers to the general public. In these places, there are usually no facilities for waste management and water supply. In addition, the slabs are frequently located within dwelling houses where the chances of contaminating domestic underground sources of water supply are high.
1.9 The cleanliness of abattoirs and slaughterhouses present one of the most difficult of all Public Health problems. The processes in the abattoir itself generate insanitary conditions; therefore, conscious efforts shall be made to maintain an adequate standard of hygiene. Problems associated with these premises and businesses are:
i. Keeping animals in confined space (Lairage).
ii. Ensuring provision and maintenance of adequate sanitary facilities.
iii. Sanitary transportation of meat and offal.
iv. Production, storage, and disposal or removal of offensive wastes.
1.10 These issues have been brought to the attention of Government through its various agencies over the years. Prior to the establishment of the Federal Ministry of Environment, the National Council on Health during its meeting in Jos in 1994 recommended that all States in the Federation should reintroduce market and abattoir sanitary inspection in all LGAs as a means of raising the level of Environmental Sanitation and promoting and protecting the health of all the citizens of this country. The call by the National Council on Health was further re-enforced by the National Council on Environment, which also recommended during its meeting in Kano in September, 2000 the re-introduction of market and abattoir inspection programme by Environmental Health Officers and Veterinary Officers in all LGAs. It is in line with these recommendations that these Policy Guidelines are being produced. The document, which, would be reviewed periodically, is to serve as a guide in the implementation of sound Market and Abattoir Sanitation.

2.0 AIM
The aim is to promote and protect the health of all Nigerians by ensuring the highest standards of sanitation within and in the surroundings of all markets and abattoirs throughout the country.
3.0 OBJECTIVES
3.1 To create, maintain and enforce adequate standards of sound sanitation in markets and abattoirs.
3.2 To ensure provision of adequate and sustainable sanitary facilities in and around markets and abattoirs.
3.3 To promote the use of sanitary facilities provided in markets and abattoirs
4.0 JUSTIFICATION
4.1 Buying and selling under insanitary conditions pose health hazards to the population.
4.2 Many markets and abattoirs in Nigeria lack sanitary conveniences including facilities for collection and disposal of solid wastes.
4.3 Failure of inspection and supervision of markets and abattoirs create grave public health concerns.
4.4 The institutionalization of routine inspection of markets and abattoirs will ensure the maintenance of adequate standards of sanitation and thus benefit the entire population by contributing to health promotion and disease prevention with added benefits for all other sectors of the economy.
4.5 The development of a sustainable Policy Guidelines is therefore, in the interest of the entire populace.

5.0 STRATEGIES
5.1 Develop Policy Guidelines for Market and Abattoir Sanitation that is feasible and sustainable within the context of Nigeria’s economic, social, cultural and political situation.
5.2 Produce and circulate the Policy Guidelines on Market and Abattoir Sanitation throughout the country to ensure implementation
5.3 Sensitize and mobilize Stakeholders to ensure commitment to, and compliance with the Policy Guidelines
5.4 Define minimum standards of sanitary facilities requirement in markets and abattoirs
5.5 Ensure that the sitting of new markets and abattoirs are subject to Environmental Impact Assessment (EIA) certification.
5.6 Recruit, train and retrain adequate numbers of Environmental Health Officers and Veterinary Practitioners to cover the entire country.
5.7 Conduct research into the various aspects of Market and Abattoir Sanitation.
6.0 INSTITUTIONAL ROLE
6.1 The Federal Ministry of Environment shall:
6.1.1 Develop and periodically review that National Policy Guidelines on Market and Abattoir Sanitation.
6.1.2 Build capacity of Environmental Health Officers at all levels for effective take-off of the programme.
6.1.3 Print and distribute necessary formats and forms for market and abattoir inspection for effective take off.
6.1.4 Coordinate and analyse inspection returns from States
6.1.5 Monitor and evaluate the implementation of the Policy Guidelines
6.2 The Federal Ministry of Agriculture shall:
6.2.1 Build capacity of Veterinary Practitioners at all levels for effective take-off of the programme.
6.2.2 Support the implementation of the Policy Guidelines

6.3 The State Government (Ministries of Environment and Agriculture as well as relevant Agencies) shall:
6.3.1 Support the implementation of the Policy Guidelines
6.3.2 Enact relevant State Legislation.
6.3.3 Train adequate manpower to implement the programme.
6.3.4 Develop and print IEC materials on Market and Abattoir Sanitation
6.3.5 Collate returns on Inspection Forms and forward quarterly report to the appropriate Federal Ministry
6.4 The Local Government shall:
6.4.1 Implement the Policy Guidelines on Market and Abattoir Sanitation
6.4.2 Enact enabling Legislation to support market and abattoir inspection.
6.4.3 Provide adequate sanitary facilities to ensure sound sanitation at markets and abattoirs
6.4.4 Recruit, train and retrain appropriate staff for programme implementation
6.4.5 Specify sanctions and fines for offenders.
6.4.6 Sensitise and mobilize communities on Market and Abattoir Sanitation
6.4.7 Print Inspection Forms
6.4.8 Ensure proper inspection of live animals at the lairage
6.4.9 Quarantine and treat diseased animals
6.4.10 Ensure proper disposal of terminally ill or dead animals
6.4.11 Ensure hygienic handling of meat products during transportation and sales to prevent exposure to contaminants.
6.4.12 Develop and print IEC materials on Market and Abattoir Sanitation
6.4.13 Forward monthly report to the appropriate State Ministry/Agency
7.0 FUNDING
7.1 The construction and management of markets and abattoirs shall be made sustainable and this shall be achieved in the following ways:
i. In cities where private sector participants are available, Government shall provide for them an enabling environment for the construction and management of markets and abattoirs
ii. In rural and semi-urban areas where private sector is not feasible, Government shall be involved in the construction of markets and abattoirs while the management is franchised.
iii. As much as possible, infrastructure and services to markets and abattoirs shall be made self sustaining.
iv. Public-private partnership shall be explored in securing needed funds for market and abattoir provision.

