REPUBLIC OF GHANA

National Solid Waste Management

Strategy for Ghana

June 2020
 REPUBLIC OF GHANA

National Solid Waste Management

Strategy for Ghana

June 2020
National Solid Waste Management strategy for Ghana

Acknowledgments
The Ministry of Sanitation and Water Resources would like to acknowledge the support of
UNICEF Ghana and the Embassy of the Kingdom of the Netherlands for providing expertise
and financial resources to produce this strategy document. We especially thank officials from
the Ministry of Environment, Science, Technology and Innovation, the Environmental
Protection Agency, the Ministry of Local Government and Rural Development, Office of Head
of Local Government Service, Department of Community Development and Ghana Health
Service for their expert inputs, which shaped this strategy document.

In addition, we are also extremely grateful for the time and patience shown by all the key
informants who contributed to the research and analysis underpinning this document. This
includes dozens of staff from metropolitan, municipal and district assemblies visited during
the fieldwork, as well as a similar number of private sector stakeholders representing small-,
medium-, and large-scale service providers drawn from the formal and informal solid waste
management sector, particularly: (i) Environmental Service Providers Association (ESPA); (ii)
Waste Pickers Association; (iii) Ghana Plastic Sachet Collectors Association; (iv) Ghana
Plastic Sachet Manufacturer’s Association; (v) Ghana Plastic Sachet Recycling Association.
We also wish to place on record our appreciation to officials of “Joy News” (a television
channel) for their insight on aspects of behaviour change.

This work was produced by Oxford Policy Management, in collaboration with Maple Consult,
under the guidance of a National Technical Working Group for Sanitation, and in c ollaboration
with WASH sector experts at UNICEF Ghana

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National Solid Waste Management strategy for Ghana

Foreword
The ambition and scope of this Solid Waste Management Strategy (SWMS) reflects the
Government of Ghana’s commitment in delivering on H.E. The President’s vision of making
Accra the “Cleanest City in Africa” and by extension the whole country. The strategy
recognises the strengths and weaknesses of current solid waste management practices
across the country and sets out a clear pathway, underpinned by existing policies and
legislations. It is supported by practical operational recommendations, for the realisation of a
more progressive, high quality, and sustainable solid waste management services in Ghana
which will enhance environmental, public health, and economic benefits for all citizens.

The development of this strategy is the latest of a series of pro-active steps the Government
of Ghana is taking to tackle the environmental challenges facing the country. On plastic waste,
for example, Ghana recently became the first African nation to join the Global Plastic Action
Partnership (GPAP) as part of efforts to drastically reduce plastic waste in waterways and
oceans. Under the leadership of the Ministry of Environment, Science, Technology and
Innovation (MESTI), a National Plastic Management Policy was launched in 2019 which aims
to establish an extended producer responsibility scheme for plastic products. The Ministry of
Sanitation and Water Resources is also finalising an Integrated Master Plan for the Greater
Accra Metropolitan Area, which will be an umbrella document including components on solid
waste, liquid waste and drainage. This will be replicated in the other urban centres of the
country.

Cumulatively these initiatives among others, are designed to place our country on the road
towards enhancing environmental stewardship, sustainable and resilient growth, and
delivering a vision for the future of which we can all be proud.

The Solid Waste Management Strategy has been prepared through a consultative and
participatory process involving all key sector stakeholders at the national, regional and district
levels. I wish to express my sincere appreciation to all those who supported the development
of this strategy and in particular representatives of the National Technical Working Group on
Sanitation, Coalition of NGOs in Water and Sanitation (CONIWAS), Ministry of Finance,
Ministry of Local Government and Rural Development, Ministry of Environment, Science,
Techno logy and Innovation, National Development Planning Commission (NDPC) and
National Commission for Civic Education (NCCE) who were instrumental in the development
of this extremely important strategy for our sector.

Cecilia Abena Dapaah

Minister

Ministry of Sanitation and Water Resources

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National Solid Waste Management strategy for Ghana

Executive summary
Despite its links to public health and environmental protection, and its salience in the
public consciousness, progress on improving Solid Waste Management (SWM)
practices remains slow in Ghana. In all urban areas of the country, solid waste is
indiscriminately thrown in the streets, drains, or the sea; crudely dumped at unapproved
sites; or burnt on-site. Problematic household practices regarding solid waste disposal are
compounded by inadequate, ineffective, or unaffordable service delivery arrangements. In
most cases, waste transfer stations (such as skips) are poorly located, inadequate in
number, and emptied irregularly. Regular door-to-door collection services, although
reasonably widespread, are selective in who they serve due to poorly defined or unenforced
zoning. In many Metropolitan, Municipal and District Assemblies (MMDAs) service providers
are not accountable for the quality of services they deliver due to weak governance,
procurement and monitoring and evaluation systems. Problems also extend to waste
disposal and landfill sites - which are poorly managed, lacking in capacity and unsafe.
Moreover, waste reduction, re-use, and recycling activities remain extremely localised and
small scale.

The overarching aim of this dedicated SWM strategy is to set Ghana on a path
towards progressive, high-quality, cost-effective and sustainable waste management
services which deliver environmental, public health, and economic benefits to all. This
strategy has been informed by consultations during extensive fieldwork across 10 urban
areas of Ghana, including: interviews with formal and informal private sector service
providers; in-depth discussions with SWM service users; consultations with local and
national authorities responsible for SWM; and site assessments of key SWM infrastructure
supporting solid waste collection, treatment, disposal, recycling and reuse. Representatives
from national and local government, the private sector, and civil society have also played a
key role in the strategy development process both as key informants to data collection but
also as a reference group to validate fieldwork findings and strategic recommendations

The SWM strategy is organised around seven interdependent pillars of action – all of
which require attention if widespread improvements of SWM services are to be delivered.

Pillar 1: Strengthen sector governance

• Harmonise sector policies to create a coherent and comprehensive approach to
SWM that is progressive and aligned with modern practices in waste management
and recovery
• Enhance sector coordination and prioritise government action on SWM by
establishing a temporary inter-ministerial coordination committee for sanitation
housed under the Office of the Vice President. Longer-term this may be super-seded
by a National Environmental Sanitation Policy Coordinating Committee
• Require MMDAs within large conurbations to establish a joint development board to
allow pooling of key infrastructure assets and to optimise the use of resources
• Develop an enforceable and tailored regulatory framework for the SWM sector which
provide a basis for procurement, contracting, monitoring and supervision of service
providers working across the waste management chain. The framework should
define mechanisms for operational enforcement and oversight, ensure an increased

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focus on environmental regulations, and simplify processes that MMDA’s have to

follow to secure a permit for waste treatment facilities.
• Build specialised waste management capacity within MMDAs through the
progressive expansion of Waste Management Departments into Municipal and
District Assemblies and the roll-out of tailored training programmes in specific
technical areas, such as: landfill management and supervision.
Pillar 2: Increase private sector participation:
• Rezone service delivery areas within urban areas to include a mix of high and low-
income areas and enable increased private sector engagement in low-income areas
by introducing a special higher rate fee for large waste producers to cross-subsidise
these services.
• Standardise procurement and evaluation guidelines and contracts to increase rigour
and consistency in tender evaluation and contracting arrangements.
• Formalise and provide legal recognition of waste pickers and other informal service
providers (e.g. ‘Borla’ taxis)
• Introduce tax and fee relief for prospective investors and service providers in the
SWM sector
Pillar 3: Optimise service delivery and infrastructure:
• Develop a spatial development plan to ensure logical and equitable placement of
SWM infrastructure
• Apply new guidelines for the evaluation of existing and proposed public private
partnerships, ensuring these decisions are transparent and based on robust
analyses of cost recovery mechanisms and likely demand in order to reduce risks of
public investments.
Pillar 4: Create positive social action on SWM:
• Strengthen the coherence and targeting of BCC messaging through the development
of a comprehensive SWM behaviour change strategy, co-developed with the support
of social marketing experts.
Pillar 5: Enable effective waste recovery, re-use, and recycling:
• Establish, promote and roll-out insurance products to cover losses in the recycling
sector when commodity pricing for recyclables deviate below defined thresholds
• Design, construct and manage publicly-owned, waste processing assets to increase
prospects for recycling and set-up local buy-back centre (using existing transfer
sites).
• Support the development of a recyclers exchange and recyclers forum that provides
key information on commodity pricing, tax responsibilities and open markets for the
trade of recyclables.
Pillar 6: Ensure effective sector M&E
• Integrate SWM indicators into a national waste management information system.
• Develop a simple monitoring framework to track implementation of SWM policies.
• Institutionalise a common set of service delivery indicators into MMDA-managed
SWM contracts. These should cover elements of service coverage, quality,
accessibility and reliability.
• Adapt the existing district performance assessment tool to place greater emphasis on
SWM performance.
Pillar 7: Establish sustainable sector financing mechanisms:
• Capitalise on other elements of this strategy which will strengthen operational
governance, competition, service optimisation and oversight (pillars 1,3,4, and 6)
within the sector, and improve overall value for money.

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• Review and revise the strategic environmental investment plan to establish the
financing gap and investment requirements over a multi-year period.
• Develop a strategic financing strategy for mobilising funds from identified sources of
funds (user fees, public finance, and private sector investment via PPPs) considering
options to set up specific funds (e.g. plastic waste recycling fund or national
sanitation fund), ringfencing taxes, or securing funds aligned to the newly developed
Plastic Waste Management Policy.
• Support improved planning for solid waste as part of the preparation of the District
Environmental Sanitation Strategy and Action Plan.

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Table of contents

Acknowledgments ................................ ................................ ................................ ........ iii

Foreword................................ ................................ ................................ ...................... iv
Executive summary ................................ ................................ ................................ ....... v
List of tables and boxes ................................ ................................ ............................... ix
List of abbreviations ................................ ................................ ................................ ...... x
1 Introduction ................................ ................................ ................................ ..... 1
1.1 Background to the development of this Solid Waste Management strategy
................................ ................................ ................................ ............ 1
1.2 Aims and objectives of the strategy ................................ ...................... 1
1.3 Structure of the strategy ................................ ................................ ....... 2
2 Situational analysis................................ ................................ .......................... 3
2.1 The SWM challenge in Ghana ................................ ............................. 3
2.2 Sector characteristics ................................ ................................ ........... 4
2.3 Sector governance ................................ ................................ ............... 5
2.4 Sector service delivery ................................ ................................ ......... 9
2.5 Behaviour change communication ................................ ..................... 12
3 Strategic priorities................................ ................................ .......................... 13
3.1 Overview ................................ ................................ ............................ 13
3.2 Pillar 1: Strengthen sector governance ................................ .............. 13
3.3 Pillar 2: Increase private sector participation ................................ ...... 18
3.4 Pillar 3: Optimise service delivery and infrastructure .......................... 21
3.5 Pillar 4: Create positive social action ................................ .................. 23
3.6 Pillar 5: Enable effective waste reduction, recovery, and recycling ..... 24
3.7 Pillar 6: Ensure effective M&E ................................ ............................ 27
3.8 Pillar 7: Establish sustainable financing mechanisms for SWM .......... 29
4 Implementation arrangements ................................ ................................ ....... 31
4.1 Coordination and phasing ................................ ................................ .. 31
4.2 Priority actions in the short term ................................ ......................... 31
4.3 Priority actions in the medium term ................................ .................... 39
4.4 Priority actions in the longer term ................................ ....................... 43
Annex A Monitoring and evaluating SWM service delivery................................ ........... 46
Annex B Stakeholders engaged................................ ................................ ................... 50

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List of abbreviations
BCC Behaviour change communication

CONIWAS Coalition of WASH NGOs

DACF District Assembly Common Fund

DESSAP District Environmental Sanitation Strategy and Action Plan

DPAT District Performance Assessment Tool

EHSD Environmental Health and Sanitation Directorate

EHSU Environmental Health and Sanitation Unit

EPA Environmental Protection Agency

GET Ghana Educational Trust

GWCL Ghana Water Company Limited

IMCC Inter-Ministerial Coordination Committee

KPI Key performance indicator

LUSPA Land Use and Spatial Planning Authority

M&E Monitoring and evaluation

MESTI Ministry of Environment Science, Technology and Innovation

MINT Materials in transition

MLGRD Ministry of Local Government and Rural Development

MMDAs Metro, Municipal, and District Assemblies

MSD Management Services Division

MSWR Ministry of Sanitation and Water Resources

MTDP Medium-Term Development Plan

NCCE National Commission for Civic Education

NDPC National Development Planning Commission

NSA National Sanitation Authority

OHLGS Office of the Head of Local Government Service

OHS Occupational Health and Safety

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List of tables and boxes

Table 1: Key dates in reform of SWM sector 6
Table 2: Assessment of functional status of selected landfill / dumpsites in Ghana 11
Table 3: Summary of key indicators and means of verification 46
Table 4: Proposed indicators to assess conditions at communal transfer stations 48
Table 5: Attendees at the validation workshop, Accra, 1 August 2019 50

Box 1: Public health and SWM ................................ ................................ ........................... 3

Box 2: Aligning sector responsibilities – MSWR, MLGRD, and MESTI ............................... 7
Box 3: M&E practices for SWM in Ghana ................................ ................................ ........... 9
Box 4: The unseen cost of waste recycling in Ghana ................................ ....................... 12

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PPBME Policy, Planning, Budgeting, Monitoring, and Evaluation

PPP Public–private partnership

PURC Public Utilities Regulatory Commission

RCC Regional Coordinating Council

RSIM Research Statistics and Information Management

SESIP Strategic Environmental Sanitation Investment Plan

SIP Sanitation Improvement Package

SME Small and medium-size enterprise

SWM Solid waste management

UNDP United Nations Development Programme

UNICEF United Nations Children’s Fund

WMD Waste Management Department

YEA Youth Employment Agency

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1 Introduction
1.1 Background to the development of this Solid Waste
Management strategy
In June 2018 the National Technical Working Group on Sanitation agreed to the
development of a comprehensive ‘National Urban Sanitation Strategy’. This ‘umbrella’
strategy was conceptualised as a consolidated document containing three distinct sub-
strategies focused on different aspects of environmental health and sanitation management:
(1) liquid waste management; (2) solid waste management (SWM); and (3) medical/
hazardous waste management.

