# The Waste Bin Is a Food Safety Control Point: Why Kenyan Food Factories Should Manage Waste Like a Process, Not a Chore

*By Isaac Muthui, CEO, Tamalaki Business Network Ltd. Originally published at [factoraerp.com](https://factoraerp.com/en/blog/waste-management-checklist-food-factories-kenya).*

In most food factories, waste is the job nobody wants and nobody owns. A bin by the line fills up during the shift. Someone carries it out when it overflows. The skip behind the factory gets collected when the truck comes, and the drain by the washing bay is cleaned when it starts to smell.

Then an auditor walks the grounds, a county public health officer asks to see the waste contractor's licence, or the pest control report shows rodent activity next to the skip. Suddenly waste is a food safety problem, an environmental compliance problem and, if anyone looks at the numbers, a cost problem. Every kilo in the skip was paid for as raw material, packaging or energy.

This food factory waste management checklist is written for dairies, millers, bakeries, juice, snack, meat, edible oil and other Kenyan and East African food and agro factories. It does not replace your HACCP team, your environmental consultant, NEMA, your county government or your certification body. It sets out ten practical checks for treating waste, by-products and effluent as a controlled process rather than a chore.

## What the standards actually say

**Codex.** The [Codex General Principles of Food Hygiene, CXC 1-1969](https://doi.org/10.4060/cc6125en), lists waste management as one of the objectives of its section on maintenance, cleaning and pest control, alongside monitoring "the effectiveness of cleaning and disinfection, pest control and waste management procedures". On facilities (9.2.1), it says waste "should be collected, disposed of by trained personnel and, where appropriate, disposal records maintained", that the disposal site should be "located away from the food establishment to prevent pest infestation", and that "containers for waste, by-products and inedible or hazardous substances should be specifically identifiable, suitably constructed and, where appropriate, made of impervious material". On day-to-day management (11.3.1), waste "should, as far as possible, be collected and stored in covered containers and should not be allowed to accumulate and overflow in food handling, food storage, and other working areas". Personnel responsible for waste removal "should be properly trained so they do not become a source of cross-contamination", and waste storage areas should be "easily identifiable, be kept appropriately clean, and be resistant to pest infestation". Codex also lists handling waste as one of the moments when hands must be washed (12.3).

**The East African code.** [EAS 39:2001, the East African code of practice for hygiene in the food and drink manufacturing industry](https://law.resource.org/pub/eac/ibr/eas.39.2001.pdf), is specific. Skips and containers for waste "shall be covered and emptied at least once per week, or more frequently as is consistent with minimizing the risk of infestation" (10.8.1). They "shall be located as far as practicable from processing areas and air intake areas and shall be sited on self-drainage concrete, tarmac or an equivalent surface" (10.8.2). Waste containers inside the factory "shall be such that they cannot be mistaken for food containers and shall be emptied daily", and "packaging material, whether damaged or not, shall not be used as a waste receptacle" (10.8.4). Section 11 adds that food factories "shall have an efficient effluent and waste treatment and disposal system", that "waste shall be stored away in a separate place from the processing room" (11.2), and that floor drains "shall be fitted with effective traps and shall be covered with a suitable grid" (11.3.1).

**Kenya's food hygiene regulations.** The [Food, Drugs and Chemical Substances (Food Hygiene) Regulations](https://faolex.fao.org/docs/pdf/ken106527.pdf) made under Cap. 254 require the grounds of a food plant to be kept free of "litter, waste and refuse which may attract, harbour or constitute breeding places for rodents, insects and other pests" (regulation 7). Regulation 11 requires that "refuse and offal is conveyed and disposed of so as to minimize noxious odour, to prevent waste which attract or harbour or provide a breeding place for vermin and to prevent the contamination of food". The Second Schedule says food processing areas and equipment "shall not be used to process animal feed or inedible products unless there is no reasonable possibility of contaminating the human food".

**Kenya's waste law.** The [Sustainable Waste Management Act, 2022](https://new.kenyalaw.org/akn/ke/act/2022/31/eng@2022-12-31) took effect on 22 July 2022, and [NEMA has said it has commenced inspection and enforcement](https://nema.go.ke/wp-content/uploads/2024/10/Public-Notice-to-All-Producers.pdf). Section 12 requires public and private sector entities to "segregate non-hazardous waste into organic and non-organic fractions", placed in "properly labeled and colour coded receptacles". Section 19 requires a private sector entity to prepare "a three-year waste management plan" and submit an annual monitoring report that specifies "the actual quantities of waste generated" and the methods applied (the Act leaves it to the Cabinet Secretary to gazette which categories of entity must do so, based on volume of waste). It also requires entities to separate hazardous from non-hazardous waste, transfer waste "to a person who is licensed to transport and dispose of the waste", and provide "waste segregation receptacles at its premises for organic, plastic and general dry waste". Factories that put packaged products on the Kenyan market also carry extended producer responsibility under section 13 and the [2024 EPR Regulations](https://new.kenyalaw.org/akn/ke/act/ln/2024/176).