8.0 PROCEDURE FOR ROUTINE MARKET INSPECTION
8.1 Routine market inspection shall be scheduled and the opportunity used to educate the traders on market sanitation and hygiene during a general post-inspection debriefing. On visiting a market, the Environmental Health Officer shall introduce himself and present his identity card to the Chairperson(s) of the Market Association informing him/them about his mission. After the introduction, he shall request for at least two (2) representatives of the Association to accompany him for the inspection and also arrange for a general post-inspection debriefing meeting with all key members. The involvement of the representatives in the inspection process and the general debrief, shall promote the principles of involvement and participation.
8.2 Using the Market Sanitation Inspection Form, all deficiencies and hazards found in and around the market are noted. At the conclusion of the inspection, the findings shall be discussed with the representatives of the various traders groups (preferably during a general meeting called for the purpose) and they shall be allowed to suggest ways of abating or correcting the deficiencies identified. Copies of the inspection forms shall be deposited with the appropriate Market Association executives while the original inspection forms shall be filed in the LGA. The procedure for market inspection is systematic, beginning as follows:
8.3 EXTERNAL INSPECTION
8.3.1 GENERAL INSPECTION
The Inspection Team (Environmental Health Officer and Market Association Representatives) shall note the general cleanliness of the market surroundings and check for:
i. Obstruction of access roads as a result of street trading, abandoned vehicles or disused materials.
ii. Over-grown weeds, which may habour reptiles, rats and other vermin of public health importance.
iii. Tall trees which may be prejudicial to the health of the traders.
iv. Heaps of refuse which may harbour reptiles, rats and serve as breeding
ground for disease vectors.
v. Stagnant water and other water bearing plants or other receptacles
capable of breeding mosquitoes.
vi. Dangerous excavations within the market, including defective septic tanks.
vii. Blocked drainages capable of breeding mosquitoes and other disease vectors.
viii. Adequacy of fire fighting facilities.

ix. Adequacy of security facilities e.g. Police Post
8.3.2 WATER SUPPLY
Check for:
i. Source of water supply.
ii. Adequacy of water.
iii. Quality of water.
iv. Potential sources of contamination.
v. Adequacy of water containers.
vi. Evidence of leakages and backflow.
vii. Evidence of good drainage system.
8.3.3 TOILET ACCOMMODATION
Check for:
i. Adequacy for market population and sex composition.
ii. Evidence of crack on walls and floors.
iii. Adequacy of ventilation
iv. Adequacy of lighting
v. Evidence of rat runs and pest infestation
vi. Adequacy and functionality of drainage system
vii. Evidence of pipe leakage
viii. Cleanliness and presence of obnoxious odour
ix. Evidence of functionality
x. Adequacy of privacy
8.3.4 BATHROOM ACCOMMODATION
Check for:
i. Adequacy for market population and sex composition.
ii. Evidence of broken soil drainpipes
iii. Evidence of crack on walls and floors
iv. Adequacy of ventilation
v. Adequacy of lighting
vi. Adequacy and functionality of drainage system
vii. Adequacy of privacy
8.3.5 REFUSE DISPOSAL
Check for:
i. Adequacy of refuse bays
ii. Evidence that refuse bays are well kept and refuse is collected regularly.
iii. Evidence of rat and pest infestation around bays.
iv. Evidence of waste spillage.
v. Evidence of drain blocked by refuse

8.3.6 EXCRETA DISPOSAL
Check for:
i. Evidence of pipe leakage and back flow
ii. Evidence of overfilled tanks leading to spillage
iii. Evidence of crack on septic tank and VIPL
iv. Presence of ventilating pipes/opening
v. Distance to source of drinking water
vi. State of on-site sewage treatment plant (if available)
8.4 INTERNAL INSPECTION
8.4.1 THE FLOOR
Check for:
i. Cleanliness of the floor and look out for broken or cracked floors.
ii. Evidence of rat infestation (rat holes, runs and droppings).
iii. Evidence of dampness.
8.4.2 WALLS
Check for:
i Dilapidated walls.
ii. Cracks liable to harbour vermin
iii. Evidence of dampness on the walls
8.4.3 ROOF AND CEILING
Check for:
i. Evidence of roof leakage
ii. Cleanliness and presence of cobwebs.
iii. Sagging of the ceiling.
8.4.4 PASSAGES AND STAIRWAYS
Check for:
i. Objects (including display of wares) that are likely to obstruct free movement along passages and stairways.
ii. Adequacy of passages and stairways for emergency evacuation.
iii. Adequate lighting of stairways and passages
iv. Adequacy of the width of stairways and state of repair of handrails (Stairways shall have a width greater than 1.5 meters and be provided with handrails on both sides)
v. State of repair of stairway steps.

8.4.5 STALLS
Check for:
i. Evidence of overcrowding.
ii. Adequacy of lighting
iii. Adequacy of ventilation (Look for objects kept in such a manner as to obstruct the free flow of fresh air)
iv. Availability of dustbin with lid.
v. Evidence of pest and vector infestation.
8.4.6 FOOD PREMISES (BUKATERIAS)
Check for:
i. Compliance with set standards on Food Premises
ii. Cleanliness of the general environment
iii. Evidence of overcrowding.
iv. Adequacy of ventilation.
v. Evidence of rat and pest infestation.
vi. Adequacy of lighting.
vii. Evidence of cracked walls and defective floors.
viii. Evidence of smoke nuisance.
ix. Evidence of hanging cobwebs.
x. Evidence of hand washing facilities.
8.4.7 HEALTH POST OR FIRST AID ROOM
Check for:
i. Availability of a room for care of ill or injured people.
ii. Availability of trained personnel responsible for and administering first Aid.
iii. Availability of first aid supplies.
iv. Appropriate location of toilet and sink/wash hand basin in the room.
8.4.8 FIRE CONTROL POST
Check for:
i. Adequate and functional fire extinguishing equipment/facilities
ii. Adequacy of fire control personnel

