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Performance Audit Report of the Auditor-General on

Accountability Arrangements in Solid Waste Management

REPUBLIC OF GHANA

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PERFORMANCE AUDIT REPORT

of theAUDITOR-GENERAL

on

ACCOUNTABILITY ARRANGEMENTS IN SOLID

WASTE MANAGEMENT


Solid Waste Management

2

Edward

Auditor-General of Ghana

Edward Dua Agyeman

Auditor-General of Ghana



3

PERFORMANCE AUDIT REPORT OF THE AUDITOR-GENERAL ON ACCOUNTABILITY ARRANGEMENTS IN SOLID WASTE

MANAGEMENT

TABLE OF CONTENTS

Page

Transmittal letter i - ii

Executive summary iii - vii

Introduction 1

Reasons for the audit 1

Problems caused by waste 1

Classification of waste 2

Importance of effective accountability and governance 3

Environmental management accounting 4

Audit of waste management in an African context 5 – 6

Details of audit findings 7 – 8

Accountability strengths 9

Way forward 10 – 11

Background 20

Problems caused by waste 20 – 21

Classification of waste 21 – 23

Importance of effective accountability and governance 23 – 25

Terms of reference 25

Summary of the audit findings 25 – 28

Role and mandate of agencies 28 – 29

Measurement and reporting of performance 30 – 32

Developing people 32 – 36

Reporting on service delivery 36 – 37



4

Ref. No. AG.01/109

Office of the Auditor-GeneralMinistries Block ‘O’P. O. Box MB 96Accra

Tel. (021) 662493Fax (021) 662493

December 2006

Dear Sir,

PERFORMANCE AUDIT REPORT OF THE AUDITOR-GENERAL ON ACCOUNTABILITY ARRANGEMENTS IN SOLID WASTE

MANAGEMENT

I have the honour to submit to you for presentation to Parliament my 15th

performance audit report in pursuant to Article 187(5) of the 1992 Constitution and Section 13(e) of the Audit Service Act, Act 584. The Audit Service Act which came into force in November 2000, gives me authority to audit programmes and activities of public offices to ensure economy, efficiency and effectiveness in the use of resources.

2. The Audit Service traditionally audits the financial statements prepared by public bodies. Performance auditing has been introduced at Ghana Audit Service as part of a capacity building project funded by the European Union. The audit was carried out by Messrs Yaw Sifah (Team Leader) and S.A.K. Quist using the Team mate software under the supervision of Messrs R.K. Anaglate, Deputy Auditor-General, Performance Audit Department of Ghana Audit Service and Khalid Hamid of South Africa Audit Office and seconded to AFROSAI-E Secretariat in South Africa.

3. Performance audits are carried out by teams of professional staff, including specialists such as architects, legal experts, economists and accountants. Depending on the extent of the coverage and complexity, it normally takes between six months and one year to complete a performance audit, thus, making it more

TRANSMITTAL LETTER



5

expensive than the traditional financial audit. Effective performance audits can leadto better use of resources by public bodies and provide support to democratic governments by bringing about accountability and transparency, improved operations and better decision-making.

4. This report is the 15th report to Parliament and is in two parts: the transversal and country-specific reports prepared by Performance Auditors who have been professionally trained in conducting performance audits to internationally recognised standards to supplement the financial audits. This is a transversal audit carried out simultaneously in five English-speaking African countries and a country specific report on Accra Metropolitan Assembly’s Waste Management Department.

5. I would like to thank my staff for their assistance in the preparation of this report and the staff of the Waste Management Department of Accra Metropolitan Assembly for assistance offered to my staff during the audit.

6. I trust that this performance audit report will meet the approval of Parliament.

EDWARD DUA AGYEMAN AUDITOR-GENERAL

THE RT. HON. SPEAKEROFFICE OF PARLIAMENTPARLIAMENT HOUSEACCRA



6

TRANSVERSAL REPORT ON THE ACCOUNTABILITY ARRANGEMENTS IN SOLID WASTE MANAGEMENT

EXECUTIVE SUMMARY

Human activities have a significant impact on the environment. Over the

last decade, specific emphasis has been placed on the sustainable use of

environmental resources. This audit focuses on one such aspect namely, waste

management.

2. The audit is a collaboration of five Auditors-General and included an

environmental theme. This was to follow up on initiatives undertaken by the

International Organisation of Supreme Audit Institutions (INTOSAI) Working

Group on Environmental Auditing. The working group has provided extensive

information on waste management and is providing training on the auditing of

environmental issues.