Each of the three sub-strategies are being developed in parallel. The Embassy of the
Netherlands, through the United Nations Children’s Fund (UNICEF) has supported the
strategy development process for two of these components – namely, liquid waste and solid
waste – whereas the strategy for medical / hazardous waste has been developed by the
World Health Organization. The Government of Ghana, through its Ministry of Sanitation and
Water Resources (MSWR), has been instrumental in providing leadership across all
workstreams of the National Urban Sanitation Strategy

This document is focused on the SWM sub-strategy. It has been developed over a 10-
month period and is based on primary research across eight regions of Ghana, secondary
data collection, and document review, including extensive stakeholder consultation through
interviews and group workshops involving representatives from the national and local
government, development partners, international non-governmental organisations, and
small-, medium-, and large-scale private sector providers.

A variety of solid, liquid, and healthcare waste management guidelines and manuals have
been developed in the past by the Ministry of Local Government and Rural Development
(MLGRD), the Ministry of Environment Science, Technology and Innovation (MESTI), and
the Ministry of Health. Many of these were developed as part of the World Bank’s
Environmental Sanitation Project; they have informed the development of this strategy
document.

1.2 Aims and objectives of the strategy

The overarching aim of the strategy is to set Ghana on a path towards progressive, high-
quality, and cost-effective SWM service delivery, which will deliver environmental, public
health, and economic benefits to all.

The specific objectives of the SWM strategy document are two-fold:

• To diagnose key challenges inhibiting effective and progressive SWM practices across
urban areas of Ghana.
• To outline a national strategic plan to help ameliorate priority challenges, ensuring
alignment with existing administrative and governance structures, inclusivity of key
stakeholders (government, private sector, and development partners), and recognition of
priority challenges for vulnerable groups.

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1.3 Structure of the strategy

The rest of the strategy document is structured as follows:

• Section 2 provides a situation analysis of SWM service delivery in urban areas of

Ghana. This includes a critical assessment of sector policies, institutional and
governance arrangements, service delivery models, and behaviour change approaches.
Within this section key sector constraints are grouped and prioritised.
• Section 3 focuses on defining the strategic priorities of the strategy. These
priorities are organised into seven pillars. Within each pillar, strategic entry points for
stakeholder action are identified.
• Section 4, which is much more operational in its focus, outlines how the strategic
priorities identified in Section 3 are to be implemented. This includes the mapping
out roles and responsibilities of key actions and projecting a sector strengthening plan
over the short, medium, and long term.

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2 Situational analysis
2.1 The SWM challenge in Ghana
Ghana is facing a waste management crisis. In all urban areas of the country, solid waste
is indiscriminately thrown in the streets, drains, or the sea; crudely dumped at unapproved
dumpsites; or burnt on-site. These challenges are most acute in the larger cities of Accra,
Kumasi, Takoradi, and Tamale, and reflect extremely poor behaviour control by households,
commercial businesses, and SWM service providers.

Challenges related to poor behaviour and practices are compounded by inadequate,

ineffective, or unaffordable service delivery arrangements. In most cases, waste
transfer stations are poorly located, inadequate in number, and emptied irregularly. Regular
door-to-door collection services are reasonably widespread, especially within metropolitan
assemblies, but private sector service providers choose who they serve due to poorly
defined or unenforced zoning. This often leaves the poorest and most marginalised
households underserved and left with the choice of either engaging an informal provider or
dumping waste at unauthorised sites.

Rapid economic activity contributes to the increased production of solid waste.

Between 2005 and 2012, the Ghanaian economy grew at an impressive 7.7% per year on
average, largely driven by commodity exports (primarily cocoa and gold) and the start of
commercial oil production in 2011. However, GDP growth rates slowed between 2012 and
2016, averaging 5.6%, while picking up again to 8.5% in 2017.

Box 1: Public health and SWM

The public health implications of irresponsible waste management are severe, recurrent, and are
invariably borne disproportionately by the poor and vulnerable. In Ghana, crude waste management
practices have exacerbated environmental (flooding, groundwater contamination) and public health
(cholera, diarrhoea, typhoid) risks, particularly in low-income, densely populated, and flood-prone
urban areas. In addition, poor SWM hinders the potential of business and enterprise growth
(particularly in the tourism and hospitality sectors).
Ghana has experienced intermittent cholera outbreaks since the 1980s, and these have become
increasingly regular in recent years as urbanisation gathers pace. The most recent large outbreak
occurred between June 2014 and January 2015, where over 28,000 cases were reported, resulting
in 243 deaths.
Approximately half of all Ghanaians live in high-density communities within or on the fringes of city
centres and these areas have become key drivers of cholera and related diseases through poor
SWM and environmental sanitation in general. Several small-scale studies have shown that those
most affected live in low-income peri-urban areas where disposal of refuse is limited, and many of
the communal facilities which do exist are overflowing and act as mini dump sites where the solids
end up in drains. These issues are exacerbated by the additional challenges associated with rapid
urbanisation: household overcrowding, lack of public space, social dislocation, and poor urban
planning. As such, waste that is collected often ends up in open drains, watercourses, and streams,
or in unauthorised dumpsites, which increases the impacts of flooding.

There are also several additional SWM challenges which are less immediately visible
to the population. In particular, most ‘managed’ dumpsites and landfills across the country
are operated in a ‘semi-controlled’ or an ‘uncontrolled’ manner. Sites are mostly not fenced

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and are open to the public, with no leachate control or treatment measures in place, and with
limited arrangements for waste compaction and or fire control.

Efforts to reduce the overall SWM burden through mitigation measures, such as
waste reduction, re-use, and recycling, remain at the piloting stage or are extremely
localised. This is despite a rapidly developing and progressive government policy
framework which seeks to keep pace with best practice mitigation initiatives in the sector.

Many of the poor SWM outcomes observed are, in part, a result of weak operational
governance in the sector. Key challenges include: weaknesses in procurement,
contracting and oversight of private providers by local government authorities; institutional
conflicts related to overlapping or incoherent functional responsibilities; and limited overall
investment in local government capacity and M&E. Moreover, the limited availability of
systematic data on service provider performance, service quality, and household knowledge,
attitudes and practices around SWM constrain informed policy debate and weaken
accountability mechanisms between households, service providers, and local and national
government. Given this context, it is clear that the SWM sector in Ghana requires a
dedicated strategy for tackling the key challenges identified.

2.2 Sector characteristics

2.2.1 Collection and transport

In Ghana municipal solid waste collection and transportation is almost exclusively

delivered through private sector providers. These providers vary in size, complexity, and
models of service delivery. Some are formalised and bid for local government contracts, but
the majority are informal, small-scale providers dealing directly with households. The two
dominant forms of waste collection are the following:

• Primary collection: Door-to-door or kerb-based collection of small aggregations of

waste. This is either undertaken by formal medium- to large-scale contractors
working on behalf of the Metropolitan, Municipal, and District Assemblies (MMDAs) and
serving registered, fee-paying, households in designated zones, or by a plethora of
small-scale informal service providers who roam the streets with low-capacity
vehicles and service households and commercial entities with a pay-as-you go service
with no standard fees.
• Secondary collection: Relating to large, national-scaled waste evacuation services for
waste deposited in communal skip containers or in public areas, including street cleaning
activities. Most of these activities are covered under the national Sanitation
Improvement Package (SIP). The SIP is a service agreement for the provision and
management of skips and waste management equipment for all MMDAs in Ghana. While
the service-level contract for each local SIP is between the various MMDAs and a single
private service provider, it is contracted and negotiated at the national level, with the
MLGRD. The SIP is a crucial pillar of SWM in Ghana and it represents the largest single
contract for solid waste service provision.

2.2.2 Waste disposal

In Ghana, the primary, formalised channel for waste disposal is through ‘managed’
landfill or dump sites. In addition, there are a small number of sophisticated material

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recovery facilities for recyclable waste, but these are not heavily utilised. Most urban areas
have one designated dumpsite, managed or maintained by a local government contractor.

2.2.3 Waste reduction, re-use, and recycling

There are comparatively few waste reduction, re-use, and recycling initiatives
operating at scale in Ghana. Most of the waste recovery and recycling facilities are
privately owned and are centred in Accra, Tema, and Kumasi. As such, the majority of
recyclables recovered from other MMDAs are sent to these urban centres, where processing
and marketing capacity exists and where the recyclables can be further processed to export
standards.

The most common recycling activity in Ghana, as in many other lower middle-income
countries, is the collection/aggregation and trade of common recyclable plastic sub-
typologies (PET, HDPE, and PP), cardboard, glass, and metals. Commercial recycling
activities range from highly advanced recycling and material recovery facilities managed
under donor and public–private partnership (PPP) arrangements, to informal outdoor
aggregation points near waste skips or on dumpsites, overseen by informal waste-pickers.
There are also several small-scale recycling centres across the country, managed by small
and medium-sized enterprises (SMEs).

What is notable about the recycling sector in Ghana is the absence of advanced and
commercially sustainable recycling businesses valorising recyclables to export-grade
quality. Such entities can compete in the international export market and drive improved
collection practice locally.

2.3 Sector governance

2.3.1 Policy and legislative arrangements

Broadly speaking, the Ghana SWM policy regime is comprehensive, progressive, and
aligned with modern practices in waste management and recovery. For example, the
Draft National Plastics Management Policy (2018) proposes an extended producer
responsibility scheme for plastic products and packaging industries in Ghana, while the
Strategic National Energy Plan (2006) made recommendations for the establishment of a
tariff regime that would be friendly to renewable energy, such as through pyrolysis or
gasification. The National Environmental Sanitation Strategy and Action Plan promotes
material recovery through the concept of materials in transition (MINT), which sees waste as
having value and which envisages the different components being recovered as a secondary
resource.

However, many MMDA actors and authorities have inadequate knowledge, within the
changing national policy environment. In general, any local government attention that is
given to SWM is focused on the operational issues of rudimentary waste collection,
transport, and disposal, without recovery. Furthermore, progressive policy instruments are
often not supported by a financial mechanism or allocations to support their implementation.
In addition, various policies are situated within different ministries, which do not coordinate
effectively on policy coherence or implementation. For example, the National Plastics

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Management Policy sits within MESTI, while the Environmental Sanitation Policy was
promulgated by MLGRD, which previously had responsibility for sanitation. The Energy Plan
(2006) rests with the Ministry of Energy.

Table 1 (below) provides timelines for key policy frameworks and documents that have
made a significant contribution to the management of solid waste.

Table 1: Key dates in reform of SWM sector

Type Year Legislation/policy
Hazardous and Electronic Waste Control and Management
2016
Act (Act 917)

2016 Local Governance Act (Act 936)

Legislation
2013 Draft Ghana Public Private Partnership Bill

2012 Public Health Act (Act 851)

2018 Draft National Plastics Management Policy

Coordinated Programme of Economic and Social Development
2017
Policies (2017–2024)
2014 Ghana Shared Growth and Development Agenda, 2014–2017
2012 National Environmental Policy
Policies and strategies 2011 Strategic Environmental Sanitation Investment Plan

2011 National PPP Policy

National Environmental Sanitation Strategy and Action Plan (2010–
2010
2015)
2010 Revised Environmental Sanitation Policy(2010)
2006 Energy Plan

2.3.2 Institutional arrangements

In Ghana the governance structure for SWM is complex and layered, with different
responsibilities across several national- and sub-national-level institutions. MSWR is
the primary line ministry in charge of strategic direction and policy development within the
SWM sector. MSWR was established in January 2017 and was widely seen as a signal-
marker of government commitment to and prioritisation of the sanitation sector as a whole –
including solid and liquid waste management. However, despite the establishment of
MSWR, institutional complexities persist (see Box 2 below).

The overall environmental compliance of the SWM sector is regulated by the

Environmental Protection Agency (EPA), whereas the day-to-day oversight and
monitoring of service delivery is provided by MMDAs, while Regional Coordinating Councils
(RCCs) have coordinating responsibility. Other ministries with direct and indirect involvement
in SWM are MLGRD, MESTI, and the Ministry of Works and Housing.

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Box 2: Aligning sector responsibilities – MSWR, MLGRD, and MESTI

Prior to the establishment of MSWR in 2017, sanitation and SWM were under the purview of
MLGRD. The current framework reflects some legacy challenges associated with this change. The
Local Government Act mandates that MMDAs have responsibility for the provision of waste
management services and this means funds are allocated for SWM from the District Assembly
Common Fund (DACF). As a result, major contracts, such as the SIP, rest with MLGRD, whereas
sectoral responsibility lies with MWSR. A second example is the fact that MLGRD, working in
conjunction with the Ministry of Finance, is mandated by Act 512,1996, to specify the use and
modalities of the plastic waste recycling fund. The act is yet to be modified to reflect the changes in
ministerial responsibility for SWM, and also to reflect the fact that MESTI is in charge of plastic
waste policy. The result is that financial-level autonomy and responsibilities are not coherently
aligned with service-level responsibilities. If these inter-ministerial accountabilities, functions, and
technical expertise are not sufficiently aligned the governance of the sector will be undermined.

2.3.3 Operational governance

Local government capacity, planning, and finance

Local authority capacity varies widely between metropolitan, municipal, and district
authorities. The six metropolitan assemblies have dedicated Waste Management
Departments (WMDs). In the 109 municipal assemblies waste management functions are
subsumed within the Environmental Health and Sanitation Units (EHSUs). WMDs are better
resourced than EHSUs, but, even so, staffing levels in WMDs still fall below the
recommended guidelines of the Office of the Head of Local Government Service (OHLGS).

In most cases, local government District Environmental Sanitation Strategy and

Action Plans (DESSAPs) only pay passing reference to SWM issues and rarely if ever
contain indicators related to SWM progress. Most annual plans include some generalised
components on broader environmental health issues, such as community sensitisation and
engagement, prosecution of offenders, and clean-up campaigns, but they do not contain any
plans for water management services or infrastructure. One of the reported reasons for this
is the existence and overall reliance on the SIP and Youth Empl oyment Agency (YEA)
contracts.