FORM E.S.9
FEDERAL REPUBLIC OF NIGERIA
MARKET INSPECTION FORM
State................................................................
Local Government Area……………………………………………………………………..
District................................ Ward...........................................................................
Town...................................... Village ………………………………Street ……………………………
Name of Market ..................................................................................
Name of Chairpersons (i) ..................................................Tel…………..................................
(ii).....................................................Tel………………………....................
Names of Persons accompanying the inspector (i) ..................................................................
(ii) ................................................................
Instructions for completing the market sanitation inspection form:
For section A-B,
i. For each item assessed tick:
A- If the item is adequate
B- If the item needs minor corrective action
C- If the item needs major corrective action
ii. If B or C is ticked, indicate corrective action required by completing the column on remarks
For section C, Provide a brief summary of inspection, highlighting significant findings and recommendations.
Section A: General Inspection
Item
DESCRIPTION
A
B
C
REMARKS
1 State of access routes
2 Surroundings well kept
3 Presence of tall trees
4 Heaps of refuse observed
5 Stagnant water
6 Dangerous excavations including defective septic tanks.
7 State of drainages
8 Fire fighting facilities
9 Security arrangements
10 Water supply
11 Toilets
12Bathrooms
14 Refuse disposal Bays
15 Excreta disposal methods
16 Rat, pest and vector infestation

Section B: Internal Inspection:
Item
DESCRIPTION
A
B
C
REMARKS
1 Floor
2 Wall
3 Roof and Ceiling
4 Passages and Stairways
5 Stalls
6 Food Premises
7 Ventilation
8 Health Post
9 Lighting
10 Sanitary Dust bins
Rat, pest and vector infestation
12 General cleanliness and tidiness

Section C: Summary of Findings and Recommendations
..........................................................................................................................................................
..........................................................................................................................................................
..........................................................................................................................................................
..........................................................................................................................................................
..........................................................................................................................................................
..........................................................................................................................................................
.................................................................................................
Signature of Environmental Health Officer and Date
...............................................................................................
(i) Signature of Representative and Date
..............................................................................................
(ii) Signature of Representative and Date

9.0 PROCEDURE FOR ROUTINE INSPECTION OF ABATTOIR AND SLAUGHTERHOUSES
9.1 DEFINITION:
9.1.1 An abattoir or slaughterhouse can simply be defined as a place where animals are killed in a sanitary condition to ensure its safety and wholesomeness for human consumption. In Nigeria, slaughterhouses are small private businesses while abattoirs are bigger, serve communities of appreciable population size and usually owned by Government.
9.1.2 The lairage is an accommodation separate from the abattoir/slaughterhouse. The animal is usually kept in a lairage for a minimum of twelve (12) hours for the single important purpose of ante mortem examination before it is taken to the abattoir for slaughtering.
9.1.3 A healthy animal is one which has a glossy coat with no injury marks on the body, moist nostril, clear eyes and alert. The animal shall have a body temperature range of 37.2 – 37.8 degree Celsius.
9.1.4 A sick animal is one which looks distressed with head hanging down, inability to stand on all four legs, watery and droopy eyes. The animal may emit an offensive odour and refuse food.
9.2. APPRAISAL INSPECTION:
For abattoirs and slaughterhouses to function hygienically, attention must be paid to the following:
9.2.1 LAIRAGE:
i. The lairage shall have sufficient space such as to allow diseased animals or those suspected of being diseased to be kept away from the healthy ones.
9.2.2 ACCOMMODATION:
i. Every premises housing an abattoir/slaughterhouse shall have:
Suitable and sufficient space for the slaughtering of animals.
ii. Suitable and sufficient space for the hanging of meat so as to allow air to circulate freely at all times between carcasses.
iii. Suitable and sufficient space apart from the slaughter hall and hanging space for emptying and cleaning of stomachs and intestines.
iv. Suitable and sufficient facilities for the isolation of meat requiring further examination by a meat inspector.

v. Suitable and sufficient disposal facilities for the retention of all meat rejected as being unfit for human consumption.
vi. Suitable cloak and wash rooms for butchers and allied staff.
9.2.3 LAYOUT:
The abattoir/slaughterhouse shall be laid out in such a manner as to:
i. Provide adequate space and facilities for the efficient performance of meat inspection;
ii. Permit the functioning of all operations under hygienic conditions;
iii. Paint white all surfaces and maintain same, to inculcate the culture of cleanliness
9.2.4 LIGHTING AND VENTILATION:
Every abattoir/slaughterhouse shall:
i. Where reasonably practicable, be so constructed that meat inspection may be carried out by daylight.
ii. Be provided with well-distributed artificial light of adequate intensity.
iii. Have suitable and sufficient means of ventilation to the external air.
9.2.5 CLEANING AND REPAIR:
i. The rooms for the preparation and storage of meat shall be constructed to
prevent any risk of contamination or access by birds and other animals.
9.2.6 WALLS:
i. The interior wall surfaces of all workrooms, hanging rooms, slaughter hall or any other room where meat is kept shall be faced with smooth hard impervious material to a height of not less than 2 meters from the floor.
ii. In instances where carcasses might come in contact with the wall, the facing shall be continued up to such higher level from the floor.
9.2.7 CEILING
i. The interior surfaces of ceilings and, where there are no ceilings, the interior surfaces of all roofs shall be so constructed and finished in such a way as to minimise condensation, mould development, flaking and lodgment of dirt.
9.2.8 FLOORS:
i. All floors in lairages, slaughter halls, workrooms, hanging rooms and any rooms for the retention of meat condemned as unfit for human consumption shall be of impervious, non-slip material, constructed as to enable them to be thoroughly cleaned.