3. The project was for all Supreme Audit Institutions to follow a common

methodology to assessing the adequacy of the accountability framework

surrounding waste management from National and International policies and

declarations through to the basic service delivery. Fifteen key areas of questioning

were identified and examined in each of the countries, including the national

perspective through to one local council per country.

4. For the purpose of the waste management audit conducted in the five African

countries, it was expected that not all accountability arrangements would be in

place. The crucial issue is to see improvement over time. Therefore, this audit will



7

be most effective if it is performed on a regular basis to provide on-going

accountability and benchmarking opportunities. At this stage, the issue of waste is

the first in the series but hopefully the principles and methodology can be

replicated in other key service delivery areas. The research which was done by

auditors from the participating countries was co-ordinated in South Africa. The

research and completion of the audits were undertaken in three months. The audit

was conducted by means of electronic working papers.

5. The summary of the audit findings provides an insight into whether adequate

accountability arrangements are in place. All negative findings reflect areas where

attention should be drawn and corrective action taken to ensure the accountability

chain can be completed.

6. The audit findings were discussed with the relevant role-players in the

different countries, but the findings have not been made public. As a result, an

overall summary, rather than detailed findings is included in this report.

7. The average achievement for the five countries was 70%, with the highest

being 82% and the lowest 55%. The criterion was a simple average of each of the

fifteen key areas of questions and whether the responses were yes or no.

Accountability gaps

8. The audit revealed a number of limitations or accountability gaps. In four

procedures, the achievement was 50% or less. One of the procedures was on

National level whereas three were on Management level.



8

National level

9. The national framework did not provide for measurement and reporting of

performance by including provisions for the following:

Targets (desired level of performance);

Indicators/measures of performance (for each objective);

Monitoring the achievement of targets and indicators;

Defined internal reporting mechanisms (including the format,

contents and frequency); and

Enforcement of laws.

Management level

10. Performance contracts for employees responsible for solid waste did not

exist or did not adequately cover:

Performance measures and targets;

Service delivery in the performance contracts is measured on the

following principles;

o Cost (consistent with budget);

o Quality (in line with the legislation and strategy of the entity); and

o Timeliness.

11. The service delivery agents are not publicly reporting its performance in

achieving the service levels defined above. Specifically whether:

Reports are in the public domain;

Reports are issued frequently (at least annually);

Reports are audited or validated internally or externally;

Reports include a plan of action on non-achievement of targets;



9

Reports include information against measures, indicators and targets

including those in the national framework;

Reports contain information that is simple, understandable and

complete; and

Reports are linking the cost of service delivery to their effects.

12. Training and education needs have not been assessed and provision has not

been made by way of internal education (employees training) and external

education (community training and education) regarding solid waste.

Accountability strengths

13. Three procedures were performed where the countries met the accountability

requirements of 100%. All three were at management level:

the relevant authorities approved the documents that constituted the

service delivery agent’s framework;

the service delivery agent has defined and documented roles and

responsibilities in respect of solid waste and the organisational

structures were aligned to meet the national requirement in terms of

service delivery; and

the different types of service delivery within solid waste management

have been separately dealt with in the policy and procedural

documents.



10

TRANSVERSAL REPORT ON THE ACCOUNTABILITY ARRANGEMEMENTS IN SOLID WASTE MANAGEMENT

Introduction

At its 2001 meeting in Ottawa, Canada, the Working Group on

Environmental Auditing (WGEA) of the International Organisation of Supreme

Audit Institutions (INTOSAI) adopted waste management as one of the central

themes of its 2002-2004 work plan. This resulted in the publication of the WGEA

document “towards auditing waste management”.

2. Subsequent to the INTOSAI WGEA developments and to bring the NEPAD

‘Action Plan for the Environment Initiatives’ (NEPAD: 66) to life, an audit was

conducted on the accountability arrangements, with specific focus on the removal

of solid waste in urban settlements in five countries, namely:

Ethiopia;

Ghana;

Kenya;

Mauritius; and

South Africa.

Reasons for the audit

Problems caused by waste

3. Waste management is an important factor in safeguarding human health and

environmental protection, and most countries, developing and developed, recognise

that waste management is a major concern. Unsatisfactory handling of waste can

lead to the contamination of soil, surface water, groundwater and air. Some

examples are:

Solid waste may contain toxic components;



11

Untreated waste can pollute surface water and groundwater;

Uncontrolled burning of waste produces toxic and carcinogenic gases; and

Leaks of radioactive substances can contaminate the air and soil.