The limited emphasis on SWM in DESSAPs also reflects the limited focus on SWM
issues in MMDAs’ Medium-Term Development Plans (MTDPs). An analysis of the 2018–
2021 MTDPs of selected MMDAs indicates that the only activity planned by the Tema
Metropolitan Assembly to manage solid waste is to provide public education. There is no
information regarding plans to strengthen logistical support for waste management, source
separation, or waste recycling. A similar picture is painted in the SWM strategies and
proposed activities for La Dade-Kotopon Municipal Assembly, Nanumba North Municipal
Assembly, and Shai-Osudoku District Assembly, which all lay emphasis on the software
aspects of solid waste collection and management, to the neglect of investments in
infrastructure provision.

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MMDA Reference to SWM in their MTDPs

Tema Metropolitan
• Provide public education on SWM
Assembly
• Improve SWM:
o household- and commercial-level waste separation and
recycling
• Determine human capital and skill set needs required:
o organise capacity building training programmes for solid waste
collection contractors
o solid waste haulage
Accra Metropolitan o acquire 200-acre land for the construction of sanitary landfill
Assembly o facilitate the identification and securing of land by solid waste
collection contractors for recycling activities
• Improve SWM:
o complete first phase of remediation works at the International
Central Gospel Church dumpsite
• Improve SWM:
o fee- and performance-based solid waste collection service
contracts monitored and evaluated
• Provide public education on SWM
La Dade-Kotopon • Promote National Total Sanitation Campaign
Municipal Assembly • Register 12,000 households for solid waste collection services (polluter
pays system)
• Enhance access to improved and reliable environmental sanitation
services:
o provide public education on SWM
Nanumba North o regulate operations of solid waste service providers in the
Municipal Assembly municipality
o procure and distribute 300 public dustbins
o fumigate communities against diseases
o evacuation of refuse dumps
Shai-Osudoku • Expand infrastructure facilities at all levels
District Assembly • Improve SWM

The SIP, contract for waste management infrastructure, and YEA are contracted
centrally and account for a substantial proportion of the funds earmarked for local
government service delivery in the DACF. This has the dual effect of: (i) leaving little
residual funds for investment in sanitation planning and delivery; and (ii) further degrading
the level of responsibility that MMDAs feel for service delivery (as, by and large, these have
been outsourced to the private sector). The combined MMDA spending on SWM – whether
through the SIP, YEA, or more discretionary local spending – represents a sizeable
proportion of MMDA funding. With these relatively high levels of public financing for the
SWM and waste recovery sector it would be reasonable to expect that service quality and
practices would be better than what is currently observed.

Procurement, contracting, and M&E

The low level of competition in formalised SWM service delivery is a major concern.
This means that there are few incentives to drive efficiency, innovation, or service quality

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National Solid Waste Management strategy for Ghana

amongst formal providers. Broadly speaking, barriers to competition take two forms: (i) the
imposition of high local government fees and rates which discourage the formalisation or
scaling of small-scale or informal providers to compete on service contracts, and (ii) lack of
transparency or probity in relation to contract awards and monitoring.

In respect of communal collection, MMDAs have little or no control over the awarding
of SIP contracts. In addition, insufficient supervision of service performance by door-to-door
service providers remains a serious threat to the efficient and sustainable management of
SWM.

At contractual level, most SWM contracts do not specify KPI or stipulate minimum
service-level requirements. At the operational level, the majority of MMDAs undertake
service monitoring in an ad hoc manner. The result is that SWM service providers working
on waste collection and disposal are not held accountable for the quality of their service
delivery. Even if MMDAs are extremely dissatisfied with the service providers, their ability to
influence service provider operation may be restricted by a poorly specified contract, or
inadequate technical capacity or resources. Indeed, one of the most common challenges
faced by MMDAs is the asymmetry of technical knowledge, capacity, and resources
between local government authorities and the provider.

In some areas, such as Kumasi Metropolitan Assembly, locally driven monitoring initiatives
have been rolled out; however, such initiatives are extremely localised and are not part of a
broader or systematic sector monitoring system.

Box 3: M&E practices for SWM in Ghana

Most MMDAs in Ghana do not have any systems in place for tracking SWM service performance.
One notable exception is Kumasi Municipal Assembly: for example, the WMD within this assembly
has geotagged the locations of all skip sites and undertakes systematic monitoring of each site to
check whether the skips are being regularly emptied and whether the sites are being maintained in
a hygienic and safe manner. On the basis of this monitoring, simple league tables have been
created indicating the sites and contractors that are performing well or badly. Kumasi Municipal
Assembly has also now taken over the management of the local landfill site at Dompoase and daily
records are kept of the vehicles and trucks that were bringing waste to the site.

2.4 Sector service delivery

2.4.1 Waste collection and transport

Service quality and equity

The role and configuration of private sector primary waste collection services varies
across Ghana. Large urban centres, such as Kumasi, present more dynamic competitive
environments that, in turn, support innovation and the development of smart governance
models among service providers and local government alike. Such dynamism and
innovation is not common in other MMDAs.

• Primary (door-to-door) collection: National and local authorities do not effectively zone
and govern formal, primary service provision. A basic principle of effective municipal
zoning for SWM service provision is the requirement that a licensed and zoned service
provider serves all properties in their respective zones. This is not happening in Ghana.

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National Solid Waste Management strategy for Ghana

• Communal collection: The minimum level of services prescribed by the NESSAP for
communal collection is not met by any of the MMDAs, and analysis provided under the
SIP is woefully inadequate based on the skip per population standard used. The
placement, density, and condition of transfer stations (in this instance, skips) is not just
an issue for households but is also important for small-scale service providers. If these
are not conveniently placed or if they are frequently full, then service providers are more
likely to practise crude dumping and fly-tipping, which cause a deterioration in
environmental standards, the local economy, and overall public health.

Cost recovery

In Ghana the cost recovery prospects for collection and transport service providers vary by
scale and type of provider operations; specifically:

• Small-scale informal service providers (e.g. unregistered ‘Borla Taxis’ and waste -
pickers) can operate a commercially viable business because (i) there is considerable
demand for their services, (ii) the financial barriers to market entry are low, (iii) the user
fees payable can be negotiated on demand, and (vi) they can avoid municipal levies.
However, their informal status acts as a considerable disincentive to scale, meaning
most providers will likely remain individualistic in an invisible, tax-free economy, reducing
the prospects for competition amongst medium-scale providers or contributions to public
funds.
• The medium- and large-scale formal collection and transport providers which exist
sometimes operate a profitable business based on existing user fee-fixing, but their
inability to draw upon legal support services from government or to receive commitments
from government for formal, legally watertight contracts also makes such investments
risky and unattractive. The lack of commitments from government in regard to issuing
legally binding contracts appears to be deliberate so that they do not undermine or pose
any threats to large PPP arrangements (e.g. via the SIP).

These constraints cannot be divorced from existing institutional arrangements at

national level, which limit MMDA autonomy of financing and decision making regarding
SWM. MMDAs cannot, for example, easily provide multi-year contracts to medium-sized
service providers, as if these service providers scale their operation, they may have an
impact upon sensitive and largely hidden PPP arrangements associated with the SIP.

2.4.2 Waste disposal

A large proportion of the final waste disposal sites in the country are not managed in
a safe, secure, or effective manner. In most cases dumpsites are managed, or at least
maintained, by a private contractor procured by the MMDA. However, the credibility of this
procurement and oversight of eventual implementation is limited by low levels of competition
and technical knowledge and capacities within MMDAs. The result is that none of the
dumpsites and landfill sites in Ghana can be properly classed as ‘sanitary engineered
landfills’, as defined by United Nations/GIZ standards. In addition to the open burning that
takes place at dumpsites, landfills are often prone to fire outbreaks. This situation presents
public health and environmental risks, particularly for children. In addition, seemingly
unjustifiable fees are levied to government for services and infrastructure that in some cases
do not exist/were never rendered (e.g. broken weighbridges, top-soil operations that are not
conducted).

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National Solid Waste Management strategy for Ghana

Table 2: Assessment of functional status of selected landfill / dumpsites in Ghana

Status as defined by United Nations/GIZ
MMDA
descriptors1
Engineered landfill (with characteristics of
Greater Accra (TMA, ASHMA, AMA) – Kpone2
uncontrolled dumpsite)
Greater Accra: Shai Osukodu District Assembly –
Uncontrolled dumpsite
Dodowa Dumpsite
Eastern: Asuogyaman District Assembly – Juapong Uncontrolled dumpsite
Central: Effutu Municipal Assembly Semi-controlled dumpsite
Volta: Ho Municipal Assembly Uncontrolled dumpsite
Upper East: Bolgatanga Municipal Assembly Uncontrolled dumpsite
Engineered landfill with operational
Northern: Tamale Metropol itan Assembly – Gbalahi
characteristics of semi-controlled dumpsite
Western: Sekondi Takoradi Metropolitan Assembly – Engineered landfill with operational
Essipong characteristics of semi-controlled dumpsite
Engineered landfill (with characteristics of
Ashanti: Kumasi Metropolitan Assembly – Dompoase
uncontrolled dumpsite)

Waste recycling, re-use, and recycling

The ‘3R’ value chain in Ghana largely consists of fragmented and organic informal sector
and SME activity, which is constrained by fiscal, tax, and structural challenges to scale and
profitability. The key challenges include the following:

• A weak international market for recyclable commodities: Recyclers face a host of

challenges that are, in reality, based on external/international factors (e.g. a low price of
crude oil).
• A lack of incentives means that the recycling sector is not commercially attractive
to the private sector: The absence of advanced recyclers in Ghana demonstrates that
prospective recyclers cannot operate sustainably without public subsidy or a more
conducive tax environment.
• Prevailing household knowledge and behaviours are not conducive or aligned to
recycling principles.
• The informality and lowly status of waste-pickers means that existing recycling
activities comes with substantial health and safety risks.

1 GIZ (2013) ‘Operator Models. Respecting Diversity. Concepts for Sustainable Waste Management’.
2
In August 2019, the Kpone landfill caught fire and continued to burn for six weeks, causing the landfill to be
closed down.

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National Solid Waste Management strategy for Ghana

Box 4: The unseen cost of waste recycling in Ghana

The informal recycling sector in Ghana is dominated by waste-pickers working at dumpsites across
the country. Although waste-picking is an extremely common practice, waste-pickers operate
entirely outside the regulatory framework or duty of care of local or national government—existing in
an invisible economy, with little legal or physical protection.
Waste-pickers constitute some of the most vulnerable and marginalised groups in Ghana and
practise a dangerous and arduous form of work. A large proportion of waste-pickers are women and
children, many of whom are economic immigrants from neighbouring countries. These people are
particularly vulnerable to the physical, environmental, and social risks inherent in Ghana’s poorly
managed dumpsites.
Movements to formalise and help coordinate waste-pickers are becoming increasingly common
globally, and light organisational structures have already been put in place at the Kpone Waste-
Pickers’ Cooperative in Accra, the city’s largest landfill. However, this has not been reflected across
the country and such initiatives are poorly supported by the Government of Ghana and the private
sector. Adopting simple measures to recognise, train, and equip the informal sector with basic
personal protective equipment, for example, can help the Government of Ghana to more effectively
harness the collective influence of waste-pickers operating across the country.

2.5 Behaviour change communication

Ghana does not possess clear, coordinated, or coherent behaviour change strategies
for SWM behaviour change communication (BCC). This lack of coordinated thinking has
led to high levels of inconsistency in messages, which likely undermines the prospects for
effective and sustained behaviour change. A BCC strategy was developed for urban liquid
waste management in 2010; this has some useful information on overall BCC options, but
does not specifically deal with SWM.

On a piecemeal basis, national and local stakeholders (government, civil society

organisations, the private sector, and others) have explored a variety of different
types of BCC channels, with seeming limited success. Symptomatic of the limited
strategic planning around BCC is the paucity of data or evidence on (i) the efficiency,
effectiveness, and cost of different approaches, and (ii) the strategic goals of different BCC
interventions, i.e. who constitutes the target group and what are the behaviours being
targeted. This lack of M&E and the poor articulation of intervention theory severely
constrains rigorous analysis of the effectiveness of existing approaches.

In all cases, without the provision of basic facilities like bins and minimum service provision
BCC will be ineffective as people will tend to fall back on the most convenient way of
discarding waste. It is therefore important that government and MMDAs should also
recognise the need to provide household and communal bins, as well as skips, to go hand in
hand with the behaviour change initiatives.

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National Solid Waste Management strategy for Ghana

3 Strategic priorities
3.1 Overview
This SWM strategy provides strategic solutions to address the challenges identified in the
situational analysis. Overall, the strategy recognises that improvements in sector service
delivery will only be achieved through coordinated action by the government, municipalities,
development partners, and the private sector. As such, the strategy is organised around
seven interdependent pillars of action, all of which require attention if improvements in SWM
services are to be realised. These pillars are as follows:

• Pillar 1: Strengthen sector governance.

• Pillar 2: Increase private sector participation.
• Pillar 3: Optimise service delivery and infrastructure.
• Pillar 4: Create positive social action on SWM.
• Pillar 5: Enable effective waste recovery, re-use, and recycling.
• Pillar 6: Ensure effective sector M&E.
• Pillar 7: Establish sustainable sector financing mechanisms.

3.2 Pillar 1: Strengthen sector governance

The situational analysis presented in Section 2 highlights the key issues of sector
governance that need to be addressed to create a supportive enabling environment for
SWM. The challenges and the proposed strategy to address the challenge are presented in
the table below.

Current situation/challenge Strategic entry point

Proactive harmonisation and
Sector policies from different ministries are not well
convergence of sector policies and
aligned and implementation of policy is a challenge at all
guidelines

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National Solid Waste Management strategy for Ghana

Current situation/challenge Strategic entry point

levels. The timeframe for some strategy documents for
the sector is outdated
A complex sector governance structure, with fragmented
Facilitate the alignment and coordination
and occasionally overlapping responsibilities across
of key stakeholder institutions
national- and sub-national-level agencies
Create a platform for inter-ministerial
Poor coordination of sector planning and implementation
coordination and inter-MMDA
to capitalise on evident political will
coordination
Inefficient supervision on service performance remains a
Strengthen regulation and oversight of
serious threat to the efficient and sustainable
service delivery
management of SWM
Establish mechanisms for specialist
technical assistance (TA) to support
Inadequate levels of capacity to deliver services
local-level SWM planning, budgeting and
finance, and governance

3.2.1 Harmonisation of sector policies and guidelines

In order to achieve results and make significant gains in the sector there is an urgent
need for cohesion and convergence of policies, whereby various policies speak to
and complement each other. Priority areas of harmonisation include the following:

• Ensuring mechanisms for extended producer responsibility profiled in the Draft Plastics
Waste Management Policy are mainstreamed within the Environmental Sanitation Policy,
with clear plans for implementation.
• Align waste to energy plans, which are currently part of the NESSAP, with the National
Energy Policy.
• Create strategic linkages between the 2012 Environment Policy and the NESSAP on the
issue of source separation.