ii. The floor in slaughter halls and workrooms shall be laid to have a gradient of no less than five centimeters for every three meters to ensure the flow of waste water by gravity.
9.2.9 CONTAINMENT
i. Every slaughterhouse shall be so constructed and maintained as to prevent the deposit, flow or seepage of solids or liquids to adjacent premises.
9.2.10 DRAINAGE:
i. Satisfactory drainages with traps for solids and oil/fat shall be maintained in proper working order.
9.2.11 WATER SUPPLY:
i. Adequate quantity of water shall be available at all times at sufficient pressure throughout the premises.
9.2.12 TOILETS:
i. Adequate number of toilets with suitable flushing appliances for both sexes shall be provided.
ii. The toilets shall not communicate directly with the slaughter hall or any workrooms.
9.2.13 HAND WASHING FACILITIES:
i. Adequate number of facilities for washing hands (including adequate supply of running water and soap, as well as nail brushes), shall be provided in places readily accessible to slaughter hall, workroom and toilets.
9.2.14 BATHROOMS:
i. Adequate number of bathrooms for both sexes shall be provided for workers
9.2.15 EQUIPMENT:
i. The equipment and fittings in slaughter halls and workrooms shall be of such material and of such construction as to enable them to be kept clean.
9.2.16 STERILIZERS:
i. There shall be installed in abattoirs/slaughterhouses suitable and sufficient facilities for sterilizing clothes, knives and other equipment used.
9.2.17 REFUSE DISPOSAL:

i. Suitable and sufficient receptacles furnished with closely fitting lid shall be provided for collection and removal of slaughterhouse garbage, filth and refuse.
ii. If such materials are insufficient, a manure bay with impervious walls and floor and drained to a suitable outlet may be provided and maintained.
9.2.18 FIRST AID MATERIALS:
i. Suitable and sufficient bandages, dressings, including waterproof dressings, and antiseptic for first aid treatment shall be provided and maintained within the premises.
9.2.19 WASTE TREATMENT:
i. To facilitate waste minimization and disposal, on-site facility for treatment
of abattoir/slaughterhouse wastes such as digesters shall be installed.
9.3 ROUTINE INSPECTION
9.3.1 Routine abattoir/slaughterhouse inspection shall be scheduled and the opportunity used to educate the workers on sound sanitation and hygiene practices during a general post-inspection debriefing. On visiting an abattoir/slaughterhouse, the Environmental Health Officer shall introduce himself and present his identity card to the Chairman of the Butchers informing him about his mission. After the introduction, he shall request for two (2) representatives of the butchers to accompany him for the inspection and also arrange for a general post-inspection debriefing meeting with all the key union leaders. The involvement of the representatives in inspection and the general debrief are to promote the principles of involvement and participation.
9.3.2 Using the Abattoir/Slaughterhouse Sanitation Inspection Form, all deficiencies and hazards found are noted and recorded. At the conclusion of the inspection, the findings shall be discussed with the butchers (preferably during a general meeting called for the purpose). They shall be allowed to suggest ways of abating or correcting the deficiencies identified. Copies of the inspection form shall be deposited with the Chairman while the original inspection form shall be filed in the LGA.

9.3.3 GENERAL INSPECTION
9.3.3.1The procedure for inspection is systematic. The Inspection Team (Environmental Health Officer and the Representatives) shall note the general cleanliness of the abattoir/slaughterhouse and in particular, the following:
i. Over-grown weeds, which may habour reptiles, rats and other vermin of public health importance.
ii. Heaps of refuse which may harbour reptiles, rats and serve as breeding ground for other disease vectors.
iii. Stagnant water and other water bearing plants or other receptacles capable of breeding mosquitoes.
iv. Dangerous excavations within the market, including defective septic tanks.
v. Blocked drainages capable of breeding mosquitoes and other disease vectors.
9.3.3.2LAYOUT
Check for:
i. Orderliness of work processes to assure efficient performance of meat inspection and the conduct of all other operations under hygienic conditions.
ii. Cleanliness of the white paint on all surfaces.
9.3.3.3LAIRAGE
Check for:
i. The separation of healthy and diseased animals.
ii. Evidence that animal wastes are cleared from site twice weekly.
iii. Evidence that fresh soil is applied to site at least every six (6) months.
9.3.3.4ACCOMMODATION
Check for:
i. Cleanliness of slaughter hall and all work rooms.
ii. Cleanliness of area where the meat is hung.
iii. Cleanliness and tidiness of cloakroom
9.3.3.5 LIGHTING AND VENTILATION
Check for:
i. Adequacy of lighting in work area
ii. Adequacy of ventilation in work area

9.3.3.6 CLEANING AND REPAIR
Check for:
i. Evidence of pest infestation and entry routes of birds and other animals.
9.3.3.7 WALLS
Check for:
i. Cleanliness
ii. Dilapidation
iii. Cracks liable to harbour vermin
iv. Evidence of dampness
9.3.3.8 CEILING
Check for:
i. Evidence of condensation.
ii. Evidence of leakage.
iii. Evidence of flaking, blight, lodgment of dirt, hanging cobwebs, etc.
9.3.3.9 FLOORS
Check for:
i. Evidence of daily washing (Floor shall be washed at the end of each day’s business).
ii. Cleanliness of the floor and look out for broken or cracked floor.
iii. Evidence of rat infestation (rat holes, runs and droppings).
iv. Evidence of dampness.
9.3.3.10 CONTAINMENT
Check for:
i. Adequate containment of slaughterhouse refuse, sewage etc.
9.3.3.11 DRAINAGE
Check for:
i. Adequacy and function.
9.3.3.12 WATER SUPPLY
Check for:
i. Source of water supply.
ii. Adequacy of water.
iii. Quality of water.
iv. Potential sources of contamination.
v. Adequacy of water containers.
vi. Possible leakages.