4. Furthermore, improper waste handling and emissions can have negative

impacts on public health, exemplified by:

Transmission of diseases and infections by rodents and vector insects;

Birth defects caused by exposure to polluted drinking water;

Cancer caused by radiation exposure;

Respiratory problems caused by waste sorting;

Uncontrolled burning of waste; and

Odour, littering, unsightliness and noise.

Classification of waste

5. There are many ways of classifying waste for example hazardous,

radioactive, medical waste and non-hazardous/solid waste. For the purpose of this

audit the scope was limited to solid waste.

Importance of effective accountability and governance

6. Across the continent there is the perception that service delivery by public

servants is not adequate or are not improving. Accountability in government is a

mechanism that could be employed to identify where the problem within the public

service has arisen. By looking at the accountability chain from the national policy

to the actual service delivery, officials throughout government can be held

accountable for their contribution or lack thereof, towards effective waste

management.



12

7. There is often a high level of commitment, even on the international stage

such as being party to UN initiatives. However, it is often difficult to establish how

it is reflected in service delivery.

8. For the purpose of the waste management audit conducted, it was expected

that not all accountability arrangements would be in place. The crucial issue is to

see improvements over time, therefore, this audit will be most effective if it is

performed on a regular basis and provides on-going accountability and

benchmarking opportunities. At this stage, the issue of waste is the first in the

series but hopefully the principles and methodology can be replicated in other key

service delivery areas.

Environmental Management Accounting

9. The emphasis that has been placed over the last decade on the sustainable

use of environmental resources increased public awareness, which resulted in a

drive by various organisations to embark on Environmental Management

Accountability (EMA) research and related reporting aspects. Different

organisations have given EMA different definitions (and even names), but in

essence, EMA is simply a better and more comprehensive approach to

environmental management and management accounting, with a particular focus on

costs related to wasted raw materials and other environmental issues.

10. Since different organisations are focusing on EMA, it created a perception

that uniform standards and practices are not developed and implemented to account

and report on environmental aspects. It seems that reporting is done haphazardly



13

and is not always disclosed in public domain. It may, therefore, be necessary to

harmonise the efforts of these organisations to specifically focus on environmental

accounting and reporting in the African context. Harmonising efforts to improve

EMA will strengthen accountability, while it would also assist in implementing a

uniform approach on reporting on environmental matters.

Audit of waste management in an African Context

11. While the majority (62.1 percent) of the African population is still rural,

urban growth rate of nearly 4 percent a year is the most rapid in the world, and

nearly twice the global average (United Nations Population Division, 2001).

Growth rates are predicted to average 3.5 percent per year over the next 15 years,

meaning that Africa’s share of the world’s urban population will increase from 10

to 17 percent between 2000 and 2015 (United Nations Population Division, 2001).

Not only are there more people living in cities, but the cities themselves are

becoming larger and more numerous. The rapid rate of uncontrolled and unplanned

urbanisation in the developing nations of Africa has brought environmental

degradation.

12. Urbanisation created a waste management problem for most city authorities,

states and federal governments, and professionals alike. A visit to any African city

today often reveal aspect of the waste-management problems such as heaps of

uncontrolled garbage, roadsides littered with refuse, streams blocked with junk,

disposal sites constituting a health hazard to residential areas, and inappropriately

disposed toxic wastes. The sheer volume of waste does not actually constitute the

problem rather it is the inability of governments and waste-disposal firms to keep

up with it.



14

13. Solutions to waste management are possible. Communities around the

world, large and small in both developed and under-developed countries have

proven that this problem can be solved effectively. The benefits of sound waste

management to human health and environmental quality outweigh the cost of

delivering these services.

14. The summary of the audit findings, which were identified during the course

of the audit, provides an insight into whether adequate accountability is in place.

All negative findings reflect areas where attention should be drawn and corrective

action taken to ensure that the accountability chain can be completed.

15. The information recorded provides an insight into areas where activities may

occur but where accountability arrangements in place are not always clear or

adequate. It is important to consider that, the deficiencies identified are not

necessarily representative of capacity or resource constraints. Instead, it identifies

the cases where the accountability cannot be determined even though the required

resources are employed. This in plain terms means that we are not sure whether the

individuals to whom responsibility have been given are providing adequate value

for money. This audit is conducted in an environment where there is limited and

often insufficient funds to deliver services. It is, therefore, crucial that

accountability is understood not to be a costly add-on but an essential requirement

of service delivery and democracy.