Currently, these policies and strategies are not linked because they are situated within
different ministries. The convergence and alignment of these national-level priorities would
constitute an important step towards a comprehensive framework for SWM that is
progressive and aligned with modern practices in waste management and recovery.

There are considerable opportunities for policy revision and harmonisation in the
short term. MSWR intends to revise the current Environmental Sanitation Policy and this
provides an opportune entry point to consolidate and bring cohesion to the national-level
policies. The revision of the Policy should identify all progressive and current good practices
in waste management, identify the existing policy documents which already refer to these,
and add an integration section at the end of the Policy to show the linkages.

In combination with policy alignment there is a need for the Government of

Ghana/MSWR to ensure internal and external accountability for policy implementation
and effectiveness. Beyond the development of policy, the government should ensure that
implementation guidelines are developed to support the achievement of policy goals. The
cost of policy implementation should be determined (see Section 3.2.5) and included in the

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implementation framework. Finally, government must ensure that adequate resource and
financing are provided for policy implementation.

3.2.2 Alignment of key stakeholder institutions

National level

The roles of key sector players, particularly line ministries and sector agencies,
should be clearly defined and aligned to avoid duplication of roles. An important first
step will be the clear mapping and allocation of functional responsibilities across national,
regional, and district-level administration, which, ultimately, can be used as a basis for
defining new policy measures and directives with effective institutional capacity, potentially
through the enhanced roles of MLGRD and MSWR in their support to local agencies, and
potentially a role for RCCs (subject to legislative review and resourcing, as outlined below).

Alongside mapping functional responsibilities, it is equally important that the

institutional arrangements and linkages among agencies are clearly defined. This can
be effectively captured in an organogram illustrating the relationship among government
agencies, service providers of different scales and complexity, and other stakeholders
across the SWM service delivery chain. The organogram would focus on the linkages across
and within institutions and the associated reporting and accountability mechanisms and
structures.

The Government of Ghana has recently announced plans for the establishment of a
dedicated National Sanitation Authority (NSA) and Fund. To ensure the effective
operationalisation and functionality of the NSA, we recommend that MSWR should interface
with the relevant government institutions for the establishment of the appropriate structures
and institutional framework of the NSA within the current government machinery, to ensure
effective delivery. We further recommend that the NSA should be adequately resourced to
ensure that it can deliver on its mandate. In line with this, the establishment of the Fund
alongside the NSA is welcome.

Local government level

Key to strengthening operational governance at local government level is the

availability of resources and support for local authorities – achieving this will likely
require legislative change. Investing in specialised technical capacity in each urban MMDA
would be unaffordable and inefficient, especially when compared with proposed investments
in technical specialists (e.g. public health engineers) based at the RCC to provide oversight
and support to multiple MMDAs. At present, RCCs do not have the mandate for waste
management (as per Act 936), and RCC staff often lack experience in SWM. As such,
enhancing the role of the RCCs will require legislative review and resources for engaging
specialised staff.

It is also critical to define clear roles and guidelines for improving governance and
oversight arrangements within MMDAs. The process for the establishment of WMDs
provides an entry point for some of the recommendations. As such, local government
operations guidelines and manuals must be updated to provide specific, tailored operational
guidelines on:

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National Solid Waste Management strategy for Ghana

• procurement and contracting for SWM;

• supervision of SWM service providers and monitoring of SWM service delivery; and
• the cost structure for waste management.

3.2.3 Sector coordination

National level

An inter-ministerial coordination committee for sanitation (and by extension SWM) is

required to enhance sectoral coordination, as well to force urgent actions to be taken
to improve SWM. As noted in Section 2.3.2, there are currently a number of ministries with
varying responsibilities, and sometimes duplicating roles, for the management of solid
waste. Given that all of these ministries are of equal importance at the executive level, it is
critical to effectively build synergy across the different ministries for the delivery of
environmental sanitation (including SWM). Furthermore, given the ramifications of poor
sanitation and SWM, it is important to elevate the issue of sanitation beyond the usual
rhetoric, to give it the needed attention.

Establish an inter-ministerial committee to be formed for SWM (or, more broadly

speaking, sanitation) under the office of the President or Vice President. To drive
change in the sector, SWM may be considered as a national emergency and, in that vein, as
a national priority for action. This would reflect the urgent need to address environmental
sanitation and associated public health challenges, and also given the vision that the
President of Ghana has espoused for waste management.

The inter-ministerial committee should be seen as an interim, temporary measure.

This structure will make way in the longer term for the National Environmental Sanitation
Policy Coordinating Committee. This committee, which was proposed by the 1999
Environmental Sanitation Policy, should be revamped to take on the longer-term
coordination activities, given that it has co-chairing arrangements across the different
ministries, departments, and agencies. Furthermore, it will be prudent to have a National
Environmental Sanitation Policy Coordinating Committee secretariat established within the
NSA to ensure continued engagement of the relevant stakeholders in the long term.

Local government level

At the local government level, a joint development board is required for MMDAs
within a conurbation, e.g. Greater Accra or Greater Kumasi Area etc. The concept of
‘assemblies without borders’ is currently being practised in some urban MMDAs. To make
this structure more permanent and to anchor it in law, these assemblies without borders
could be formalised to become joint development board, with an appointed joint
development committee. Provision for the establishment of such a structure exists in Act 936
– Section 31. (1), which states: ‘A District Assembly may appoint a joint committee with
another District Assembly for a project in their mutual interest and may delegate a function of
the District Assembly related to the project to the committee.’

A joint development board is likely to be most effective in instances where MMDAs share
common infrastructure, such as treatment plants. could also be a means of pooling together

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National Solid Waste Management strategy for Ghana

resources, especially financial resources, for solid waste delivery. This will be of particular
benefit to smaller MMDAs which are not able to raise as much revenue as the large ones.

3.2.4 Regulatory framework and regulation of service delivery

Sector oversight and regulation must be guided by a well-defined and consolidated

regulatory framework. This framework would provide a basis for procurement, contracting,
monitoring, and supervision of service providers in all aspects of the waste management
chain. Regulatory measures to control the functions of waste management are critical to
ensure adequate service delivery in SWM. The extremely limited and ad hoc oversight of
service provider performance is a major weakness of existing service delivery. The
underlying reasons for this are complex and have roots in issues of local government
capacity and resources, personal and professional incentives, and hidden interests;
nevertheless, a major contributing factor is the absence of a common framework outlining
how oversight is to be exercised, with roles and responsibilities. At the time of writing, it is
clear that MSWR intends to consolidate all key legislation on sanitation and waste
management into one document. While this is a step in the right direction, it is important to
ensure that this law is underpinned by a well-defined regulatory framework. Some of the
issues that could be considered by this regulatory framework are:

• registration and licensing of service providers;

• the requirements of service providers (e.g. the requirement of providers to actively
engage in 3Rs not as corporate social responsibility but as an integral part of their
service provision);
• regulation of the siting, construction, operations, and maintenance of major sanitary
infrastructure;
• the process of setting and approval of tariffs and tariff collection (a formula could be
indicated in the act);
• service quality and expansion;
• service equity issues; and
• environmental protection.

The regulatory framework should also define the mechanisms for enforcement. This
will be useful for oversight and supervision for private service providers and also for PPPs.
Discussions with the officials of MSWR suggest that the yet to be established NSA will play
the role of a single formal regulatory body for the management of waste in the country. A
stakeholder consultative process will help to consolidate the issues to be considered. The
rules and regulations could be consolidated into a Solid Waste Recovery and Disposal Act.

Ensuring an increased focus on environmental regulations. MMDAs intending to set up

waste treatment or disposal facilities will benefit from a guidance document that outlines
what EPA permitting processes and environmental impact assessments are to be
conducted, particularly for projects that have a high environmental impact. As noted in
Section 2.3.1, while there are comprehensive policy documents, some MMDAs may not be
sufficiently aware of these. We recommend that MSWR engages with the EPA to build
capacity for the MMDAs in environmental assessment regulations and processes.

Some documents that MMDAs should be engaged with include:

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National Solid Waste Management strategy for Ghana

• Ghana’s Environmental Policy (2012);

• Environmental Protection Agency Act, 1994 (Act 490);
• Environmental Assessment Regulations 1999 (LI 1652); and
• Ghana Landfill Guidelines, 2002.

Furthermore, the current gazetted fee regime may be prohibitive for investment and will
require review, particularly for MMDAs making investments in final disposal facilities. We
recommend that MSWR collaborate with the EPA to improve the processes that the MMDAs
have to follow to receive environmental permits for much-needed waste treatment facilities.

3.2.5 Capacity building

It is imperative to address capacity gaps through the establishment of WMDs at the

municipal level and by resourcing existing WMDs at metropolitan assemblies. The
institutional capacity to govern SWM is limited and this is widely acknowledged as a critical
gap. Addressing this gap requires a commitment to bring staff numbers to the levels
prescribed by the OHLGS. In addition, it is necessary to tighten up the criteria for the
recruitment of public health engineers to WMD roles. At present, such roles are open to
those without waste management experience, training, or qualifications.

Specialised capacity building will be rolled out for key staff at the different levels. This
requires the revision and enhancement of current training programmes under the scheme of
service, to include specific training for landfill management and supervision. Moreover,
current or potential managers of landfills and treatment facilities in the MMDAs require
support to undertake professional and specialised courses in landfill management. MSWR
should lead the development of a capacity building programme, in conjunction with the
OHLGS.

Financial resources for the MMDAs are discussed in detail under Pillar 7. The availability of
financial resources is critical and is linked to providing equipment for the MMDAs. Currently,
some equipment is being provided under the SIP programme. This could be reviewed to
provide adequate levels of equipment for each of the MMDAs.

3.3 Pillar 2: Increase private sector participation

This section of the strategy draws heavily upon recent and relevant primary and secondary
data that indicate that working to improve cost recovery mechanisms is key to
strengthening the enabling environment of Ghana’s waste management, recycling, and
recovery value chains. It also argues, strongly, that the private sector can never effectively
participate in service provision so long as the inclusion of informal actors, including
waste-pickers and Borla Taxis, is not recognised, or more systemically engaged with, by
national government.

The overarching recommendation is that the government ensure that sector

institutions, policies, and regulations for private sector participation are realigned to
promote healthy competition and to reduce barriers to entry for the private sector.
The provision of quality SWM services across Ghana is a basic public utility right, but largely
operates in an organic and uncoordinated manner. Supporting an enabling environment that

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National Solid Waste Management strategy for Ghana

provides conducive investment and operational conditions for prospective and existing solid
waste service providers is key to promoting and increasing private sector participation
across the sector.

Current situation/challenge Proposed strategy

Introduction of ‘price-inflated’
fee bands to co-subsidise and
• Current fees in the gazetted MMDA fee-fixing resolutions do finance a number of
not effectively generate funds for cross-subsidising SWM
investments, with the aim being
service provision in Ghana.
to increase private sector
engagement.
The elimination or temporary
• Prospective and existing service providers are responsible for waiving of specific applicable
paying the same VAT, import, and licensing taxes and fees as taxes, fees, and licensing
any other business type, despite indirectly helping government
costs, levied on service
to provide a basic public utility service.
providers.
• Low-income areas receive fewer choices and poorer service
standards.
• Fragmentation in service provision contracts for related
activities (beautification, street sweeping, waste collection) Equity in private sector
leads to poor evaluation and zoning support from local participation (standardised
authorities. procurement, evaluation, and
• A lack of standardised procurement guidance and contracting zoning support).
incentives within and outside the SIP provides some private
sector stakeholders with large market advantages, preventing
healthy competition.

3.3.1 Cost recovery mechanisms and governance

National government to promote dynamic cost recovery mechanisms that improve the
prospects of cost recovery for public and private service providers.

• Government to introduce a special ‘price-inflated’ fee band, levied on large waste

producers (e.g. hotels, shopping malls, and commercial districts). Revenue from
this fee band to cross-subsidise service
with the aim being to increase private sector engagement in less popular consumer
sectors of the SWM sector (e.g. services in poorer areas, recycling services).
Determining the rates and conditions of the new fee band will require discussion and
consensus among MMDAs (and where present, WMDs), as well as among policy,
enforcement, planning, health and environmental officers, and those responsible for
regional oversight, through the RCCs.
Determining the roll-out and implementation plan for the special fee band will require
discussion and engagement with Ghana’s public, private, community-based, and
informal service providers.
• Government to eliminate or temporarily waive specific applicable taxes, fees, and
licensing costs levied on service providers. The enhanced tax and licensing
environment will reduce the administrative and cost-related barriers for new investments
and scaled business services across the sector.
Rationalisation or waiving of VAT that is applied on SWM services.

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National Solid Waste Management strategy for Ghana

Rationalisation or waiving of import taxes and charges for equipment and vehicles
destined for use in solid waste service provision.
Rationalisation or waiving of application, licensing, and business fees levied by local
authorities for prospective service providers.

Tailoring regulations for the importation of different goods and products is essential
to ensuring Ghana’s private sector is able to source necessary technology and equipment
for beneficial waste recovery and recycling operations. Developing countries like Ghana are
reliant on imports due to a weaker local manufacturing sector, lower access to skills and
finance, and stronger export markets elsewhere (Europe, America, and China etc). Building
on this point, MSWR, working in collaboration with MESTI, could develop guidance on
specific types of imports that do not compete with local industry, such as advanced waste
recycling machinery, and seek to waive or ease the tax and administrative burden of
importing such equipment into Ghana.

3.3.2 Inclusive SWM and recognition of the role of the informal sector in
SWM

National government to lead efforts to recognise, formalise, and support the considerable
collective influence of the informal economy in SWM service provision and waste recycling
and recovery activities.