9.3.3.13TOILET ACCOMMODATION
Check for:
i. Cleanliness
ii. Evidence of crack on walls and floors.
iii. Evidence of pest infestation
iv. Evidence of obnoxious odour
v. Evidence of leakage pipe
vi. Evidence of functionality.
9.3.3.14 HANDWASHING FACILITIES
Check for:
i. Adequacy of water supply.
ii. Availability of soap and brushes.
9.3.3.15 BATHROOMS
Check for:
i. Evidence of broken soil drain pipes.
ii. Evidence of broken floor or wall.
iii. Adequacy of the drainage system.
9.3.3.16 EQUIPMENT AND FITTINGS
Check for:
i. Cleanliness of sterilizers and other equipment
ii. Evidence of pipe leakages and backflow
9.3.3.17 REFUSE DISPOSAL
Check for:
i. Suitability and adequacy of waste bins.
ii. Adequacy of refuse bays and regularity of refuse collection.
iii. Evidence of rat and pest infestation at refuse bays.
iv. Evidence of waste spillage.
v. Evidence that receptacles for animal dung are emptied regularly and do not constitute a nuisance.
9.3.3.18 EXCRETA DISPOSAL:
Check for:
i. Evidence of pipe leakage and back flow
ii. Overfilled tanks leading to spillage
iii. Evidence of crack on septic tank and VIPL
vi. Presence of ventilating pipes/opening
vii. Distance to source of water
viii. State of on-site sewage treatment plant (if available)

9.3.3.19 FIRST AID
Check for:
i. Availability and adequacy of first aid supplies.
9.3.3.20 ON-SITE WASTE TREATMENT
Check for:
i. Availability and functionality of on-site waste treatment.
10.0 PERSONAL HYGIENE
10.1 A sick person shall report his/her ill health to the Medical Officer of Health for appropriate treatment.
10.2 A sick person shall not enter the abattoir/slaughterhouse until confirmed by a medical doctor that he/she is free from the illness and any other communicable/ infectious disease.
10.3 All minor cuts and injuries shall be properly covered with good water proof dressing.
10.4 All persons shall wear overalls or any other recommended protective clothing including head-cover and boots. All materials shall be washable and kept reasonably clean at all times.
10.5 All persons shall maintain good personal hygiene, viz: washing of any part of the body that comes in contact with meat, washing of contact materials including overalls.
10.6 No tobacco chewing/smoking or cigarette smoking or eating shall be allowed in all work rooms.
10.7 No spitting, picking or blowing of the nose shall be allowed in all work rooms.
10.8 All knives, cutlasses shall be washed in hot water immediately after use or sterilized in steam.

11.0 RELIGION AND BELIEF
Regards must be given to local, tribal, religious and cultural beliefs in the slaughtering of animals.
MINIMUM REQUIRED STANDARD FOR MARKETS AND ABATTOIRS
Water Supply
Toilet Facility
Solid Waste Management
Effluent Treatment Facility
Market
 1 Standpipe: 200 persons
 Potable source
 Regular supply
 1: 25 persons
 Functional
 Clean
 Every stall to have waste bins.
 All refuse to be carted away by PSP or others regularly
N/A
Abattoir
500 Litres per cow
 1: 25 persons
 Functional
 Clean
 Incinerator (for carcasses)
 Protected temporary storage bins.
 Arrangement for prompt removal.
 Oxidation Pond
 Percolating Filter
 Activated sludge.

FORM E. S. 10
FEDERAL REPUBLIC OF NIGERIA
ABATTOIR INSPECTION FORM
State.................................... Local Government Area…………………………………………
District................................ Ward...........................................................................
Town...................................... Village …………………………………………. Street………………………………………
Name and address of Abattoir/Slaughterhouse..................................................................................
Name of Chairpersons (i) ......................................................................
And contact telephone
Numbers
(ii) ........................................................................
Names of Persons accompanying the inspector (i) ......................................................
(ii) .....................................................
Instructions for completing the Abattoir/Slaughterhouse inspection form:
For section A-C,
ii. For each item assessed tick:
A- If the item is adequate
B- If the item needs minor corrective action
C- If the item needs major corrective action
ii. If B or C is ticked, indicate corrective action required by completing the column on remarks
For section D, Provide a brief summary of inspection, highlighting significant findings and recommendations.
Section A: General Inspection
Item
DESCRIPTION
A
B
C
REMARKS
1 State of access routes
2 Surroundings well kept
3 Heaps of refuse observed
4 Stagnant water
5 Dangerous excavations including defective septic tanks.
6 State of drainages

Section B: Internal Inspection:
Item
DESCRIPTION
A
B
C
REMARKS
1 Layout-Adequacy of space and facilities
2 Lairage- Separate accommodation provided for healthy and sick animals
3 Accommodation
4 Lighting and ventilation
5 Cleaning and repair
6 Wall
7 Roof and Ceiling
8 Floors
9 Containment of sewage, refuse, etc
10 Drainages
11 Water
12 Toilets
13 Hand washing facilities
14 Bathroom accommodation
15 Equipment and fittings
16 Excreta disposal
17 First Aid Post
18 On site Waste Treatment
19 Others – (Pls. specify)

Section D: Summary of Findings and Recommendations
..........................................................................................................................................................
..........................................................................................................................................................
..........................................................................................................................................................
..........................................................................................................................................................
..........................................................................................................................................................
..........................................................................................................................................................
.......................................................................................
Signature of Environmental Health Officer and Date
....................................................................................
(i) Signature of Representative and Date
...................................................................................
(ii) Signature of Representative and Date