15

Details of audit findings

16. The audit findings were discussed with the relevant role-players in the

different countries, but findings have not been made public. As a result thereof, an

overall summary, rather than detailed findings is included in this report.

17. The audit procedures were grouped into National (Government policy level

and assurance and reporting) and Management level (Strategy and assurance and

reporting). Detailed findings are included in Tables 1 and 2.

18. The average achievement for the five countries was 70%, with the highest

being 82% and the lowest 55%

Accountability gaps

19. The audit revealed a number of limitations or accountability gaps. In four

procedures, the achievement was 50% or less. One of the procedures was on

National level while three were on Management level.

National level

20. The national framework did not provide for measurement and reporting of

performance by including provisions for the following:

targets (desired level of performance);

indicators/measures of performance (for each objective);



16

monitoring the achievement of targets and indicators;

defined internal reporting mechanisms (including the format, content

and frequency);

defined external (public) reporting mechanisms (including the format,


enforcement of laws.

Management level

21. Performance contracts for employees responsible for solid waste did not

exist or did not adequately cover:

performance measures and targets;

service delivery in the performance contracts is measured on the

following principles:

- cost (consistent with budget)

- quality (consistent with budget)

- timeliness.

22. The service delivery agents are not publicly reporting their performance in

achieving the service levels defined. Specifically whether:

reports are in the public domain;

reports are issued frequently (at least annually);

reports include information against measures, indicators and targets

including those in the national framework;

reports include a plan of action on non-achievement of targets;



17

reports contain information that is simple, understandable and

complete; and

reports are linking the cost of service delivery to their effects.

23. Training and education needs have not been assessed but provision has been

made for training and education regarding solid waste, including internal education

(employee training) and external education (community training and education).

Accountability strengths

24. Three procedures were performed where the countries met the accountability

requirements of one hundred percent (100%). All three were on the management

level. These are:

the relevant authorities approved the documents that constituted the

service delivery agent’s framework;

the service delivery agent has defined and documented roles and

responsibilities in respect of solid waste and the organisational

structures were aligned to meet the national requirement in terms of

service delivery; and

the different types of service delivery within solid waste have been

separately dealt with in the policy and procedural documents.



18

Way Forward

25. The audits were conducted over a three-month period and have provided an

insight into what can be achieved in a small timeframe across the AFROSAI-E

environment. The auditors selected from each country had attended environmental

awareness training given by INTOSAI. However, it is felt that the ability of others

to undertake such an audit would be an obstacle. The key possible scenarios using

the tools and methodologies identified in the audit are to:

utilise the auditors to facilitate other auditors within the sub-region,

for example, the Ghanaians to facilitate the West African

contribution;

to undertake the waste management audit (with the option of

considering electronic working papers) throughout the 23 countries;

go further and consider more relevant and difficult aspects of waste

management, in particular, the performance auditing dimensions; and

undertake research on further issues such as in the health or education

arena.

26. All the options will require a centralised capacity to facilitate, research and

co-ordinate the process. This will also entail collating and summarising

information. A long-term vision would be to set up annual assessment of service

delivery.



19

Table 1: National Level

Procedure % Achievement

Determine whether the national framework

provides for measurement and reporting of

performance by including provisions for the

following:

Targets (desired level of performance);

Indicators and measures of performance

(for each objective);

Monitoring the achievement of targets and

indicators;

Defined internal reporting mechanism

(including the format, contents and

frequency);

Defined external (public) reporting

mechanisms (including the format,


Enforcement

‘50%

Determine whether:

For each of the agencies identified, their

respective roles and responsibilities have

been clearly identified including the

function of monitoring;

‘70%



20

Service delivery agents in particular have

been given the appropriate mandate to

carry out their functions as required by

national legislation and policy;

Clear and specific timeliness for the

implementation of the service delivery

agent’s mandate have been established.

Obtain documentation pertaining to the

national framework including legislation and

policy and determine whether:

There is a national framework including

legislation and policy dealing with waste

management;

This framework reflects internationally

recognised principles on waste

management. These principles of the

waste stream are as follows:

Prevention;

Generation;

Recycle, reuse;

Collection;

Transport;

Treatment and disposal.