• National, regional, and local government agencies to publicly recognise and

commend the role of waste-pickers and informal Borla Taxi operators in print and
media campaigns, to set the precedent that informal waste management and recycling
activities are welcomed and beneficial for the wider waste collection and recycling value
chain.
• National government to provide basic, government-issued ID cards for waste-
pickers and informal Borla Taxi operators to collect valuable data on the size, scale, and
characteristics of this informal economy.
• National government to integrate an Occupational Health and Safety (OHS)
standards directive for the wider SWM and recycling value chain. Upon launching an
OHS strategy for the wider sector, national and regional government can employ a
measured effort to equip waste-picker cooperatives and informal Borla Taxi operators
with basic personal protective equipment (e.g. municipal branded overalls) and training
(e.g. on waste segregation techniques).

3.3.3 Promoting equity in private sector participation

National government to ensure wider equity in private and public service provision and
procurements.

• Government to provide standardised procurement and evaluation guidelines for

SIP and non-SIP opportunities that are tailored to a wide selection of different
corporate, SME, and community-based contractors across Ghana. Formal guidance
and opportunities that are appropriately positioned for smaller, localised service
providers across Ghana will increase service quality and equity in lower-income areas
and support healthier competition across the value chain.
Government to lead a robust stakeholder mapping and consultation process to
identify and determine the varying capacity of prospective and existing service

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National Solid Waste Management strategy for Ghana

providers across Ghana. Such efforts to be led in partnership with well-established

representative bodies in the sector, such as the ESPA.
Standard rates payable to contractors and related incentives (e.g. bin distribution
programme), for SIP and non-SIP services will be defined and publicly
communicated, to allow for fair and transparent competition among prospective and
existing service providers.
Robust, independent, and transparent evaluation criteria to be presented to
prospective and existing service providers, underpinned by measurable indicators
and scientific data (further discussed under Pillar 6).
• Government to zone service delivery areas that require service providers to
provide comprehensive SWM services, including skip management, street
cleaning, and beautification. Comprehensive SWM contracts will ensure easier
monitoring and measurement of service provider performance and will eliminate
confusion on where roles and responsibilities lie in regard to any waste challenges within
the zone.
Government to conduct a consultative process to determine what services will be
included under SWM contracts (including street and drain cleaning, beautification)
and the cost recovery model that will be applied to each service (e.g. user fees,
public subsidy for public cleansing).
Comprehensive SWM and public cleansing contracts to further inform revised M&E
strategy (further discussed under Pillar 6).

3.4 Pillar 3: Optimise service delivery and infrastructure

This section of the strategy draws heavily upon recent and relevant primary and secondary
data that indicate that working to improve approved sanitary and waste transfer
infrastructure sites and leveraging private sector investments through PPPs is key to
strengthening the enabling environment of Ghana’s waste management, recycling, and
recovery value chains.

The overarching recommendation is that the government ensure that existing and
proposed waste management, transfer, and recovery infrastructure is strategically
and equitably distributed, and that it is supported by smart PPP frameworks. The
equitable and strategic distribution of waste transfer assets is essential to supporting service
provision among public, private sector, community-based, and informal-based waste
collectors, and furthermore, inherently attracts and supports investments in waste recycling
and recovery activities. This waste transfer infrastructure, most commonly skip sites,
provides the foundation for the provision of waste services in lower-income settlements, by
Ghana’s smallest waste collectors. While higher-income service provision can always price
larger distances into the cost model the ability to provide affordable services in lower-income
settlements is a key policy objective.

3.4.1 Leverage private sector investment and expertise through appropriate

PPPs

Government to lead the drive for infrastructure delivery through considered use of PPPs.
This will include an emphasis on strengthening the transparency of how PPP models are
designed and implemented to ensure value for money.

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National Solid Waste Management strategy for Ghana

• MSWR to develop guidelines for PPPs (based on the PPP bill, while still being
tailored to suit the needs of SWM).
The guidelines will provide directions on how to respond to unsolicited PPP
proposals.
The guidelines will provide a framework for the systemic assessment of proposals.
For solicited PPPs MSWR will outline and prepare a list of all projects that require
investment (similar to Ghana Water Company Limited (GWCL) SIPs), showing the
projected cost etc.
At the local level, a guidance document for procurement and assessment of service
providers will be developed for the MMDAs.
• Clarify, rationalise, and ratify all existing PPPs that do not have clearly defined
contracts and terms of engagement to ensure fairness for both the private sector
investor and the government.
Government to ensure that modern facilities financed by PPPs are not underutilised
and are clearly defined in existing contracting modalities.
Government to ensure the presence of an appropriate tariff scheme to ensure that
the right prices are paid for services while service quality is regulated.
Government to request that potential investors in the SWM value chain submit both
technical and financial proposals for vetting, benchmarked against international best
standards.
As noted in Section 3.2.4, an appropriate regulatory framework is essential to support
the delivery of service through the private sector. A regulatory body similar to the
Public Utilities Regulatory Commission (PURC) could be set up to regulate and
harmonise the tariff-setting mechanisms.

3.4.2 Strategic spatial planning of transfer infrastructure

Government to undertake a strategic spatial planning and mapping study to reposition waste
transfer infrastructure and zone these sanitary sites through the Land Use and Spatial
Planning Authority (LUSPA).

• National government will promote scientific, evidence, and systemic backed

spatial planning of public waste management, transfer, and disposal infrastructure
and assets to ensure the effective allocation of infrastructural assets.
Assessment of MMDA-controlled waste transfer assets: The quantification,
indexing, and assessment of the standard, quality, and condition of waste transfer
infrastructure held by MMDAs. This can be achieved by mapping of the various
sanitary sites and disposal sites in order to optimise their usage, to avoid
‘overcrowding’ or ‘scarcity’. A pre-designed mechanism will facilitate requests for
supplementary skips and waste transfer assets where an MMDA does not meet skip
to population/area directives.
Redefining the category of service delivery based on population density: This
approach forces private sector collectors to focus on an area or locality to which their
equipment is well suited. The various MMDAs can limit the use of the Borla Taxis to
collect waste from densely populated areas to be transported to a ‘waste transfer
site’ akin to a sanitary site for onward lifting by the compactor truck. In this way, the
issue of fly dumping by the Borla Taxis can be curtailed.

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National Solid Waste Management strategy for Ghana

GIS zoning and strategic spatial planning of waste transfer assets: A rigorous
study to indicate the appropriate level and quantity of resources that each
MMDA/WMD requires to meet national indicators/requirements for skip to population
and area ratios.
Determination of whether current MMDA-controlled waste transfer assets meet
directives on skip to population and skip to area ratios. These could either be defined
by the SIP or national government, or via consultations with GIS and engineering
specialists in Ghana or academic institutions, or based on international guidance.
Procurement and placement of new waste transfer assets: Financial or material
support from the national government to ensure that local MMDAs/WMDs have
sufficient internal resources to ensure skip ratios are adequate based on local
population and areas.

3.5 Pillar 4: Create positive social action

Future approaches to BCC in SWM will embedded within a coherent strategic
framework, adhering to the following principles:

• Giving disproportionate attention to legislative approaches, such as legal enforcement, is

ineffective and potentially inequitable if it is not combined with the provision of
accessible waste facilities (public bins, skips, and carts) and affordable services.
• To the extent possible the design and implementation of BCC approaches will be
informed by evidence and defined strategic objectives:
the channels and mechanisms of BCC will be tailored according to target audiences
– segmenting approaches by low-, middle-, and high-income households,
commercial businesses, and service providers; and
the aims, objectives, and target behavioural outcomes of specific BBC initiatives will
be stated before implementation, to enable monitoring, learning, and accountability
• BCC will be implemented through a mixture of channels, leveraging, where
appropriate, the use of increasingly prevalent communication channels – particularly
social media. This recognises that both traditional approaches, such as messaging
through local radio and town hall meetings, and more modern approaches, such as
leveraging social media ‘influencers’, can be extremely cost-effective ways of reaching
different audiences.
• The impact and cost-effectiveness of all BCC approaches can be improved if they are
implemented in a coordinated manner as part of an overarching behaviour change
strategy – led by MSWR and supported by a specialist communication agency. It is
envisaged that this strategy will involve the following:
Define key behaviours and messages for segmented stakeholder groups across the
country, ensuring messages are consistent, coherent, and integrated with parallel
initiatives – whether enforcement measures, private sector outreach, or the provision
of infrastructure. It is expected that messages will be simple, powerful, memorable
and targeted. Example slogans are ‘reduce your waste’ and ‘use a bin’.
The Environmental Health and Sanitation Directorate of MSWR and the proposed
NSA should, in collaboration with the National Commission for Civic Education
(NCCE), coordinate solid waste-related BCC messaging and activities to ensure
coherence and sustainability.
Ensure that bins and communal facilities are progressively provided in areas where
household waste collection is not feasible.

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National Solid Waste Management strategy for Ghana

Establish a private sector and civil society platform at national and regional levels to
periodically assess and evaluate BCC programmes on SWM.

3.6 Pillar 5: Enable effective waste reduction, recovery, and

recycling
Government to provide and stimulate key tax policy, cost recovery, and co-
investment measures to influence the uptake and scaling of 3R activities across
Ghana. Sustainable and integrated SWM practices are rooted in the diversion of waste from
landfill and the integration of resource recovery into waste management practices. The
design, provision, and strengthening of incentives that influence and increase waste
reduction, recovery, and recycling activities across Ghana will set a benchmark precedent
that promotes and increases private sector engagement and participation in these
sustainable activities. It will also ensure that the government is able to operationalise its own
policy on MINT.

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National Solid Waste Management strategy for Ghana

Current situation/challenge Proposed strategy

National government currently • The introduction of a special ‘price-inflated’ fee band,
provides limited support to the levied on large waste producers (e.g. hotels, shopping
existing or prospective investors in malls and commercial districts) and ring-fenced to
the waste reduction, recovery, or support recycling activities.
recycling sectors. • National government to conduct an objective
examination of import/export, and VAT tax measures, to
waive or reduce these charges for recyclers.
• The provision of timely subsidies or the promotion of
insurance products that partially cover the loss in
revenue of the recycling sector.
Tightly controlled PPP arrangements
• National government to design, construct, and manage
on waste valorisation infrastructure
public, light infrastructural waste valorisation assets for
arguably favour a small, non-
stakeholders operating at various scales within the
inclusive group of stakeholders,
recycling value chain, to expand their activities and
limiting the number of SMEs entering
capacity to valorise waste recyclables.
the advanced waste recycling sector.
Waste-pickers and informal waste • Government-sponsored establishment of WIEGO-
recyclers are currently unrecognised backed national and local waste-pickers’ cooperatives.
by government and receive no • Integration of basic OHS standards for the waste
support—despite representing the management and recycling sector through ongoing
largest waste management and support to waste-pickers cooperatives such as WIEGO.
recycling stakeholder group in
• Provision of basic personal protective equipment,
Ghana.
training, and marketing resources to support integration
and inclusion of waste-pickers in the waste management
and recycling value chains.
• A conscious effort should be made to create a database
of all players in the informal sector.

3.6.1 Dynamic tax instruments to enhance cost recovery

Government to provide and stimulate key tax policy, cost recovery, and co-investment
measures to influence the uptake and scaling of 3R activities across Ghana.

• National government to introduce a special ‘price-inflated’ fee band, levied on large

waste producers (e.g. hotels, shopping malls, and commercial districts). These fees
would be designed similarly to those applied to large waste producers (Pillar #2) but
would be ring-fenced to directly support recycling activities.
Determining the rates, conditions, and implementation plans for such a fee band
would require consistent stakeholder consultation and consensus, as outlined under
Pillar #2. The evaluation and stakeholder consultations may determine that the most
appropriate method of selecting cost recovery options is through a dedicated,
independent body, such as a Tariff Regulatory Commission.
One popular method of introducing and streamlining the new fee band would be to
couple/bundle it with other utility charges (e.g. water, electricity, property tax).

• National government to conduct an objective examination of import/export, HS

code, and VAT tax measures currently in place in Ghana, to identify a number of tax
relief or waiving measures that will support recycling activities, while setting the important
precedent, by government, that sustainable waste recycling activities are desirable and
invited.

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Government to eliminate import tax bands, payable on equipment, vehicles, or assets

that are destined for a 3R activity. The Government of Ghana to set up a mechanism
that facilitates the import of these assets to influence further uptake of 3R activities.
Government to waive VAT payable on valorised or recycled products.

• Government to promote subsidies or directly provide insurance products that

partially cover the loss in revenue of the recycling sector.
Design and promotion of index insurance products that cover losses in the recycling
sector when commodity pricing for recyclables deviate below a pre-defined threshold.

3.6.2 Construction of public, free-to-use recycling stations to valorise

recyclable commodities

National government to design, construct, and manage, public, light infrastructural waste
valorisation assets for stakeholders operating at various scales within the recycling value
chain, to expand their activities and capacity to valorise waste recyclables.

• Government to lead efforts related to the allocation of land, light construction of storage
facilities for waste valorisation activities, and simple paving for vehicle access.
• Government to develop an operational plan for the facility (usage base: per Mt
processed vs per hour used). Government will lead robust stakeholder engagement to
determine most conducive and effective operational model.
• Government to lead efforts related to the procurement and setting up of light processing
technologies, including for a vertical baler and plastic shredder, operational in every
MMDA.

3.6.3 Inclusive SWM and recycling value chains / integrating OHS standards
in SWM and recycling value chains

Similar to the entry points outlined under Pillar #2, national government to lead efforts to
recognise, formalise, and support the considerable collective influence of the informal
economy in SWM service provision and waste recycling and recovery activities.

In addition to the previously stated entry points on, the public recognition by national,
regional, and local government agencies of waste-pickers, the provision of basic,
government-issued ID cards for waste-pickers, and the integration of OHS standards
for the wider SWM and recycling value chain. Specific recycling sector tailored entry points
include the following:

• The creation of a recyclers exchange that provides key information on commodity

pricing, tax responsibilities, and open markets for the trade of recyclables.
• The creation of a recyclers’ forum/association that provides a more conducive and
welcoming environment for existing and prospective investors in the recycling market to
meet others in the sector and form collaborations. There is currently a United Nations
Development Programme (UNDP) waste recovery platform that provides information on
all waste recycling activities and stakeholders in Ghana. It will be useful for MWSR to
draw linkages with and information from this platform. The Ghana National Plastics
Action Platform has recently been established by MESTI. It is recommended that MSWR
engage in these knowledge exchange programmes, to ensure it is abreast of the current
state of knowledge in the recycling and waste recovery sector in Ghana.