**A useful benchmark.** US rules are not binding in Kenya, but [21 CFR 117.37(f)](https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-117/subpart-B/section-117.37) puts the food safety point in one sentence: rubbish and offal must be "conveyed, stored, and disposed of as to minimize the development of odor, minimize the potential for the waste becoming an attractant and harborage or breeding place for pests, and protect against contamination of food, food-contact surfaces, food-packaging materials, water supplies, and ground surfaces".

## Why waste management goes wrong

Waste rarely goes wrong because a factory has no bins. It goes wrong because nobody owns the whole stream, from the line to the gate.

The patterns are familiar. Production bins have no lids, or the lids are propped open so they are quicker to use. An empty ingredient bag or a spare crate becomes a waste container, so waste and food packaging look the same. Bins are emptied when they are full, not on a schedule. The skip sits next to the raw material store because that is where the truck can reach. The same cleaner carries waste out and then handles product without washing. By-products such as bran, whey, pomace or trimmings are stored like waste, then sold as feed with no record of what went where. Nobody weighs anything, so nobody knows whether yield losses are going up. And the waste contractor's licence, if it was ever checked, expired last year.

## The 10-step food factory waste management checklist

### 1. Map every waste stream and give it an owner

- List each stream: production waste (rejects, spills, trimmings, line purges), by-products (bran, whey, pomace, press cake, peels), packaging waste, effluent, hazardous waste (chemical containers, oils, laboratory waste, fluorescent tubes, e-waste) and general office and canteen waste.
- For each one record where it is generated, how it is contained, how often it is removed, where it goes and who is responsible.
- A flow diagram already shows where waste and by-products leave the process. Codex asks HACCP teams to include this in the flow diagram, so start there.

### 2. Use dedicated, identifiable containers that cannot be mistaken for food containers

- Waste containers should be a different colour or shape from anything used for food, clearly labelled, lidded and easy to clean. EAS 39 says they must not be mistakable for food containers.
- Never use packaging, ingredient bags, product crates or buckets as waste containers. EAS 39 says packaging, damaged or not, "shall not be used as a waste receptacle".
- Hazardous waste containers should be identified and, where appropriate, lockable, as Codex recommends.
- Our [packaging material control checklist](https://factoraerp.com/en/blog/packaging-material-control-checklist-food-factories-kenya) and [chemical control checklist](https://factoraerp.com/en/blog/chemical-control-checklist-food-factories-kenya) cover the other side of this rule.

### 3. Segregate at source

- Separate organic waste, plastics, other dry waste and hazardous waste where it is generated, in labelled and colour-coded containers, as the Sustainable Waste Management Act requires.
- Keep by-products intended for feed or further use apart from waste, in their own containers, so they stay usable and traceable.
- Segregation at source is easier than sorting later, and it is the only way to know what each stream weighs.

### 4. Keep lids closed and empty bins on a schedule

- Production-area containers should be emptied at least daily, as EAS 39 asks, and more often on busy lines. Skips should be emptied at least weekly or more often if pests are a risk.
- Never let waste accumulate or overflow in production or storage areas. Put the emptying times on the cleaning schedule and check them on the hygiene inspection.
- See our [cleaning and sanitation checklist](https://factoraerp.com/en/blog/cleaning-sanitation-checklist-food-factories-kenya) for building this into the master cleaning schedule.

### 5. Move waste out without crossing clean areas

- Plan the route waste takes from the line to the store and the skip, so it does not pass through finished-product, packing or raw-material areas when they are in use.
- Waste trolleys and tools should be dedicated, identified and cleaned in a separate area. Codex asks for separate cleaning facilities for tools from waste disposal areas.
- Anyone who handles waste must wash their hands before returning to food handling. Codex lists handling waste among the hand-washing moments. Our [personal hygiene checklist](https://factoraerp.com/en/blog/personal-hygiene-staff-health-checklist-food-factories-kenya) covers the facilities.

### 6. Site and maintain the waste store and skips properly

- Keep the waste area away from processing areas and air intakes, on a concrete or similar self-draining surface, as EAS 39 requires. It should be clearly marked, roofed or covered, and cleaned on a schedule.
- Keep the surrounding grounds free of litter, spilled waste and stagnant water. Kenya's food hygiene regulations require the grounds to be free of waste that attracts pests.
- Put the waste area on your pest control map. Our [pest control checklist](https://factoraerp.com/en/blog/pest-control-checklist-food-factories-kenya) explains why.

### 7. Control drains and effluent

- Floor drains should have traps and grids, be kept clean and be sanitised at appropriate intervals, as EAS 39 asks. Drainage should never run from raw or dirty areas towards areas where finished food is exposed.
- Check grease traps and solids screens on a schedule and record it.
- If effluent is treated on site, keep the plant downwind of air intakes and keep its monitoring records. Discharge permits and limits are set by the competent authorities, so confirm your obligations with NEMA and your county or water service provider.