‘77%



21

Legislation was revisited during the last 10

years.

The framework addresses the need for

learning and education (internal and

external).

National framework provides for an agent

responsible for the enforcement of the

principles of the framework.

Budget is provided for on a separate line

item for waste.

The Constitution clearly states the rights of

people with regards to clean and safe

environment.



22

Table 2: Management level

Procedure % Achievement

Obtain performance contracts for employees

responsible for solid waste and determine

whether:

There are performance contracts including

performance measures and targets.

Service delivery in the performance

contracts is measured on the following

principles:

Cost (consistent with budget);

Quality (in line with the legislation and

strategy of the entity); and

Timeliness.

Individual targets clearly are linked to the

organisational strategy (or in absence of

that to the national requirements).

‘37%

Determine whether the service delivery agent is

publicly reporting its performance in achieving

the service levels defined. Specifically

whether:

Reports are in the public domain;

Reports are issued frequently (at least

annually);

‘46%



23

Reports are audited or validated internally

or externally;

Reports include information against

measures, indicators and targets including

those in the national framework;

Reports include a plan of action on non-

achievement of targets;

Reports contain information that is simple,

understandable and complete; and

Reports are linking the cost of service

delivery to their effects.

Obtain evidence that training and education

needs have been assessed and whether there is

provision made for training and education

regarding solid waste

These should include:

Internal education (employee training); and

External education (community training

and education).

‘50%

Determine whether:

The service delivery agent allocated (and

documented) available resources based on

priorities and risks.

‘60%



24

The service delivery agent has identified the

additional resources needed to fulfil its solid

waste management responsibilities.

Determine whether there is provision for

community engagement in the planning and

decision making by the service delivery agent.

This could include:

Planning and setting of strategy; and

Corrective actions taken.

‘60%

Determine whether:

Processes and systems are in place to

provide information as required for

measuring and reporting; and was it

communicated to all relevant personnel –

obtain evidence as to the means of

communications to the relevant officials?

Consult with officials to determine whether

they are aware of the provisions of the

document.

‘63%

Determine whether management has

established and documented an operational

framework for fulfilling its waste management

services:

‘74%



25

Determine whether the operational framework

addresses:

Legal and policy requirements, including

those derived from national framework and

internationally recognised principles;

Measurement and reporting requirements;

and

Day to day solid waste management

activities.

Determine whether authority, accountability

and responsibilities are assigned to people with

relevant capacity e.g. is appropriate

delegations in place.

Determine whether positions are profiled

to identify the required capacity of

personnel.

Obtain delegations of responsibility.

‘80%

Determine whether the expected levels of

service delivery for solid waste are

documented. This should be in terms of cost,

extent, quality and timeliness of service

delivery.

‘86%



26

Inspect whether the relevant authorities

approved documents constituting the service

delivery agent’s framework.

Determine whether:

The service delivery agent has defined and

documented roles and responsibilities in

respect of solid waste.

The organisational structure is aligned to

meet the national requirement in terms of

service delivery.

‘100%

Determine whether the different types of

service delivery within solid waste have been

separately dealt with in the policy and

procedural documents.

‘100%



27

PERFORMANCE AUDIT REPORT OF THE AUDITOR-GENERAL ON

THE ACCOUNTABILITY ARRANGEMENTS IN SOLID WASTE

MANAGEMENT IN GHANA BY ACCRA METROPOLITAN ASSEMBLY

Background

At its 2001 meeting in Ottawa, Canada, the Working Group on Environmental

Auditing (WGEA) of the International Organisation of Supreme Audit Institutions

(INTOSAI) adopted waste management as one of the central themes of its 2002-

2004 Work Plan. This resulted in the publication of the WGEA document

“Towards Auditing Waste Management”.

Problems caused by waste

2. Most countries recognise that environmentally solid waste management is an

issue of major concern. For both developing and developed countries, waste

management is an important factor in safeguarding human health and

environmental protection. Unsatisfactory handling of waste can lead to the

contamination of soil, surface water, groundwater and air. Some examples are:

Soil can be contaminated with toxic components;

Waste can pollute surface water and groundwater;

Uncontrolled burning of waste produces toxic and carcinogenic gases; and

Leaks of radioactive substances can contaminate the air and soil.