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3.7 Pillar 6: Ensure effective M&E

National and local-level M&E of SWM is extremely weak and will be a focus of
government action – specifically through commitments to harmonised data management
systems and monitoring of policy implementation, and establishing common key
performance indicators (KPIs) to enable the measurement and comparison of MMDA and
service provider performance. Central to M&E strengthening is the definition of robust SWM
performance, integration of M&E with ICT solutions for cost-effective and reliable reporting,
and the establishment of mechanisms for independent oversight.

This strategy provides a wide range of recommendations for the consideration of specific
M&E indicators to measure service delivery quality and enhance the capacity of existing and
proposed oversight in national and operational government. These tables and resources can
be found in Annex A.

3.7.1 Creation of a harmonised data management system at both local and

national level

Government to establish a National Waste Management Information System and integrate

indicators of solid waste in sector monitoring systems.

• MSWR is currently being supported by the United States Agency for International
Development (USAID)/WALIS project to create a harmonised database for sanitation
and water. A section on SWM information should be created in this database.
There should be coordination between the Research Statistics and Information
Management (RSIM) Directorate of MSWR and the Environmental Health and
Sanitation Directorate (EHSD) to ensure data are regularly updated.

Appropriate SWM data capture systems should be created at the WMDs to collect data for
M&E purposes. MMDAs will be provided with budget and resource allocations for newly
established M&E functions to enable them to provide up to date information for a national-
level database.

3.7.2 Monitoring of policy implementation

MSWR to develop a framework for monitoring policy implementation as part of its policy
review process.

• Government to establish a monitoring framework to ensure effective

implementation of policy.
Design and release terms of reference for the policy review assignment; include the
requirement for an appropriate framework for policy monitoring.
MSWR to mainstream policy monitoring for sanitation either in the RSIM or Policy,
Planning, Budgeting, Monitoring, and Evaluation(PPBME) Directorates of MSWR.
These two directorates will work closely with EHSD to ensure that monitoring is done
at the agreed frequency.
At the MMDA level, newly established structures for M&E at MMDA level (3.7.1) will
be provided with adequate budget and resource allocations.

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3.7.3 Clearly defined KPIs at the operational level

Government to develop service delivery indicators for SWM.

• Government to adopt a structured monitoring framework that measures service

delivery.
M&E for services received by users – quantity, quality, accessibility, an d reliability
over time. These types of indicators are often missing from assessments, such as
District Performance Assessment Tool ( DPAT ). The quality of service received by
users could also serve as a proxy for the performance of service providers
M&E for sector performance of the service authority (MMDAs) – assessment of
planning, coordination, regulatory, supervisory, and support functions necessary to
effectively procure and oversee service provider performance

• Government to adopt KPIs that cover key areas related to improved service
delivery. KPIs considered important to the SWM value chain are indicated below and
are also unpacked in more detail in the annex A.
Generation/collection/transport, including: household-level coverage of SWM
services; efficiency of the collection of municipal solid waste; and the extent of
segregation of municipal solid waste.
Re-use, treatment, and disposal, including: the extent of municipal solid waste
recovered; and the extent of scientific disposal of municipal solid waste.
User perspective, including: efficiency in addressing customer complaints and
grievances (use client service unit at MMDA level as grievance redress mechanism);
and the creation of a short code or call centre that will be used for this service.

3.7.4 Use of DPAT to incentivise performance of MMDAs

Two major recommendations are made under this heading:

1. Government to integrate SWM indicators within DPAT to incentivise performance

of MMDAs

• Government to design and develop a Responsive Factor Grant (as part of DPAT)
to improve performance.
Financial incentives will be linked to performance and delivery in SWM.
Financial incentives could be developed similar to the Sanitation Challenge Awards
for Ghana.
Scoring information will also draw upon existing and new M&E functions led at
MMDA level, such as a DPAT-based assessment on whether MMDAs have a
DESSAP that has been implemented, verified, and approved by the MSWR.

• Validation and verification of MMDA performance in SWM should be done prior to

DPAT assessments. The DPAT is undertaken by external consultants, mainly through a
document review. This limits the ability to adequately assess service delivery through
indicators from the DPAT. The DPAT assessment co uld benefit from the review of
reports that have been validated. For example, rather than checking whether an
assembly has a DESSAP, the DPAT assessment could rather check whether the
MMDAs have a DESSAP that has been implemented, verified, and approved by MSWR.
Similarly, the check for improvements in sanitation and SWM should be approved by
MSWR.

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2. Civil society to provide independent assessment of performance through the

design and development of a score card showing the performance of MMDAs in
SWM.

The development of the score card for SWM will draw upon best practice and knowledge
transfer from the current UNICEF score card for SWM.

3.8 Pillar 7: Establish sustainable financing mechanisms for

SWM
Mobilising and making efficient use of public, private, and household finance is
essential to drive improvement in waste management nationwide. The strategic
recommendation for strengthening sector financing has several dimensions which cut across
some of the sector governance, competition, and capacity issues mentioned in other pillars:

1) Ensure investments in sector governance and oversight are in place to

improve the value for money of existing SWM investments.

- The Government of Ghana is already making significant investments in the sector

through municipal budgets, quarterly allocations from the DACF and central
contracts. However, lack of operational oversight and performance management
of private operators means that collection, transport, recycling, and disposal
services fall well below expected levels.
- More broadly, MSWR/the Ministry of Finance does not have a tailored PPP
strategy or guidelines to support the design of existing and prospective
investments in waste management and recycling value chains. This has
contributed to some PPP being designed without adequate guidance. National
and local government officials are also ill equipped to guide sustainable
investments into Ghana.

2) Review and update the Strategic Environmental Sanitation Investment Plan

(SESIP)3 to establish the existing funding gap and clarify the level of investment
required to address low service coverage rate and the very poor rate of waste
recovery and recycling. This will require appropriate planning, budgeting, and
forecasting based on the life cycle costs of service delivery and supporting
infrastructure and technology. The development of SESIP should actively involve
both the Ministry of Finance and MLGRD.

3) Develop a strategic financing strategy for mobilising funds from identified

sources (including fees, taxes, and private sector investments via PPPs). Specific
measures that have been or could be proposed include the following:

- The ringfencing of taxes and fees for investments in the waste and recycling
value chains.
- The proposed plastic waste recycling fund (proposed in Act 512 but not yet
established). The law provides that the disbursement of this fund should be the
responsibility of MLGRD. However, MSWR could liaise with the Ministry of
Finance to amend this, to ensure that those in charge of waste management will
determine fund usage.

3 The previous investment plan elapsed in 2015.

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- Investments and finances that derive from the newly developed Plastic Waste
Management Policy (2018), which sits with MESTI. MSWR should work closely
with MESTI to ensure these amendments are in place, and possibly to ensure
joint oversight of the plastic fund.

4) Introduce a public levy that can be ring-fenced for investments in the SWM and
recycling value chains – similar to charges and levies for national health insurance
and education. While the introduction of special levies is outside the remit of MSWR,
the ministry can engage with the Ministry of Finance and appropriate parliamentary
select committees to lobby and help inform such policy shifts. Recently, MPs called
for an increase in VAT to deal with waste management4. If this is to be realised, it is
critical that an appropriate fund management structure – similar to the Ghana
Educational Trust (GET) fund secretariats – is established to transparently and
sustainably disburse funds. The MSWR should additionally ensure that appropriate
guidelines are developed for disbursement, so that related ministries understand and
are able to effectively assess prospective investments.

5) Establish a National Sanitation Fund. Officials of MSWR, in addition to the Vice

President, indicated at the Mole 2019 Conference that an NSA and corresponding
fund is to be established in Ghana, with significant scope for addressing SWM
challenges and opportunities across Ghana. There have also been talks of a green
fund that could integrate or align itself with the NSA. MWSR could review existing
and proposed funds and funding streams for SWM and explore how to integrate
them into a consolidated Sanitation Fund. These can all be defined in the SESIP.

6) MMDAs should undertake adequate planning and budgeting for SWM as part of
preparation for the DESSAP. Guidelines would be provided as part of the DESSAP
handbook to support this action. Outputs would feed into existing operational
governance structures, such as the MTDPs and the annual workplans of the
MMDAs. The respective budget should be used as an input for fee-fixing in the
specified year5. Amounts obtained from fees, fines, and other revenues should be
ring-fenced at the assembly level to finance and pay for SWM services (a minimum
amount could be determined).

7) Mobilise funds through public levies though mechanisms such as:

- ringfencing environmental fees (licences, littering fines, new tax instruments) for
investments exclusively in local SWM service provision; and
- bundling of public utility fees to combat citizen apathy and default rates (e.g.
water, electricity, property tax, waste management, sanitation).

4 www.myjoyonline.com/politics/2019/September-11th/npp-mp-proposed-increase-in-vat-to-tackle-sanitation-
challenges.php
5 Guidance for MMDAs to set appropriate fees for cost recovery is discussed under Pillar 2.

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4 Implementation arrangements
4.1 Coordination and phasing
The required actions to strengthen SWM service delivery will need to be implemented
by a variety of stakeholders in a coordinated and phased manner. The prior Section 3
outlined the key strategic priorities for SWM sector strengthening. However, the
operationalisation of these recommendations involves multiple stakeholders and as the
recommendations have a degree of interdependence it is vital that they are sequenced to
maximise impact and effectiveness.

This section provides operational details on the key activities required to implement
identified strategic objectives. To make this information as accessible and practical as
possible, recommendations are organised into those that are most appropriately
implemented in the short term (within a year), medium term (within three years), and longer-
term (over three years), and they are thematically clustered. For each recommendation
additional details are provided on the specific inputs required, the stakeholders responsible,
and likely resources or interdependencies implied.

4.2 Priority actions in the short term

4.2.1 National level

A platform that provides the foundational structure for enhanced inter-ministerial

coordination—helping to align incentives and policy measures that promote private sector
participation in service delivery. This will be complimented by the further development of a
comprehensive institutional framework and organogram for sanitation and waste
management and the expansion of financial and technical support to help establish WMDs in
all MMDAs. Once national and local government institutional structures are revised, a
number of priority actions will also be adopted to ensure adequate data management and to
support new PPPs with SME and corporate partners in the private sector.

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Create platform for inter-ministerial coordination

Objective: To establish a new sect or mechanism which provides a forum for coordinated
action, decision making, and financing for the SWM sector
Strategic alignment: Strengthening sector governance and decision making to lay the
foundation for achieving the President’s mission of improving sanitation across the country
and in Accra specifically
Inter-
Required activities / inputs Responsibility
dependencies
MSWR to submit a policy brief and a cabinet memo for the
establishment of an Inter-Ministerial Coordinating
Committee (IMCC) under the Chairmanship of the Vice MSWR N/A
President or Senior Minster. The Secretariat for the IMCC
should be at the Office of the President/ Vice President.
MSWRto set up a core team to follow up on
operationalising the recommendations in the cabinet MWSR N/A
memo.
Development
Ongoing support and TA to ensure that these
partner / N/A
recommendations and actions are implemented.
UNICEF
Other considerations / implementation risks
N/A

Establish well-resourced WMDs in the MMDAs

Objective: Effectively resource MMDAs and WMDs to ensure efficient oversight and
quality control of service provision in Ghana
Strategic alignment: The National Environment Sanitation Policy states that ‘Waste
management shall be carried out by Waste Management Departments, within Metropolitan
and Municipal Assemblies’. This recommendation seeks to fully implement that policy
recommendation
Inter-
Required activities / inputs Responsibility
dependencies
New WMDs will need to be established through executive
instrument, this will require:
- MSWR to draft a letter, in conjunction with
MSWR Management
MLGRD, in line with Act 936, for the presidency to
establish WMDs in the Municipal and District MLGRD Services
Assemblies. OHLGS Division (MSD)
- The amendment of schedule 2 of Act 936 to
provide the necessary authority for the
establishment of WMDs at the MMDA level.
Supporting the effective operation of newly established
WMDs at municipal level will require:
- updated operational guidelines for the WMDs; OHLGS MSWR
- recruitment and staffing of WMDs; and
- training and orientation for WMDs (e.g. training
and capacity building of a number of public health

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National Solid Waste Management strategy for Ghana

Objective: Effectively resource MMDAs and WMDs to ensure efficient oversight and
quality control of service provision in Ghana
engineers and related staff to be attached to
various MMDAs country-wide).
Other considerations / implementation risks
• Establish mechanisms for specialist TA to support local-level SWM planning, budgeting
and finance, and governance.
• WMDs are established on paper but are not provided with sufficient technical and
financial resources to allow them to perform their role effectively.

Develop a comprehensive institutional framework and organogram for waste

management

Objective: Facilitate the alignment and coordination of key stakeholder institutions

Strategic alignment: Improving operational governance by establishing clearer guidelines

on respective stakeholder roles and responsibility and level of authority at national and
local government – particularly in respect of service delivery oversight and regulation
Inter-
Required activities / inputs Responsibility
dependencies
MSWR to ensure that the same team leading efforts at MESTI
inter-ministerial coordination leads the development of MLGRD
the sector organogram (likely with some form of TA Ministry of
support): Health
- identify the role of key stakeholders and existing OHLGS
overlaps; MSWR MSD
- define clear responsibilities; and National
- organise key informant interviews and focus group Development
discussions with related stakeholders and ministries to Planning
ensure a wide range of views are represented and taken Commission
into account. (NDPC)
Once agreed by the task force, the cross-sector
organogram would be drawn up by the Management
Services Division of the Office of the Head of Civil
Service. In particular, the organogram should draw MSD MSWR
linkages and reporting structures among the national,
regional, and district levels (reporting mechanisms and
structures).
Other considerations / implementation risks
• The political decisions regarding the proposed NSA will have a significant impact on
institutional arrangements in the sector

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Develop a framework for data harmonisation

Objective: Strengthen processes for data collection, processing, and harmonisation to

enable improved sector oversight, and ultimately decision making
Strategic alignment: Supporting ongoing government-led efforts to develop an integrated
‘sector information system’
Inter-
Required activities / inputs Responsibility
dependencies
Extending the scope of work and additional funding for
the ongoing ‘Improving Data Harmonisation within the USAID
MSWR
Ghana WASH Sector’ assignment to consider indicators UNICEF
and data management processes associated with SWM.
Develop a framework for solid waste data capture at both
MLGRD,
the national and district level – defining the frequency MSWR
OHLGS, TA
and type of data to be collected.
Establishing robust processes for the field and remote MLGRD,
MSWR
collection of data relating to newly established indicators. OHLGS, TA
Establishing the newly required capacity to clean, MLGRD,
manage, and articulate data to related departments and MSWR
OHLGS, TA
ministries.
Other considerations / implementation risks
• The existing ODF protocol provides some indicators for SWM to be considered.