FORM E.S. 11G
FEDERAL REPUBLIC OF NIGERIA
INSPECTION OF PRIVATE SLAUGHTERHOUSE
State.................................... Local Government Area…………………………………………
District................................ Ward...........................................................................
Town...................................... Street……………………………………………………………………
TO ……………………………………………………….
………………………………………………………………………..
Following your application for renewal of license to operate a private slaughterhouse and the subsequent inspection of your premises and facilities the following observations were made:-
Slaughter slab: Satisfactory
Personal Hygiene: Satisfactory
Water supply: Adequate
Disposal Facilities for
(blood, offal, dirt, rubbish, etc) Appropriate
Your operational permit ref. No……………………….…issued on the ……… of ……………………20……..
to operate a private slaughterhouse is therefore renewed/extended for the rest of
the year.
Dated this ……………………. day of ……………………….20……… at………………………………………………
……………..……………………………………………….. ……………………………………………………
Chief Environmental Health Officer Head of Department

FORM E.S. 11R
FEDERAL REPUBLIC OF NIGERIA
INSPECTION OF PRIVATE SLAUGHTERHOUSE
State.................................... Local Government Area…………………………………………
District................................ Ward...........................................................................
Town...................................... Village …………………………………………………. Street………………………………
TO ……………………………………………………….
………………………………………………………………………..
Following your application for renewal of license to operate a private slaughterhouse and the subsequent inspection of your premises and facilities the following observations were made:-
Slaughter slab: Satisfactory
Personal Hygiene: Satisfactory
Water supply: Adequate
Disposal Facilities for
(blood, offal, dirt, rubbish, etc) Appropriate
Your operational permit ref. No……………………….…issued on the ……… of ……………………20……..
to operate a private slaughterhouse is therefore cancelled for the rest of the year.
Please note that your continued operation shall amount to a violation of the law. You may however take actions specified in the attached report and invite my office for another inspection.
Dated this ……………………. day of ……………………….20……… at………………………………………………
……………..……………………………………………….. ………………………………………………
Chief Environmental Health Officer Head of Department

FORM E.S. 12
FEDERAL REPUBLIC OF NIGERIA
CERTIFICATE OF REGISTRATION OF FOOD PREMISES
State.................................... Local Government Area…………………………………………
District................................ Ward...........................................................................
Town...................................... Street……………………………………………………………………
1. Name of Proprietor / Occupier / Manager …………………………………………………………...
2. Address of Premises ……………………………………………………………………………………………………..
3. Purpose of Registration: …………………………………………………………………………………………………
……………………………………………………………………………………….
4. The registration license is valid until the 31st day of December of the year of issue. However this license is subject to renewal/revocation at the discretion of the issuing authority
Fee Paid ……………………………………………….
Date ……………………………………………………
……………………………………………………………………..
Chief Environmental Health Officer
…………………………………………………………………….
Head of Department

POLICY GUIDELINES ON EXCRETA AND SEWAGE MANAGEMENT 2005

DEVELOPED BY
FEDERAL MINISTRY OF ENVIRONMENT
ABUJA
JULY 2005

PREFACE
Insanitary methods of Excreta and Sewage Management (collection, treatment, disposal and after disposal care) by majority of the population had exacerbated problems of the spread of faeco-orally transmitted and other sanitation related diseases. Government’s efforts at addressing poor Excreta and Sewage Management have been piece-meal and uncoordinated with poor regulatory measures. This situation has spanned over a century from pre-independence period to the present time.
The 1986 National Policy on Health recognises insanitary excreta and sewage disposal as a cause of environmentally induced health problems while the 1989 National Policy on Environment seeks the improvement of environmental health services and conditions relating to water supply, sewage, excreta etc. Nonetheless, the lack of a specific National Policy on Environmental Sanitation and in particular Policy Guidelines on Excreta and Sewage Management, has been a major gap and significant constraint towards efficient service delivery in this critical sector.
Within the framework of the National Environmental Sanitation Policy, the present Policy Guidelines has been developed with appropriate strategies to “roll back” the poor sanitation problems and preventable diseases attributable to poor Excreta and Sewage Management. The purpose of this Policy Guidelines is therefore, to ensure countrywide access to efficient and sustainable sanitary Excreta and Sewage Management methods and obviate associated public health hazards.
In this regard, the Policy Guidelines have taken cognisance of Excreta Sewage Management Options, Collection Equipment, Private Sector participation as well as, Enforcement Mechanisms and Sanctions. This Policy Guidelines is therefore critical in the implementation of appropriate programmes on the Excreta and Sewage Management component of the National Environmental Sanitation Action Plan.
Col Bala Mande (rtd)
Honourable Minister of Environment
July 2004


1.0 INTRODUCTION
1.1 Human faeces frequently contain a wide range of disease-causing organisms including viruses, bacteria, and eggs or larvae of human parasites. Many of these organisms are transmissible to people through houseflies, contaminated hands, food, water, eating and cooking utensils, and by direct contact with contaminated objects. Infections such as diarrhoea, cholera, typhoid, etc. that account for significant morbidity and mortality in developing countries such as ours, are spread in this way. Some others, for example, hookworm and whip worm are transmitted through contact with soil contaminated with faeces and may spread very rapidly where open defaecation is common and people walk barefoot. Hookworm and whipworm contribute significantly to the occurrence of malnutrition and anaemia and thereby render people more susceptible to other diseases. In areas where intestinal schistosomiasis is endemic, contamination of water bodies by human feaces is the main route of spread of this disease.
1.2 Although urine is relatively harmless, in areas where urinary schistosomiasis is endemic, transmission of this disease is through contamination of fresh water bodies with urine of infected persons. Incidentally, urinary schistosomiasis is endemic in many communities in Nigeria.
1.3 Access to basic sanitary facilities is particularly poor. It has been observed that, in urban centres, some households with water carriage system, pipe the raw sewage into the public drains. According to the 1999 Nigeria Demographic and Health Survey (NDHS), 12% of the urban population has no toilet facilities of any kind whilst, 55% use pit latrines and 31% use flush toilets. Rural areas are even less served. The 1999 NDHS also indicated that about one third of rural households have no toilet facilities at all and as a result make use of bushes and rivers. Open defecation is a common practice in the rural areas. In the periurban centres, children as well as adults defaecate indiscriminately at dumpsites, gutters or any available open space in the late hours of the night and early hours of the morning.
1.4 These figures are especially sobering as they imply that a large number of people urinate and defaecate in open spaces, with serious health implications in densely populated urban and periurban settlements.
1.5 This Policy Guidelines provides general guidance to ensure that every family has access to a suitable sanitary method of excreta/sewage management.