3. Furthermore, insufficient waste handling and emissions can have negative

impacts on public health, exemplified by:

Transmission of diseases and infections by rodents and vector insects;

Birth defects caused by exposure to polluted drinking water;



28

Cancer caused by radiation exposure;

Respiratory problems caused by waste sorting;

Uncontrolled burning of waste; and

Odour, littering, unsightliness and noise.

Classification of waste

4. There are many ways of classifying waste, for example hazardous,

radioactive, medical waste and non-hazardous/solid waste. For the purpose of this

audit the scope was limited to solid waste.

5. While the majority (62.1%) of the African population is still rural, urban

growth rates at nearly 4% a year are the most rapid in the world, and nearly twice

the global average (United Nations Population Division, 2001). Growth rates are

predicted to average 3.5% per year over the next 15 years, meaning that Africa’s

share of the world’s urban population will increase from 10% to 17% between 2000

and 2015 (United Nations Population Division 2001). Not only are there more

people living in cities but the cities themselves are becoming larger, and more

numerous. The rapid rate of uncontrolled and unplanned urbanisation in the

developing nations of Africa has brought environmental degradation.

6. Urbanisation created a waste management problem for most city authorities,

state and federal governments, and professionals alike. A visit to any African city

today will reveal aspects of the waste management problem such as heaps of

uncontrolled garbage, roadsides littered with refuse, streams blocked with junk,

disposal sites constituting a health hazard to residential areas, and inappropriately



29

disposed toxic wastes. The sheer volume of waste does not actually constitute the

problem, it is the inability of governments and waste-disposal firms to keep up with

it.

7. Solutions to waste management are possible. Communities around the

world, large and small in both developed and under-developed countries have

proven that this problem can be solved effectively. The benefits of sound waste

management to human health and environment outweigh focus on the removal of

solid waste in urban settlements.

8. Subsequent to the INTOSAI WGEA developments and to bring the NEPAD

Action Plan for the Environment Initiatives (NEPAD: 66) to life, an audit was

conducted on the accountability arrangements, with specific focus on the removal

of solid waste in urban settlements in six countries, namely.

Ethiopia;

Fiji;

Ghana;

Kenya;

Mauritius; and

South Africa.

9. The main focus was on African countries, but Fiji was included since they

expressed an explicit interest towards participating in this project and due to their



30

participation in the previous training course presented by INTOSAI and IDI in

Nairobi in 2004.

Importance of effective accountability and governance

10. Across the continent, many people perceive that public services are

inadequate or not improving. Accountability in government is a mechanism that

could be employed to identify where the problem within the public service is arisen.

By looking at the accountability chain from the national policy to the actual service

delivery, officials throughout government can be held accountable for their

contribution or lack thereof towards effective waste management.

11. Accountability implies that mechanisms are present and effective for

transparency in the operational functions of different tiers of government;

responsiveness towards the higher level of the government; population and civic

grievances; standards for professional and personal integrity and rule of law and

public policies are applied in transparent and predictable manner.

12. Often there is high level commitment even on the international stage (such as

being party to UN initiatives). However, it is often difficult to establish how this is

reflected in service delivery.

13. We carried out the audit on the premise that not all accountability

arrangements in place are always clear or adequate. This audit is conducted in an

environment where there is limited and often insufficient funds to deliver services.



31

It is, therefore, crucial that accountability is understood not to be a costly add on but

an essential requirement of both service delivery and democracy.

14. We do not expect that all accountability arrangements will be in place. The

crucial issue is to see improvements over time, therefore, this audit will be most

effective if it is performed on a regular basis and provides on-going accountability

and benchmarking opportunities. At this stage, the issue of waste is the first in the

series but hopefully the principles and methodology can be replicated to other key

service delivery areas.

TERMS OF REFERENCE

15. Following the INTOSAI WGEA training intervention in Nairobi during

February 2004, this audit is aimed at trying to implement sustainable development

issues into the Supreme Audit Institution’s audit practices. The audit is conducted

in terms of SAI’s mandate, to conduct a value for money auditing from the

perspective of efficiency, effectiveness and economy. The intention is to be an

introduction to the accountability arrangements on key service delivery aspects of

the public sector. The first focus has been decided on in line with INTOSAI

initiatives and the topic of solid waste management was selected.

Summary of the audit findings we identified

16. These findings indicate whether adequate accountability is in place. This

study will not make recommendations but will highlight negative findings for

management’s attention for corrective action to be taken to ensure the

accountability chain can be completed.