Develop appropriate guidelines and procedures for PPPs in waste management

Objective: Strengthen the transparency and probity of decision making around PPPs in
waste management to ensure investments deliver value for money for public and
development partners funding
Strategic alignment: Supporting the optimisation of SWM service delivery and
infrastructure through increased oversight and more considered private sector engagement
Inter-
Required activities / inputs Responsibility
dependencies
Increasing capacity and resources within MSWR to lead
PPP decision making – such as setting up a PPP within
MSWR N/A
the ministry as a counterpart to the similar unit within the
Ministry of Finance.
Identify and clarify funding architecture for existing PPP
MSWR N/A
projects in the sector.
MMDAs,
Develop a list/ inventory of all projects that require MSWR NDPC,
investments (similar to GWCL Strategic Investment Plan).
TA
- Set up a standing committee at MSWR to undertake
Ministry of
initial assessment on the merit of PPP proposals.
Finance/Public
- MSWR (through the established PPP unit) to liaise with MSWR
Investment
the Public Investment Division of the Ministry of Finance
Division
for the evaluation of PPPs.

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National Solid Waste Management strategy for Ghana

Objective: Strengthen the transparency and probity of decision making around PPPs in
waste management to ensure investments deliver value for money for public and
development partners funding
Ministry of
Finance,
Develop guidelines for the assessment and evaluation of
MSWR Attorney
proposals.
General’s
Department
Other considerations / implementation risks
N/A

4.2.2 Operational level

Newly revised and established national structures in the waste management sector will
demand bold actions to be adopted by local regulatory bodies. A framework for enhanced
oversight and reporting functions, similar to the PURC, for example, will be established and
a number of key research and capacity building actions will be explored, through the body,
employing internal TA and an external consultant. Specific outputs of such research and
capacity building measures will include new KPIs and M&E forms, to be used to measure
service provider performance.

Operational-level actions in the short term will also be defined by the strategic and spatial
data-informed placement of waste transfer infrastructure to ensure foundational, public,
waste management infrastructure is equitably distributed for informal, community-based,
SME, and larger private sector actors. Such measures will be complemented by the
establishment of community-based recycling and buy-back centres, to allow smaller and
informal actors to access advanced waste recovery and recycling technologies without
fronting the entry costs. Actions will also address the recognition and coordination of the
informal sector, including through the provision of PPP and basic OHS standards for Borla
Taxis and waste-pickers.

Develop a regulatory framework and regulatory body for waste management

Objective: Strengthen regulation and oversight of service delivery

Strategic alignment: Sector regulation to ensure that service is delivered according to set
standards. This is in line with existing recommendations in policy and the sector’s strategic
action plan
Inter-
Required activities / inputs Responsibility
dependencies
Develop a regulatory framework for waste
management MESTI
MSWR to initiate steps to develop SWM Act – Solid EPA
Waste Recovery and Disposal Act or Solid Waste MSWR MLGRD
Management and Regulations Act – ministry to decide on
title and scope of act – Section 3 of the report proposes OHLGS
some areas to consider. Further study and discussions
required to finalise.

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National Solid Waste Management strategy for Ghana

Objective: Strengthen regulation and oversight of service delivery

Drafting of Act – Consultancy assignment, working in TA – Attorney
concert with the drafting division of the Attorney General’s MSWR General’s
Department. Department
- Set up regulatory body similar to PURC (explore setting
it up as a unit in the PURC or as an independent body).
- Define reporting framework for the designated
regulatory body.
- Regarding the regulatory agency – the government to
study and review options for the set-up of a unit within PURC
PURC or, alternatively, an entirely independent regulator MSWR EPA
for SWM.
- Government to make a final decision on the body and
the duties of the agency. The legislation setting up the
regulatory body to be part of the SWM Act. Department
vs commission debate by considering duties outlined for
the new agency.
Capacity building for government officers to build PURC
technical and administrative capacity of new regulatory MSWR
EPA
body.
Other considerations / implementation risks
• The mandate and roles of the NSA is not clear at the time of drafting and will influence
the roles and responsibilities of sector regulation and oversight.
• The regulatory framework to consider appropriate regulations to support waste
reduction and recycling and environmental standards (3Rs, MINTing etc.).

Develop a service delivery monitoring framework for MMDAs

Objective: To support efficient and effective supervision and monitoring of services at the
operational level
Strategic alignment: Alignment with the National Environment and Sanitation Policy
(NESP) policy focus of M&E at the local level. The NESSAP (2010) indicates that the
foundations for implementing an effective M&E system would be established in the short
term as part of the pre-implementation stage of DESSAPs. This would involve building on
assessed capacity needs at all levels for effective M&E.
Inter-
Required activities / inputs Responsibility
dependencies
OHLGS,
Develop KPIs for service delivery at the MMDA level. MSWR
MMDAs
OHLGS,
Develop forms for supervision and monitoring. MSWR
MMDAs
Other considerations / implementation risks
• Possibly link to the preparation and M&E of the DESSAPs.
• Possibly link to verification for ODF in communities.

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Develop a system to recognise and monitor the operations of the informal sector

Objective: Improve working conditions and economic potential of informal waste-pickers

and recyclers
Strategic alignment: Enabling effective waste reduction, recovery, and recycling;
strengthening the protection of vulnerable and marginalised groups
Inter-
Required activities / inputs Responsibility
dependencies
MMDA to spearhead a step-wise process
- Identification and registration of informal service
providers. YEA, GSA
- Provision of identification numbers and identity cards. MMDAs NHIA
- Monitoring of ‘Borla Taxis’ through electronic tracking.
- Provision of basic OHS standards.
- Provision of basic OHS equipment by MMDAs.
MMDAs to consider zoning the operations of registered
MMDAs YEA,
Borla Taxis.
Borla Taxis to be registered to be part of the community -
based waste recovery and recycling programme in each MMDAs YEA, NHIA
MMDA.
Other considerations / implementation risks
• Requires government-led commitment to protect vulnerable and marginalised groups.
• Free National Health Insurance registration of informal sector service providers based
on minimum tonnage collected.
• Introduce a bonus scheme through YEA for informal sector.

Revise the placement and locations of transfer infrastructure

Objective: To improve the placement and allocation of MMDA -controlled waste transfer
assets, such as skips, through systemic and strategic use of GIS data within local MMDAs
Strategic alignment: Optimise service delivery and infrastructure
Inter-
Required activities / inputs Responsibility
dependencies
Develop a spatial plan for the equitable placement of MMDAs
MSWR,
skips within MMDAs. National government will mandate (WMDs,
LUSPA
and support MMDAs to assume this capacity. Planning Unit)
WMDs and LUSPA to work in close concert to develop
MSWR,
area/ street mapping and spatial data for SWM purposes MMDAs
LUSPA
(location of skips, transfer and other sanitary sites).
Locations of large-scale infrastructure (for treatment and
MSWR,
disposal) should be included in the Spatial Development MMDAs
LUSPA
Plans being developed by LUSPA.
MSWR,
Resolve property rights relating to sanitary sites (payment LUSPA
MMDAs
of compensation to land owners where appropriate).

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National Solid Waste Management strategy for Ghana

Objective: To improve the placement and allocation of MMDA -controlled waste transfer
assets, such as skips, through systemic and strategic use of GIS data within local MMDAs
Other considerations / implementation risks
• GIS capacity to be built up at MMDAs and based on indicators that are strongly based
on ensuring an equitable and effective distribution of these assets, relating to their
placement per population and area.
• Government to set up a call centre and control room where all sanitation-related
activities are monitored. The call centre will serve as a means of providing a quick
response to reported issues.

Create community-based waste recovery and recycling programme in low-income

areas

Objective: Increase access to advanced waste recycling technology for marginalised

groups
Strategic alignment: Promotion of inclusive waste management and recycling
infrastructure and technology
Inter-
Required activities / inputs Responsibility
dependencies
Various inter-related activities, including:
- setting up of a local buy-back centre (using existing
transfer sites);
- government to lead efforts for the allocation of land,
light construction of storage facilities for waste
valorisation activities, and simple paving for vehicle
access;
- government to develop an operational plan for the MSWR
facility (usage base: per Mt processed vs per hour
Informal sector
used);
- government will lead robust stakeholder engagement Manufacturing
to determine most conducive and effective operational companies
model; MMDAs Private sector
- government to lead efforts for the procurement and (e.g.
setting up of light processing technologies, including Environment
for a vertical baler and plastic shredder, operational in 360 or city
every MMDA.
waste)
Possible models include:
- Community education to encourage members to send
separate waste at source. Waste to be picked by the
informal sector or sent by the community members to the
centre for a token.
- Results-based waste rewards scheme to encourage
community members to bring in waste,
Other considerations / implementation risks
• Risk of Bora Taxis and informal sector not complying.
• Risk of not getting off-takers for the waste.

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4.3 Priority actions in the medium term

In the medium term, national government will seek to establish PPPs with advertising and
social marketing companies to communicate effective and comprehensive BCC strategies
through various media, print, and online channels. It will additionally revise the DPAT so that
it effectively measures service quality for SWM services and effective oversight by MMDAs
and WMDs, and will develop a Clean Cities Challenge in Ghana to create a sense of
competition among MMDAs in regard to cleanliness and beautification.

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4.3.1 National level

Develop and roll-out comprehensive BCC strategy and campaigns

Objective: Improve household practices in relation to waste disposal

Strategic alignment: Create positive social action on SWM
Inter-
Required activities / inputs Responsibility
dependencies
NCCE;
- MSWR to engage the services of an advertising and CONIWAS,
social marketing company to develop a Media,
comprehensive BCC strategy for SWM emphasising community-
the link between improved service delivery and MSWR based
behaviour change.
organisations
- A key action is to develop an actionable slogan,
tagline, or message associated with positive sanitation Advertising
behaviours that can be implemented nationwide. and social
marketing TA
- Identify other targets for behaviour change, such as MMDAs MSWR
formal and informal service providers.
MSWR,
- Pilot the implementation of this strategy in selected UNICEF,
MMDAs
urban areas with a view to scaling it up nationwide. development
partners
MSWR,
UNICEF,
- Roll-out of campaign on a nationwide scale. MMDAs
development
partners
MSWR,
- Engage local groups and community-based UNICEF,
organisations/faith-based organisations etc. to support MMDAs
development
implementation at the community level.
partners
- Consider other effective tools and outlets – use of
selected BCC sketches, jingles, and drama to be MSWR,
played/aired just before prime news on GTV and NCCE,
popular TV and FM stations; also, to be played at lorry UNICEF,
MMDAs
parks, sports stadia, and markets; and display of small
posters on front page of national dailies such as Daily development
Graphic, Ghanaian Times etc. Employ use of social partners
media in the campaigns.
Other considerations / implementation risks
• Behaviour changes approaches must be complemented by the provision of appropriate
infrastructure to enable and support positive behaviours.
• Seek to complement this with the progressive implementation of sanctions for those
egregiously dumping irresponsibly in locations where transfer infrastructure is available.

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National Solid Waste Management strategy for Ghana

Develop and implement a strategic sector investment plan

Objective: Implement new approaches to mobilise finance and maximise value for money
Strategic alignment: SESIP to consider the priority actions and plans stated in the
National Infrastructure Plan. The development of the SESIP will support strategic priorities
to optimise service delivery and infrastructure, and enable effective waste recovery, re-use,
and recycling
Inter-
Required activities / inputs Responsibility
dependencies
Review of the current SESIP:
Develop terms of reference for review of SESIP to be
developed for a consultant, this should include elements
looking to:
- review and update SESIP;
- costing the services;
- identifying the funding gap;
- plan for mobilising funding; PPP, taxation, results-
based financing etc. at both the national and district MSWR MMDA/TA
levels;
- include a financing plan for the DESSAPs; and
- cover a 10-year period up to 2030.
MMDAs to present their funding gaps based on their
DESSAPs. These will feed into the bigger SESIP. As part
of the development of SESIP strategic infrastructure that
need investment should be identified.

Other considerations / implementation risks

• Revisions of the NESSAP and SESIP are important interlinked priorities, given that the
implementation wing of the existing documents has elapsed.

Incentivise performance of MMDAs through the provision of financial rewards

Objective: Implement an incentivised system for MMDAs in SWM similar to and based on
the Sanitation Challenge for Ghana Strategy
Strategic alignment: Improving operational governance and strengthening M&E systems
in SWM
Inter-
Required activities / inputs Responsibility
dependencies
Include incentives for sanitation service delivery
under DPAT:
- Liaise with MLGRD, OHLGS, to identify and agree
MLGRD,
on the appropriate SWM indicators to be added to
the DPAT. MSWR OHLGS,
- Integrate SWM indicators within DPAT to DACF
incentivise performance of MMDAs.
- MMDAs to report on performance monthly.

Establish clean cities challenge for Ghana: Development

MSWR
- Develop an implementation plan for the challenge. partners,

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National Solid Waste Management strategy for Ghana

Objective: Implement an incentivised system for MMDAs in SWM similar to and based on
the Sanitation Challenge for Ghana Strategy
- Interested MMDAs to register on a platform. DACF,
- Procedures would be designed for self-assessment OHLGS
and reporting.
- Introduction of tracking devices on skips, vehicles,
and other equipment to verify information reported
by MMDAs.
- MWSR to undertake verification of reports
submitted.
- Independent judges to assess and score the
performance of MMDAs.

Other considerations / implementation risks

To ensure that the DPAT scoring is effective, the MMDAs will be required to submit regular
reporting, similar to district reports to the controller and account general. These reports will
be required to be submitted to MSWR by the middle of the month and verified by MSWR by
the end of the month within which they are submitted.
Some of the risks of the sanitation challenge include:
• the lack of interest in MMDAs – this could be mitigated by sensitisation workshops to be
held at zonal level to introduce and market the challenge; and
• lack of funding – MSWR and MLGRD to source funds to implement this challenge for at
least two years. Civil society organisations can provide independent monitoring score
cards for MMDAs.