### 8. Treat by-products as products, not as waste

- By-products sold or given away as animal feed or for further processing should have their own specification, storage and records: what it is, which production run it came from, how much, when it left and who received it.
- Keep their handling apart from food. Kenya's food hygiene regulations say food processing areas and equipment must not be used for animal feed or inedible products unless there is no reasonable possibility of contaminating the food.
- If a by-product could be affected by a food safety issue, for example a mycotoxin problem on a grain intake, you need to know where it went. Our [aflatoxin control checklist for maize millers](https://factoraerp.com/en/blog/aflatoxin-control-checklist-maize-millers-kenya) discusses this.

### 9. Use licensed contractors and keep the paperwork

- Hand waste only to waste service providers licensed to transport and dispose of it, as the Act requires, and keep copies of their current licences.
- Keep a record of every collection: date, stream, quantity, collector and destination. Codex asks for disposal records "where appropriate". Hazardous waste needs its own handling under the Environmental Management and Co-ordination Act and its regulations.
- Rejected or recalled product should be destroyed in a controlled way, with a record and, where possible, evidence of destruction, so it cannot find its way back onto the market.

### 10. Weigh it, review it and reduce it

- Weigh each stream, at least by category and week. You cannot manage what you do not measure, and if your entity is one that must submit an annual monitoring report, the Act asks for actual quantities.
- Review the figures monthly against production. A rise in production waste is often the first sign of a yield, equipment or training problem. Our guide to [batch costing and yield tracking](https://factoraerp.com/en/blog/batch-costing-yield-tracking-agro-processors-kenya) shows how to link waste to cost.
- Include waste management in your internal audits, as Codex asks for its effectiveness to be monitored. See our [internal audit checklist](https://factoraerp.com/en/blog/internal-audit-checklist-food-factories-kenya).

## A simple waste stream register

| Column | What to record |
|---|---|
| Stream | e.g. production rejects, bran, whey, plastic film, chemical containers, effluent |
| Generated at | Line, area or process step |
| Container | Type, colour, label, lid |
| Removal frequency | e.g. every shift, daily, weekly |
| Destination | Skip, by-product store, licensed collector, recycler, effluent plant |
| Owner | Person responsible |
| Records | Weight, collection notes, contractor licence, destruction certificate |

If you cannot fill in a row, that stream is not yet under control.

## An illustration

*This is an illustrative example, not a real case.* A small bakery keeps unlidded bins by the oven line, emptied when full, and stores its skip next to the flour store because that is where the collection truck parks. The pest control contractor reports rodent activity near the flour store for three months running. When the bakery moves the skip to a concrete pad away from the store, puts lidded bins on a twice-per-shift emptying schedule and starts weighing rejected product each day, the pest activity becomes something it can act on, and the daily reject weight tells the production manager which shift and which product are losing the most dough.

## How FactoraERP helps

FactoraERP lets a product's recipe declare its outputs as primary product, co-product, by-product or waste, and records waste quantities against production runs, so waste and by-products are measured where they are made rather than estimated at the end of the month. Because production, stock and costing sit in the same system, a rise in waste shows up next to the batch, the line and the cost. See [factoraerp.com](https://factoraerp.com).

## Free download: eTIMS readiness checklist for factories

Kenyan manufacturers increasingly need their operational records, stock records and invoices to tell one consistent story. If you want a free **eTIMS readiness checklist for factories**, sign up for the FactoraERP Insights newsletter at [https://isaacmuthui.substack.com](https://isaacmuthui.substack.com). You will get practical operations notes for food and agro manufacturers. No spam; unsubscribe anytime. For background, see our guide to [eTIMS for food and agro manufacturers](https://factoraerp.com/en/blog/etims-for-food-agro-manufacturers-kenya).

## FAQ

**What does a food factory waste management checklist cover?**  
Mapping each waste stream, dedicated and identifiable containers, segregation at source, emptying schedules, waste routes, the waste store and skips, drains and effluent, by-products, licensed contractors and records, and weighing and reviewing waste.

**How often should waste bins in a food factory be emptied?**  
EAS 39 says waste containers inside the factory should be emptied daily, and skips at least once a week or more often if needed to minimise the risk of infestation. Codex says waste should not be allowed to accumulate or overflow in food handling and storage areas.

**Do Kenyan food factories have to segregate waste?**  
Yes. The Sustainable Waste Management Act, 2022 requires private sector entities to segregate non-hazardous waste into organic and non-organic fractions, separate hazardous waste and provide receptacles for organic, plastic and general dry waste.

**Can packaging or ingredient bags be used as waste bins?**  
No. EAS 39 says packaging material, whether damaged or not, shall not be used as a waste receptacle, and waste containers must not be mistakable for food containers.

**Is a by-product sold as animal feed still the factory's responsibility?**  
It should be controlled and recorded like a product: what it is, which run it came from, how much and who received it. Kenya's food hygiene regulations also say food processing areas and equipment must not be used for animal feed or inedible products unless there is no reasonable possibility of contaminating the food.

**Who can collect waste from a food factory in Kenya?**  
The Sustainable Waste Management Act requires waste to be transferred to a person licensed to transport and dispose of it. Keep a copy of the contractor's current licence and a record of each collection.

---

*Isaac Muthui, CEO, Tamalaki Business Network Ltd*