Fix up, look sharp - occupational safety and health management in Kenya

22 April 2016

Delivering an assessment of occupational safety and health management in Kenya’s leather sector, Arthur Onyuka of the Kenya Industrial Research and Development Institute (KIRDI), outlines a case study of the country’s efforts to clean up its act.

The leather industry in Kenya contributes about 4.0% of the agricultural GDP and 1.5% of overall GDP. Currently, there are 13 commercial tanneries offering employment to about 1,500 people, and mainly processing wet-salted raw hides and skins to wet-blue for export. Occupational safety and health (OSH) has been a major concern for the industry stakeholders, so a recent study aimed to assess the OSH management and practices in the tanneries, and the extent to which they are aligned to the legislation and overall requirements.

The study focused on eight of the tanneries, involving site visits to examine practices, governance and structures established to achieve and maintain the required OSH as it relates to safe operations and the work environment. Within the scope of the assessment, the study found that general practices in the tanneries didn’t meet requirements and needed urgent improvement.

Specific areas requiring urgent improvement include formulation of policies; mandatory OSH awareness and training for management, supervisors and workers; information system on workplace hazardous materials and practices; and the establishment of internal monitoring and performance measures for the management to more effectively evaluate the performance of the OSH measures in place. As a result, this study has provided the current status of OSH in Kenya’s leather industry and forms the basis for addressing training needs including regulatory interventions from relevant government agencies.

With great potential comes great responsibility

The Kenyan leather industry is one of the key agro-based sectors, and has great potential to contribute towards economic development and the promotion of employment opportunities within the country. Agriculture, which is the main employer and economic driver for growth, contributing 14.5% to the overall GDP according to the recent economic survey by Kenya National Bureau of Statistics.

Previously, for close to a decade, the industry faced stagnation due to a number of challenges ranging from poor-quality raw materials, export of raw hides and skins to an unskilled labour force, and the introduction of cheap used shoes into the local market. However, in the past three years and having recognised the potential of the leather industry, the Kenyan Government initiated strategies to revitalise growth in the sector with an emphasis on value addition through the chain of production to finished product.

With this in mind, the government has mainstreamed favourable policies targeting the leather sector into various national development plans, embarked on upgrading infrastructure and created leather cluster zones to enhance the competitiveness of the industry. This has resulted in restoring confidence among the front-line industry stakeholders and has seen the number of commercial tanneries increase from nine to 13, and a number of mini-tanneries distributed across the counties.

The existing commercial tanneries are mainly family owned, small and medium-scale enterprises employing 50–120 workers. They are mainly export-oriented, processing wet-salted hides and skins into wet-blues for the Asian and European markets. The tanning segment of the industry is also 90% male with female employees mainly carrying out cleaning, trimming and clerical jobs. Plus, education and literacy level among the tannery workers is fairly low, many of whom have not gone beyond primary level education and have no formal vocational training.

A matter of public perspective

Over the years, the leather industry has been negatively perceived by the public, and tanning has been associated with pollution caused by the odour and effluent generated. And unless proper preventive and protective measures are put in place, workers face OSH risks, ranging from exposure to chemical and biological hazards, machinery and equipment, processes, physical hazards, ergonomic hazards, air contaminants and psychosocial factors.

The transformation in the global leather industry has seen the relocation of the productive tanning activities from developed to developing economies leading to expansion of the leather industry in these developing economies. As the industry moves towards revitalisation and growth in Kenya, this is bound to be accompanied by increased pollution, and OSH risks associated with exposure to the identified tannery workplace hazards.

The primary goal of all OSH programmes is to promote a safe work environment, and the possible impact on the surrounding communities and general environment should also be taken into account. Although there are limitations on data collection, the International Labour Organization (ILO) estimates that, globally, occupational accidents and work-related diseases cause over 2.3 million fatalities every year, out of which approximately 300,000 are caused by occupational accidents and about 2.0 million by work-related diseases. Exposure to hazardous substances at work causes nearly 900,000 deaths every year, according to 2014 estimates.

In Kenya, the Occupational Safety and Health Act (OSHA) and Worker Injury and Benefits Act (WIBA) were enacted in 2007, and are the principal laws that govern OSH in the country. The Directorate of Occupational Safety and Health Services (DOSHS) is the designated national authority for collection and maintenance of a database, and for the analysis and investigation of occupational accidents and diseases. DOSHS, however, has inadequate capacity to inspect all the workplaces effectively, which leaves most workers potentially exposed to OSH hazards without intervention.

The Kenyan leather industry is one of the key agro-based sectors, and has great potential to contribute towards economic development and the promotion of employment opportunities within the country.

In most firms and organisations, OSH issues are not in their strategic plans, and employers and employees treat OSH matters casually, which further suggests that many work-related injuries and diseases go unreported. Besides, enforcement of OSH regulations are weak and the level of compliance is wanting.