32

Key audit findings

National level

National framework for waste management

17. A national framework represents the commitment of government to

implement effective waste management. It also serves to guide national efforts and

to establish an accountability chain. A framework could be in the form of

legislation or policy. The national framework is found in the 1992 Constitution and

the Environmental Sanitation Policy (ESP) of May 1999.

18. We found that the national framework only partially exists with regards to

waste management. The Constitution did not provide for the right of citizens to a

clean and safe environment. The ESP on its part seeks to define a systematic

approach and framework within which resources can be used most efficiently.

Additionally, the ESP has eleven objectives it intends to achieve by the year 2020.

We found the planning horizon of 20 years too long for any meaningful evaluation

of policy objectives as some of the strategic and even the particular activities may

be outdated by technological innovations and creation of awareness. Furthermore,

the objectives were not specific and measurable.

19. A national framework only partially exists with regards to waste

management.

20. Various international groups and summits have recognised principles of

effective waste management, including the 1992 Rio Summit and Agenda 21 and

further reinforced by the 2002 World Summit on Sustainable Development held in



33

Johannesburg. Internationally recognised principles of effective waste management

include the following aspects:

Prevention

Generation

Recycle, reuse

Collection

Transport

Treatment/disposal

21. We found that the national framework only partially reflected internationally

recognised principles of effective waste management as it was silent on prevention.

Prevention is the first stage in the waste stream. The motivation behind this stage is

the sustainable use of resources in general. We should use not more of the natural

resources than necessary, and the manufacture of products that do not have any

useful purpose, generates waste. Wanton use of natural resources and the seeming

lack of replenishment and the extended regeneration period calls for look to be

taken at the usage rates.

22. To address capacity issues in ensuring effective service delivery, it is

necessary to provide for training and development of personnel.

23. We found that in terms of training, the national framework included

provisions for education and training on waste.

24. The national framework provides for an enforcement agent (Ministry of

Local Government and Rural Development).



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25. For implementation of any framework the required resources have to be

made available. The specific identification of ‘waste’ in the budget process will

facilitate adequate resources to be applied to waste management. We found that

there was a separate budget allocation for waste.

Role and mandate of agencies

26. A crucial aspect of accountability is a clear and documented understanding

of the respective roles and responsibilities of each of the agencies involved in waste

management, from the national to local levels. The roles and responsibilities of

agencies included the monitoring function.

27. ESP required the setting up of the National Environmental Sanitation

Coordination Council (NESPCC) within the Ministry of Local Government and

Rural Development with the objective of coordinating policy and ensuring effective

communication and cooperation between the various actors involved in

environmental sanitation. According to Chief Director, MLGRD, the NESPCC has

not met for four years, and, thus, providing insufficient information to aid delivery

of the monitoring function of MLGRD. Therefore, the monitoring function is only

partially satisfied.

28. An important aspect of accountability is for timeframes to be set for when

key aspects of legislation are to be implemented. In terms of timeliness,

timeframes, legislation and other relevant national documentation, we noted that

Section 8.2 of NEP reposed the development of Strategic Environmental Sanitation



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Plans (SESPs) in District Assemblies for the implementation of basic

environmental sanitation programmes and services. The policy required District

Assemblies to use short planning horizon of between 10 and 15 years

29. We found the planning horizon not clear and specific enough to ensure that

adequate project management principles can be employed for implementation of

waste management.

Measurement and reporting of performance

30. A primary role of accountability is to facilitate adequate and consistent

measurement and reporting. This can be achieved effectively by setting out

instructions through national policy documents such as legislation or policy. This

requires that the national framework sets out:

i. targets (desired level of performance);

ii. indicators/measures of performance (for each objective);

iii. monitoring the achievement of targets and indicators;

iv. defined internal reporting mechanisms (eg. the format/contents/frequency);

and

v. defined external (public) reporting mechanisms (eg. the

format/contents/frequency).

31. We identified that the national framework only partially included provision

for measurement and reporting. The following aspects were not provided for:

Indicators/measures of performance (for each objective);

Monitoring achievement of targets and indicators;

Defined internal reporting mechanisms (eg. the format/contents/frequency);



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Defined external (public) reporting mechanisms (eg. the

format/contents/frequency); and

Provisions for the enforcement of law.

Management level

Establishing an operational framework

Budget priorities

In most public sector organisations the limited funding requires choices between

different services and limits to the scale of services provided. It is the responsibility

of management to make choices and decide what can be provided from the finite

funding available. Such allocation should be made on the basis of priorities and

risks.