4.3.2 Operational level

Operational-level actions will focus on the zoning of MMDAs to be revised so that

prospective contractors of all sizes (e.g. informal, community-based, SME, and larger private
sector actors) are capable of applying and competing with one another.

Develop clarity in service delivery zones for contractors

Objective: Improve SWM service coverage and service quality through zoning such that
private contractors undertake all waste management activities within the zone
Strategic alignment: Optimise service delivery and infrastructure; enable effective waste
recovery, re-use and recycling
Inter-
Required activities / inputs Responsibility
dependencies
- Undertake a consultative process to re-zone urban
areas, ensuring that each zone includes a mix of high-
and low-income areas.
- Service delivery contracts to include mandates for the MMDA N/A
provision of beautification and street cleaning services
to ensure there is no ambiguity relating to the role and
scope of the service providers’ work.
Other considerations / implementation risks
• New zoning provisions will likely challenge SIP arrangements. Local governments will
have to directly influence and amend their SIP contracts to suit their particular needs.

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Develop standard procedures for the procurement and support of contractors

Objective: Promote equity in private sector participation through standardised

procurement, evaluation, and zoning support
Strategic alignment: Transparency to ensure improved competitiveness for private waste
companies/a level playing field for all. This is in line with policy recommendations for
providing sector-wide standards for service provision
Inter-
Required activities / inputs Responsibility
dependencies
Defining service provider categories and capacities
(financial, logistical, human resource) to determine the MMDA N/A
realistic scale and zone allocation that they could manage
and administer.
Develop standard procurement guidelines (invitation for
bids, templates for bid, agreement forms, contracts, MMDA N/A
criteria for evaluation) based on the Public Procurement
Act.
New investments in the sanitation space based on MMDA N/A
approved technical and financial modelling.
Identify relevant subsidies to be provided for contractors
and provide uniform subsidies across service provider MMDA N/A
category.
Development of Standard Operating Procedures. MMDA N/A
Other considerations / implementation risks
N/A

4.4 Priority actions in the longer term

4.4.1 National level

Longer-term priorities at the national level are focused on building the prominence of
environmental sanitation as a priory aspect of decentralised service delivery, improving the
prospects for policy implementation through improved monitoring and accountability of
government actions, and the gradual introduction of incentives to improve private sector
engagement in the sector.

Include the MSWR in the IMMC on decentralisation

Objective: To improve intersectoral collaboration by making the MS WR a permanent

member of the IMCC on decentralisation
Strategic alignment: The IMMC which is responsible for the intersectoral policy
coordination of decentralisation and for the decentralised local governance system. The
objective of this action is aligned to Pillar 1 and will support the policy goals of achieving a
sustainable mechanism for effective coordination of, and collaboration among, sector
stakeholders for country-wide adoption of policies, plans, and programmes

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National Solid Waste Management strategy for Ghana

Objective: To improve intersectoral collaboration by making the MS WR a permanent

member of the IMCC on decentralisation
Inter-
Required activities / inputs Responsibility
dependencies
IMCC/Office of
MSWR to prepare justification and make submission to
MSWR the President
the IMCC secretariat.
Annex
MWSR,
IMCC Secretariat to respond to proposal; necessary Attorney
IMCC
amendments to be made to Act 936, Part Nine. General’s
Department
Other considerations / implementation risks
Time and processes required to make amendment to legislation may be challenging.
Ministry to engage with the appropriate parliamentary select committees to ensure
processes are completed.

Develop incentives for private sector engagement through tax reliefs, or similar

Objective: The elimination or temporary waiving of specific applicable taxes, fees, and
licensing costs, levied on service providers
Strategic alignment: Providing an enabling environment to encourage private sector
participation in waste management
Inter-
Required activities / inputs Responsibility
dependencies
Identify the current operational costs for service
providers.
ESPA
members,
Make an inventory of taxes paid by service providers (e.g. Ghana
import taxes, PAYE on employees, property rates, MSWR
Revenue
business operating permits).
Authority
(GRA)
ESPA
Ascertain the contribution of taxes to the cost build up. MSWR
members,
Identify which of the taxes can be eliminated and prepare Ministry of
MSWR
a proposal to Ministry of Finance and GRA. Finance, GRA
Other considerations / implementation risks
N/A

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National Solid Waste Management strategy for Ghana

Monitoring of policy Implementation

Objective: To provide follow through for policy implementation – ensuring accountability

and transparency in policy implementation
Strategic alignment: Aligned to the strategic entry points for Pillar 1 and also to the
Environmental Sanitation Policy which requires the MSWR to ‘appraise and assess
progress in policy implementation, the effectiveness of policy actions’
Inter-
Required activities / inputs Responsibility
dependencies
Identify policy objectives and outcomes. MSWR N/A
Identify the interventions needed to achieve outcomes
and the timelines for implementation (to support policy
MSWR N/A
implementation there should be a team of persons within
the MSWR responsible for overseeing the interventions).
Development of framework for policy implementation and
MSWR N/A
provide indicators for outcomes.
Establish a technical committee or assign personnel to
undertake the monitoring – link to mid-year and annual MSWR N/A
review activities for the ministry.
Civil society to provide independent assessment of
performance through the design and development of a
MSWR CONIWAS
score card showing the performance of national
government and MMDAs in SWM.
Other considerations / implementation risks
N/A

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National Solid Waste Management strategy for Ghana

Annex A Monitoring and evaluating SWM service delivery

This annex provides an overview of a series of proposed indicators of SWM service performance at different stages of the SWM chain.
Alongside the proposed indicators themselves, guidance is provided on the means of verifying the indicator and the source of information.

Table 3: Summary of key indicators and means of verification

Indicator(s) Means of verification Source(s) of information
Collection 1. Volume of waste generated Reports on waste characterisation; Monitoring data from WMDs on public
2. % of solid waste collected weighbridge or landfilling capacity records; and private infrastructural assets; key
3. Household storage facilities and data on capacity of public and private waste informant interviews with transport
communal storage facilities transfer assets and vehicle fleets (e.g. number managers at largest waste collection
of vehicles, volumetric capacity of skips, companies
trailers)
Transport 1. Availability of transfer stations Reports on actual vs recommended vehicle Monitoring data from WMDs on public
2. Availability of compactor trucks and and transfer capacity; population and area and private infrastructural assets; key
other means of transporting ratios (e.g. actual skip: to population ratio vs informant interviews with transport
3. Small-scale Borla Taxis should be
industry recommendations); reports on the managers at largest waste collection
regulated
4. % of waste collected and transported to scale, size, and capacity of informal workers, companies
end disposal (dumpsites, landfills) including Borla Taxis and wa ste-pickers
5. % of waste collected and transported to
waste transfer stations
Treatment 1. Availability of treatment plants Reports and spatial data on location and Logs from treatment and recycling plant
2. Availability of recycling plants and capacity of waste recycling and recovery operations
transfer stations infrastructure
3. Volumes of waste treated or recycled
Disposal 1. Availability of final disposal site/landfill Reports on waste characterisation; Logs from landfill managers; internal
2. Volumes of waste safely disposed of weighbridge or landfilling capacity records records from private sector operators
after treatment who dump at the site

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National Solid Waste Management strategy for Ghana

As part of developing the indicators for monitoring service delivery, the indicators of the ODF
verification protocol for urban areas were reviewed. It was noted that some of the features of
a sanitised community are as follows:

• there is a SWM system in place (this includes composting, recycling, re-use, burying,
temporarily kept in bins with cover, and collection and transferred to designated site);
• lanes and alleys between houses and path to the refuse dump are clean or regularly
swept;
• overgrowth of weeds controlled to a minimum; and
• animal droppings controlled to a minimum.

These indicators are somewhat shallow and not well targeted on the key aspects of SWM
and do not provide any insight into the service delivery performance.

A.1.1 Routine service provider monitoring

House-to-house collection monitoring (to be done weekly in line with the collection plan
stated in the contracts):

• name of sub-metro
• service zone
• number of households in zone
• name of contractor/contractor capacity – equipment/number of workers
• number of collections
planned
actual
• total weight/tonnage collected
• destination of waste
MRF
landfill
dumpsite

Communal collection monitoring (to be done weekly)

• name of sub-metro
• service zone
• number of households in zone
• number of containers
• volume of containers
• name of contractor/contractor capacity – equipment/number of workers
• number of collections
planned
actual
• total weight/tonnage collected
• destination of waste
materials recovery facility
landfill

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National Solid Waste Management strategy for Ghana

dumpsite
A.1.2 Communal collection – monitoring of site conditions for transfer points

In addition to monitoring collections, the transfer site should be monitored to ensure that the
site is properly managed. Forms for monitoring centrally located containers/communal
containers to be completed by cleansing officer and reviewed by the officer in charge of solid
waste.

Table 4: Proposed indicators to assess conditions at communal transfer stations

(skips)
Indicators
Metro/sub-council
Date and time of monitoring
Service provider for the area
Location of container (linked to the mapping of the container sites)
Note – provide location ID on the form, also provide container ID (containers to be provided with
electronic tagging to aid e-monitoring)
Volume of container
Collection days/frequency of collection
Planned collections can be calculated based on expected volumes for the area being served
Describe site conditions upon visit – well kept, or dirty with litter on the ground; skip pad in place or
just open skip site
Describe container condition – empty; full; not full; spills
Compile summary of planned vs actual collections at the end of the week or month

A.1.3 Compliance checking and monitoring of OHS standards

One recommendation is the mandatory provision and use of OHS equipment by MMDA
staff, workers employed by contractors, and service providers and the informal sector. The
WMDs can pay regular visits to sites where workers are located or to company premises for
inspections.

This requires OHS guidelines to be developed for MMDAs, contractors, service providers,
and the informal sector. The list of items to be checked includes the following:

• Protective clothing – personal protective equipment (gloves, masks, boots, first aid kit,
overalls and uniforms, boots or appropriate footwear that protects the toes, goggles,
nose masks where needed – nose masks to have special protection against dangerous
gases etc.).
• Also check that appropriate OHS signage, notices, and warnings are provided for waste
management sites. Check the site management practices to ensure that the sites are
clean and operated in a compliant manner.
• Check medical exams and inoculations and shots.

A.1.4 Monitoring of waste at landfill

This should include the routine monitoring of vehicles, including: vehicle details; type of
vehicle; capacity – volume/tonnage

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1. information on source of waste

2. type of waste
3. tipping fees paid

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National Solid Waste Management strategy for Ghana

Annex B Stakeholders engaged

Table 5: Attendees at the validation workshop, Accra, 1 August 2019

No Name Organisation
1 Gladys Wartenberg MSWR
2 Emmanuel Obeng ACARP
3 Ama Ofori Antwi ESPA
4 Kweku Akuamoah-Tsekpetse MSWR
5 Lorretta Roberts UNICEF
6 Joseph Boham EASD
7 Anthony Mensah MSWR
8 Jonathan Manu MSWR
9 Stephen L. Padi MSWR
10 G. Joseph Agbesie MSWR
11 Millicent Oppong City Waste
12 Vivian Ahiagbor City Waste
13 Jonas Duneebon STMA
14 I.B. Freeman National Focus
15 Dr Richard Amponsah AFESC – Jospong
16 Dr. Daniel Sarpong MSWR-GASSLIP
17 Thomas M. Edinam MSWR
18 Bright A. Baah MWSR
19 Theophilus Addico MSWR
20 Elvis Oppong PRWCIA
21 Doris Acquah EHSU, Asuogyaman DA
22 Agnes Korletey EHSU, Shai-Osudoku
23 Paul Sitsofe Dept. of Comm. Development
24 Francis Xavier Anowie Global Communities
25 Ishaq K. Mahama MLGRD
26 Gloria Akuffu MLGRD
27 Prosper Kotoka Kumasi Metropolitan Assembly
28 Bertha Darteh (Dr) MAPLE Consult
29 David Delienne UNICEF consultant
30 Ramesh Bhusal UNICEF
31 Susana Martinson Effutu Municipal Assembly
32 Ellen Gyekye GES SHEP Organiser
33 Patience Ampomah National Dev. Planning Commission
34 Aaron K. Amedzo Ho Municipal Assembly
35 Derick Tata Anku Tema Metropolitan Assembly

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National Solid Waste Management strategy for Ghana

No Name Organisation
36 Paul Amoako-Gyampah UPPR
37 Josh Palfreman Oxford Policy Management
38 Jacob Amanor MSWR
39 Ing. Baah Tetteh OHLGS
40 Pamela Adompreh OHLGS
41 Prince Bio JICA
42 Janet Arthur EKN
43 Faustina Asante WSUP
44 Peter Dagadu Waste Landfills Co. Ltd.
45 Basilia Nanbigne CONIWAS
46 S. K. Martey PWWCA
47 Cindy Badoe EPA
48 Theophilus Arthur -Mensah AGI
49 Levina Owusu MESTI
50 Senam Tengey Zoompak
51 Dr Solomie Gihen Int. Water Management Institute
52 John Defor Association of Ghana Industries
53 Prof. Oteng Ababio Tersus Ghana
54 Abraham Bugre Univ. of Ghana
55 Johannes Boachie-Yiadom Zoompak Ghana
56 Emmanuel Lamptey MSWR
57 Dr Tanko Azzika WSUP
58 Mahamoo A. Samari PWWCA
59 Giwa Shaabu B. MSWR
60 Jamil Wuni Iddi DEHO,
61 Erasmus Amanor MSWR
62 Nii Odai Laryea MAPLE Consult
63 Mawuena Dotse MAPLE Consult
64 Emmanuel Sessou MAPLE Consult
65 Peter Burr Oxford Policy Management
66 Joel Ayim Darkwah UNDP
67 Patrick Tsigbey ASHMA
68 Korama Ocran UNICEF
69 Isaac Barnes ESPA
70 Matilda Owusu ESPA
71 Faustina Essandoh Department of Community Development
72 Martin Ahorlu Tamale Metropolitan Assembly
73 Fiabge E. Eugene EHSD
74 Lydia Essuah MESTI

51