The leather industry, despite being among the traditional industries in the country, has received less attention with regard to occupational accidents and work-related diseases. There is lack of information, and no published research work on OSH management systems and practices in the sector, which makes it difficult planning for intervention measures. An Occupational Safety and Health Management System (OSHMS) has been defined as a framework that allows an organisation to consistently identify and control its health and safety risks, reduce the potential for accidents, help achieve compliance with health and safety legislation, and continually improve its performance. To achieve this, ILO outlines an OSH management system that comprises policy, organising, planning and implementation, evaluation and action for improvement.

The study results

The purpose of this study was to assess OSH management in the tanning sector of the Kenyan leather industry and the degree to which it is fulfilling its responsibilities in complying with the requirements.

The main objective was to determine whether management framework, and the the required elements of OSH programmes are in place to support compliance and establishment of a healthy and safe work environment. The study was conducted through a survey method for a period of three months and respondents were randomly chosen across all levels of operations in the tannery, which included administrative office workers, security personnel, cleaners, sorters, chemical storage personnel, beamhouse production staff, tanyard operators, post tanning operators, supervisors and managers, and a total of 312 respondents participated.

According to ILO’s model of an OSHMS, it is a requirement for an organisation to have in place an OSH policy that is specific to the scope of the organisation’s activities and complies with the national laws and regulations.

The policy should be an integral part of the overall business and also be documented, available to all interested parties and communicated, to demonstrate meaningful participation of the workers, and signed to show commitment to continuous improvement.

In this study, 75% (six of the tanneries) did not have a written OSH policy, or any safety and health management programme in place, and two tanneries had OSH policies that were ten years old, non-specific and lacked clear details of the scope, objectives, delegation of responsibilities and evidence of workers’ involvement; for example, safety and health committees. Plus, the policy was not in open display for the workers and or any interested party to view.

Among the employees who responded, 72 were in positions of management and or in a supervisory level. About 69%, (50 employees) were ignorant about the Kenya national OSH Act of 2007 and had no knowledge about OSH requirements at the workplace. And those remaining with awareness of the OSH Act didn’t have previous formal training on OSH and didn’t think OSH policy was a compliance requirement. Furthermore, the tannery operators – 135 – at different processing stages who responded were not aware of the OSH policy, or the OSH Act, and none had been consulted, involved or been part of any safety and health committee in their tanneries. All of them felt it was the responsibility of the owners of the tannery to ensure their well-being.

In the ILO model of OSH management systems, organising covers the allocation of responsibilities and accountability throughout the organisation, competence and training, processes and procedures, and the overall structure of OSH management system. In the eight tanneries studied, there were no defined roles and responsibilities with regard to OSH.

According to the ILO guidelines, OSH management systems clearly state that the employer should have overall responsibility for the protection of the workers’ safety and health, and provide leadership in OSH activities in the organisation. But documentation that describe how OSH is managed, management roles and responsibilities was not available.

Although the 72 employees in management and supervisory positions in the tanneries who responded noted OSH
as being an important component in the tannery, there were no established OSH structures or budget allocation for OSH activities. All of the 197 employees who responded confirmed not receiving any training in OSH and have never undergone medical surveillance as required by the 2007 OSH Act of Kenya.

Put it into action

The planning and implementation element of the OSH management system requires an organisation to have in place an effective management structure and arrangements to deliver the OSH policy. It focuses on plans for each element of the OSH management model, covering contingency plans, measurements and activities.

Workplace hazard identification and risk assessment are also covered in planning, and should be done on a continuous basis to determine priorities and set objectives for eliminating hazards and minimising risks.

Under the planning and implementation element, this study also focused on variables under hazard prevention. An 80% majority of the workers who responded revealed that they are never provided with adequate personal protective equipment and, in most cases, they are required to purchase their own. They further indicated that the tanneries did not have emergency response plans in case of fire outbreak and there were no marked fire exits, emergency first-aiders or first aid boxes.

The ILO guidelines state that procedures should be developed to enable an organisation entity to monitor, measure and evaluate safety and health performance on a regular basis. This is carried on the basis of identified hazards, and risks and benchmarked on the set standards and OSH objectives. It encompasses self-monitoring of ill health, auditing and review of effective functioning of the system. In all the tanneries the study was undertaken, there were no procedures in place for monitoring and measuring performance. Subsequently, no audit or reviews were conducted as there was no one to take responsibility or accountability for evaluating the performance.

There were fundamental weaknesses in OSH management in the tanneries studied. Safety and health was not taken seriously by the top management leaving many of the workers vulnerable to exposure to hazardous materials, and risk of injuries and ill health. The tannery operators and line managers displayed ignorance in OSH matters, which creates serious concerns if the Kenyan leather industry is to assume competitiveness at the global market.

The poor integration of the OSH management systems in the tannery  processes may be attributed to weak or poor enforcement of the OSH Act by relevant agencies, lack of awareness of the ILO OSH standard guidelines, and the general culture of irresponsibility on safety and health matters. Consequently, there is an urgent need for training and awareness creation, as well as diligence in enforcement of the laws and regulations across all levels of the leather sector. In order to remain competitive in the global market in the future, the tanning sector will need to integrate OSH management systems in the entire chain of production to increase productivity and promote business profits. ?

The Kenyan leather industry is one steeped in tradition; however, it needs to modernise its health and safety programmes.

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