32. We noted that available resources allocated by the central government were

not based on the service delivery agent’s priorities and risks.

33. In addition, it is the responsibility of management to identify those services

that cannot be addressed within available resources and to make relevant decision

makers aware of the shortfall in the budget.

34. We found that the management of the service delivery agent has identified

the additional resources required to fully implement its waste management

responsibilities.



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Operational framework at local level

35. In order to facilitate accountability and transparency it is necessary that the

management of the service delivery agent establishes a coherent operational

framework that captures the requirements for waste management at the local level.

36. This includes legal and policy requirements (including those derived from

national framework and internationally recognised principles of effective waste

management), measurement and reporting requirements, and day-to-day waste

management activities. It is also important that the operational framework be

aligned to the national framework, to ensure effective policy implementation. We

found that the service delivery agent has established an operational framework that

satisfies these requirements.

Approval of operational framework

37. To create an accountable framework, the documentation should be approved

at an appropriate level. We found that Accra Metropolitan Assembly approved the

operational framework of its Waste Management Department.

Developing people

Training

38. Staff capacity is a major barrier to effective service delivery. Consequently,

it is essential that training is provided to address this concern if possible.

39. We noted that:

Training was piecemeal, limited by resource availability; and



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Community training/awareness was provided for.

Roles and responsibilities within the service delivery agent

40. In addition to documentation (systems), the organisational structure (people)

is also essential to provide the necessary capacity for service delivery. This needs

to be defined on an organisational level and be broken down in terms of service

delivery requirements (including solid waste).

41. We noted that the agency has defined and documented responsibilities

relating to the management of solid waste.

Capacity and delegation

42. A key element in the successful provision of any service is to match peoples’

ability and experience to their responsibilities. We identified the following:

AMA profiled each position (in terms of competencies and skills) to ensure

appropriate personnel were at post; and

Delegations of responsibilities were clear and documented.

Performance contracts of staff

43. Performance contracts need to exist to provide individual accountability at

least for senior management down to the level of the manager responsible for

service delivery. In addition, the contracts need to include requirements regarding

timeliness, cost and quality of service delivery in sufficient detail.



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44. We noted that the performance contracts or other mechanisms partially

covered the requirements of performance for assessment purposes. The following

aspects were not covered:

Cost

Quality

45. It was difficult to identify whether individual performance targets were

aligned to organisational targets.

Setting standards and reporting on performance

Aspects of service delivery

46. Accountable public services set their expectations of service delivery before

the commencement of the relevant time period. By setting out predefined

expectations in respect of service delivery, transparency is enhanced. For the audit

we evaluated this in terms of cost, extent, quality and timeliness within policies and

procedures.

47. The audit found that, there was pre-defined framework in place for the cost,

extent, quality and timeliness of service delivery established by management.

48. The cost of service delivery was not linked to the expected or budgeted

levels of service delivery.



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Engaging the community

49. Engaging the community in delivery of services is essential. The

engagement could take the form of training, education, setting standards and

monitoring the activities of service delivery agents. This engagement with the local

community should be included in formal documentation.

50. We found that community involvement in service delivery was extensive

including setting of standards and review of performance.

Systems and processes

51. A strong measurement and reporting framework are essential for effective

accountability. This needs to be at the organisational level and used for internal and

external purposes.

52. During the audit we found that the organisation had established and

documented the processes and systems enabling the reporting in line with the

required reporting framework.

53. The documentation on the processes and systems of reporting obtained from

management was not up to date.

54. The documentation on the processes and systems of reporting was

communicated to those individuals affected.



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Reporting on service delivery

55. As well as setting standards, organisations must report transparently on their

activities. We noted that:

Reports were available in the public domain;

Reports were available at least annually and were audited;

Reporting against measures/indicators/targets were included in the

report;

There was no plan of action for non-achievement of targets; and

The information was simple, understandable and complete.

Service delivery unit

Identification of services for solid waste

56. It is important that solid waste is identified separately in the policy and

procedure documentation of the entity.

57. We found that the policy and process documentation of the entity includes

clearly identified processes for the service delivery on solid waste.



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MissionStatement

The Ghana Audit Service exists

To promote

good governance in the areas of transparency, accountability and probity in the public financial management system of Ghana

By auditing

to recognized international auditing standards the management of public resources

And

reporting to Parliament

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