Nonetheless, what is considered suitable will vary markedly depending more on the location and to a lesser extent on the socio-economic status of families.
2.0 AIM
To ensure countrywide access to efficient and sustainable Excreta and Sewage Management methods and obviate associated public health hazards.
3.0 OBJECTIVES
3.1 To create awareness on the effects of insanitary Excreta and Sewage Management on the quality of the environment and public health.
3.2 To promote the adoption, construction, use and maintenance of culturally acceptable sanitary Excreta and Sewage Management systems.
3.3 To ensure safe and nuisance-free management of excreta and sewage during collection, transportation, treatment and final disposal, in a manner that protects public health.
3.4 To promote environmental aesthetics.
3.5 To prevent the contamination of environmental media (soil, water, food, etc.).
3.6 To promote the adaptation of the by-products of sewage treatment to productive purposes.
4.0 JUSTIFICATION
4.1 In Nigeria, it is not uncommon to see people urinate and defecate in open spaces and into public drains with impunity. Such actions contribute to environmental degradation and pollution.
4.2 Insanitary Excreta and Sewage Management as well as deficiencies in other components of Environmental Sanitation, contribute significantly to the continuing high rate of infant and child mortality from diarrhoeal diseases and also play a major role in vector borne diseases.
4.3 Ensuring countrywide access to sanitary Excreta and Sewage Management methods will result in a lowered incidence of Environmental Sanitation related diseases and free precious funds used in health care costs for other developmental activities.

5.0 STRATEGIES
5.1 Develop Policy Guidelines for sustainable Excreta and Sewage Management in line with National Development Objectives.
5.2 Promote countrywide adoption of the Policy Guidelines on Excreta and Sewage Management.
5.3 Undertake research, develop and promote culturally acceptable and affordable Excreta and Sewage Management technology options
5.4 Facilitate the construction and maintenance of adequate sanitary facilities in public places including the high ways.
5.5 Establish mechanisms for sanctioning insanitary management of excreta and
sewage.
5.6 Promote Stakeholders participation in Excreta and Sewage Management.
5.7 Foster and promote private sector participation in the maintenance and operation of Excreta and Sewage Management facilities and services.
6.0 INSTITUTIONAL ROLES
6.1 The Federal Government shall:
6.1.1 Develop, periodically review and update the Policy Guidelines on Excreta and Sewage Management.
6.1.2 Source for funds for programme development, specialized studies and capacity building on Excreta and Sewage Management.
6.1.3 Support research into culturally acceptable and affordable Excreta and Sewage Management technologies.
6.1.4 Build capacity of, and provide technical support for, States and LGAs in effective Excreta and Sewage Management.
6.1.5 Encourage incentives for compliance with the provisions of the Policy Guidelines.
6.1.6 Support sensitization and awareness programmes.

6.2 The State Governments shall:
6.2.1 Ensure the implementation of the Policy Guidelines on Excreta and Sewage Management.
6.2.2 Provide technical support to the LGAs through training and manpower development programmes for capacity building and institutional strengthening.
6.2.3 Support the provision of logistics including financial instruments to facilitate private sector participation.
6.2.4 Review and update relevant State legislations to create enabling environment for effective private sector participation in Excreta and Sewage Management.
6.2.5 Conduct public education and enlightenment on Excreta and Sewage Management.
6.2.6 Encourage private sector participation in Excreta and Sewage Management.
6.2.7 Provide adequate and functional sewage dislodgement facilities.
6.3 The Local Governments shall:
6.3.1 Collaborate with all Stakeholders in the provision of sanitary Excreta and Sewage Management.
6.3.2 Enact Bye-laws and establish sanctions and enforcement mechanisms.
6.3.3 Define and enforce appropriate standards for Excreta and Sewage Management.
6.3.4 Sensitize and mobilize the community members for effective participation in the programme.
6.3.5 Undertake routine inspection and regular monitoring of facilities
6.3.6 Build capacity of community artisans in the construction of culturally acceptable and affordable excreta management facilities.
6.3.7 Ensure provision of hygienic sanitary conveniences at large public assemblies and this shall be mandatory as a prerequisite for granting approval
6.4 The Private Sector shall:
6.4.1 Comply with the provisions of the National Policy Guidelines on Excreta and Sewage Management.

6.4.2 Participate effectively in Excreta and Sewage Management on cost recovery basis.
6.4.3 Design appropriate cost effective and affordable technology for improved service delivery.
6.4.4 Engage in partnership with LGA for better service delivery.
6.4.5 Support research into Excreta and Sewage Management.
6.4.6 Promote public enlightenment campaign.
6.5 Civil Society Organizations shall:
6.5.1 Undertake grassroots mobilization to support appropriate sanitary Excreta and Sewage Management systems.
6.5.2 Promote the adoption, construction, use and maintenance of culturally acceptable sanitary Excreta and Sewage Management systems.
6.5.3 Promote public enlightenment campaigns on appropriate strategies for excreta and sewage collection, transportation, treatment and disposal.
6.6 The Public shall:
6.6.1 Comply with the provisions of the National Policy Guidelines.
6.6.2 Adopt environment friendly habits and practices.
6.6.3 Pay requisite fees for services.
6.6.4 Cooperate with other Stakeholders to ensure a sustainable Excreta and
Sewage Management systems.
7.0 GUIDELINES FOR EFFICIENT EXCRETA AND SEWAGE MANAGEMENT SERVICE DELIVERY AT THE LOCAL GOVERNMENT LEVEL
The strategies adopted for Excreta and Sewage Management at Local Government level shall relate to the culture, land use types, economic base, climatic conditions, level of urbanization and the existing institutional arrangement. Nevertheless, the following guidelines are provided as a broad statement to make for strategic intervention in Excreta and Sewage Management at the LGA.
7.1 EXCRETA DISPOSAL
7.1.1 Every house shall have suitable and adequate numbers of sanitary latrines/toilets. This shall be built of hygienic easy to clean materials, accessible and designed to minimize the proliferation/harbourage of disease vectors.

