In 2018, Kenya’s Ministry of Agriculture introduced new rules under the Food (Food Crops) Regulations, a set of laws anchored in the Crop Production and Livestock Act (Cap 321). One clause in this law (regulation 30) shocked farmers across the country. It is said to have stated plainly that “a grower shall not use raw animal manure for the production of food crops.” This proposal faced significant public opposition during the drafting process.
Although the regulation was meant to safeguard public health and align Kenya with international food-safety standards, it immediately triggered public outcry. Smallholder farmers, advocacy groups, and agronomists accused the government of disregarding traditional, low-cost farming systems. For generations, farmers in Kenya have relied on cow dung, goat droppings, chicken litter, and other organic wastes to fertilize their land. The manure enriches soils, improves structure, and reduces dependency on expensive chemical fertilizers. The sudden prohibition seemed not only punitive but also detached from smallholder realities.
What the Law Says
The 2018 Food (Food Crops) Regulations contain several provisions to ensure safe, sustainable farming. Regulation 30 explicitly forbids the use of raw animal or human waste on food crops. The intent, according to the Ministry, was to prevent contamination of produce by harmful bacteria such as E. coli, Salmonella, and Listeria, which can survive in untreated waste and enter the food chain.
Other sections of the regulation restrict the growing of crops near garbage dumps, sewage outlets, or industrial zones that may contaminate soil and water. The overarching goal was clear: protect consumers and improve Kenya’s export credibility by aligning with international safety standards. However, many Kenyans saw it differently. To them, the law was yet another example of policy crafted without consulting those who would feel its weight the most: smallholder farmers who produce over 70 percent of the country’s food.
Why Farmers Reacted Strongly
The following is an outline of reasons that caused farmers to oppose the law;
1. Threat to Smallholder Livelihoods: For mixed farmers who rear livestock and grow crops side-by-side, manure is a natural fertilizer source. Buying synthetic fertilizers is expensive and, in some regions, logistically difficult. The regulation effectively criminalized an age-old practice that costs farmers nothing but their labour.
2. Rising Production Costs: Composting manure to meet safety requirements demands space, labour, time, and sometimes added materials to accelerate decomposition. For many smallholders, this is a significant burden, especially when they are already struggling with low margins.
3. Soil Fertility Concerns: Chemical fertilizers boost yields but do little to maintain soil structure or organic matter. Organic manure, in contrast, enhances microbial life and improves water retention which is crucial for resilience against droughts. Many feared that banning manure would accelerate soil degradation.
4. Implementation Confusion: The regulation did not specify how compliance would be monitored or what defined “treated” manure. Would partially composted dung qualify? Who would inspect farms? Such ambiguities created uncertainty and anxiety among farmers.
5. Food Security Implications: If manure use was restricted and fertilizer prices remained high, yields could decline, undermining Kenya’s goal of achieving food self-sufficiency. Critics argued that the law risked worsening, rather than solving, food insecurity.
Understanding the Science Behind the Law
Despite the uproar, the scientific rationale behind the ban was not without merit. The Scientific Animations Without Borders (SAWBO) program which produces educational animations for farmers explains in one of their videos that raw or improperly composted manure can carry serious health risks if applied at the wrong times or in the wrong way.
In addition to the content in the SAWBO animation video, general scientific knowledge states that animal manure may contain E. coli, Salmonella, Listeria, and parasitic eggs. When fresh dung is applied to soil, these pathogens can survive for weeks or months, contaminating crops, especially those eaten raw. The risk increases depending on when and how the manure is applied.
Timing Matters: When Manure Use Becomes a Hazard
This does not outlaw the use of compost manure on crops, but helps to understand that timing the application of manure matters most as stated in the following cases.
1. Immediately After Collection: Using fresh dung directly on crops is highly dangerous. According to scientific guidance, pathogens in raw manure can easily transfer to vegetables, herbs, or root crops. Farmers who apply manure soon after collecting it from livestock expose themselves and consumers to diseases such as salmonellosis and diarrheal infections.
2. Just Before Harvest: Applying manure close to harvest time even if partially composted gives pathogens no time to die off. If the interval between manure application and harvesting is too short, contamination risk remains high in crops such as kale, spinach, or lettuce, which are eaten raw, are particularly vulnerable.
3. On Crops Grown for Direct Consumption: If composting is incomplete the pile did not heat up enough or was not turned regularly, harmful microorganisms may survive. Using such “half-ready” compost on vegetables or fruits eaten raw, like tomatoes or herbs, can spread disease.
4. During Heavy Rain or Irrigation: When manure is applied on the surface during rainy periods, splash water can carry pathogens onto the leaves or edible parts of plants. SAWBO animations emphasize applying composted manure early in the season or incorporating it into the soil to prevent runoff contamination.
5. In Fields Shared with Animals: Fields where livestock graze or where animal waste is deposited directly pose high contamination risks. Crops planted too soon after animals leave the field may carry pathogens from manure into the food chain.
Safe Composting and Use: Lessons from SAWBO
SAWBO and other agricultural health experts recommend proper composting to make manure safe and effective. The process includes:
- Mixing animal dung with plant residues and kitchen waste.
- Ensuring adequate moisture and aeration.
- Turning the pile regularly to promote uniform heating.
- Allowing enough time (often several weeks to months) for the compost to reach high internal temperatures that kill pathogens and weed seeds.
Once the compost is dark, crumbly, and earthy-smelling (not foul or sticky) it is ready for use. Importantly, apply compost well before planting or early in the crop’s growth cycle, not just before harvest.
International food-safety guidelines, such as those from the FAO and WHO, suggest at least a 90- to 120-day interval between manure application and harvest for crops eaten raw. While this may vary by climate, such a buffer ensures that any remaining pathogens die off before crops are consumed.
Kenya’s attempt to ban raw manure was rooted in legitimate food-safety concerns. However, blanket bans rarely work where livelihoods and tradition intersect. The challenge is to find balance by encouraging safe composting and proper timing without punishing farmers.
The government, agricultural extension officers, and NGOs should collaborate to:
- Train farmers on composting techniques.
- Watching and dissemination SAWBO content on composting while encouraging scaling within communities.
- Provide clear, practical guidance on safe intervals and handling.
- Encourage a combination of composted organic matter and moderate chemical fertilizer use to sustain soil health.
The outcry over Kenya’s manure regulation reveals a deeper truth about agricultural policy: science and practicality must go hand in hand. Yes, raw manure can endanger public health if misused as the SAWBO animations clearly show. But with education, proper composting, and sensible timing, manure remains one of the most valuable resources for building healthy soils and resilient farms. Rather than banning it outright, Kenya can lead by example by promoting safe, informed, and sustainable manure management that protects both people and the planet.