7.1.2 The latrine/toilet shall provide adequate privacy for users.
7.1.3 The latrine/toilet shall be located to avoid potential contamination of water sources and surface soil.
7.1.4 There shall be no handling of fresh feaces.
7.1.5 The following minimum number of latrines/toilets to the number of persons indicated below shall be accepted as ideal:-
1 - 10 persons 1 toilet
11 - 20 persons 2 toilets
21 - 40 persons 3 toilets
50 - 75 persons 4 toilets
75 - 100 persons 5 toilets
Over 100 persons, one toilet to every additional 30 persons.
7.2 EXCRETA MANAGEMENT
The Local Government shall:
7.2.1 Classify all settlements according to their level of urbanization, size, function and economic base into urban, semi-urban and rural.
7.2.2 Review existing methods of Excreta and Sewage Management. Where existing methods are sanitary and acceptable, they shall be promoted. Where the methods are insanitary or inappropriate, the LGA shall enforce the provision and use of acceptable methods by house owners.
7.2.3 In general, States and LGAs shall promote methods that take into account differences in residential districts as indicated in the table below:
Residential Area
Collection Method
Rural - sparsely populated areas
Ventilated Improved pit latrines (VIPs)
Well laid out modern cities with Central Sewage System
Connect to the Central Sewage System
All other areas*
Water Closet with septic tank and soak away pit, Aqua Privy, Pour-flush and Decentralized Sewage System where applicable
*Cognizance has been taken of the peculiar problems of riverine communities where excreta is disposed in water bodies. While it is intended that specific guidelines to address this issue will be provided in future review of this Policy Guidelines; to ensure privacy and human dignity, affected communities shall provide appropriate structures at designated areas for defecation purposes.

7.2.4 Set up an efficient system for detecting and abating nuisance, sanctioning defaulters and enforcing the law through Sanitary Inspection of Premises.
7.2.5 Monitor, evaluate and re-plan management strategies at regular intervals
7.3 COLLECTION EQUIPMENT
The emptying of septic tanks by local authorities or private operators shall be carried out with appropriate equipment that conforms with the provisions in the National Policy Guidelines on Sanitation Equipment.
7.4 SEWAGE/SLUDGE MANAGEMENT
7.4.1 Every State/LGA shall, as a matter of urgency, discourage the indiscriminate dumping of sewage sludge on land and in water bodies. Therefore, the private sector shall be encouraged to undertake the construction, privatisation and commercialisation of sewage treatment plants at every LGA for use by all companies involved in sewage management.
7.4.2 Recycling of sludge arising from sewage treatment shall be encouraged as much as possible.
7.4.3 For cottage industries, provision shall be made for onsite management of sewage sludge in an environmentally sound manner.
7.4.4 The Environmental Sanitation Authorities of the LGA shall inspect and license all dislodging vehicles operating in the LGA. Such a license shall be renewed annually.
7.4.5 Environmental Sanitation Authorities in collaboration with other relevant agencies shall designate areas where sewage sludge and other matter dislodged by these vehicles shall be emptied.
7.4.6 It shall be illegal to empty sludge in any area not designated for such a purpose and any dislodger who fails to use such a facility shall be prosecuted and appropriate sanctions imposed.
7.5 EXCRETA AND SEWAGE/SLUDGE MANAGEMENT OPTIONS
7.5.1 Three (3) management options are recommended:
i. By Local Government/ Municipal Authorities;
Direct operations of sewage management by Local Government/Municipal Agencies may be embarked upon where the private initiative is low. This practice is often bedeviled with frequent personnel turnover and the use of

incompetent or untrained officials. Although money may be saved, it may be at the expense of satisfactory performance.
ii. By Private Companies on contract with Municipality;
Contracting out sewage management to private contractors by Local Government/Municipal Agencies has its advantages. First, sewage treatment is conducted as a business venture without political considerations. Similarly, the burden of expenditure for equipment and capital outlay is placed on private companies whose management is often effective. However, it is often counter-productive, as profit is the object of service. This problem can be overcome by effective monitoring and sanctioning system by the LGA, to ensure compliance with standards.
iii. Private Companies on contract with Home Owners.
8.0 PRIVATE SECTOR PARTICIPATION
Private sector participation shall be hinged on the principle of fair-play and transparency that is devoid of political undertones. The selection of private sector participants in Excreta and Sewage Management shall be organised as follows:
8.1 Franchised area shall be planned and mapped.
8.2 Criteria for company qualification and selection shall be clearly stated.
8.3 Indicators for franchised performance shall be specified.
8.4 Terms of Reference and Conditions of Engagement of the private sector participants shall be defined.
8.5 Monitoring and evaluation procedure shall be outlined.
8.6 Entire operations shall be backed by legislation.
9.0 SANCTIONS AND ENFORCEMENT MECHANISMS
Mobile Sanitation Courts have become necessary to encourage public compliance with set rules and regulations, enforce standards and ensure positive attitudinal changes. In this regard, the following are recommended:
9.1 Laws/Bye-laws on excreta management, which stipulate recommended methods of management for different areas, and the citizens’ obligations shall be enacted.

9.2 The Laws/Bye-laws shall be adequately disseminated to the communities.
9.3 Local and mobile courts shall be established where they do not exist, to try offenders and impose sanctions.
9.4 Sanctions shall be strictly enforced.