Behind the paper: beyond the rules – the reality of onsite sanitation regulation

We spoke to Claire Grisaffi, Paul Leinster, Reuben Sipuma, Emanuel Owako, and Alison Parker about their recent research, “New definitions for good practice: Regulators as activists for urban road-transported sanitation in eastern and southern Africa“, published in PLOS Water and part of the ongoing UNC Water and Health Conference Collection with PLOS.

What motivated you to explore the topic and decide on this research question?

The motivation came from firsthand experience of how national regulators and city authorities, in east and southern Africa were trying to scale safe faecal sludge emptying and transport services through a highly diverse private sector. Previous research by the authors indicated that national regulators and city authorities were taking a distinct role in building compliance, as a social and technical actor (Grisaffi et al 2022 and Grisaffi et al 2025). For the Water & Sanitation for Urban Populations (WSUP) affiliated authors these ideas resonated with their experience working with utilities and national regulators in Kenya and Zambia. Utilities were mandated to provide universal access to safe sanitation, and national regulators provided policies and guidelines. However, actual change resulted from very different ways of working, where utilities took new roles in co-opting regulatory tools to engage front line service providers in multi-layered regulatory frameworks and national regulators leant into learning (WSUP 2019).

This research seemed a great opportunity to document these emergent ways of working. The research question emerged from discussion within the author team as to whether these ways of working were really novel, or already part of established good practice in regulation.

Could you talk us through how you designed your study?

The first step in the study design was to develop a clear definition of what was included in good practice roles and characteristics. We took as wide a definition as possible, reviewing seminal literature on regulation, peer-reviewed publications on water, sanitation and environmental regulation, and practitioner literature. Secondary data, collated for previous publications by the author group, ESAWAS and WHO, was then analysed to develop a robust base for key informant interview guides. We then completed key informant interviews with positive outliers: sanitation leaders making change in their organisations, within organisations leading change in the sector. Thematic analysis of interview transcripts and comparison with the established good practice was used to identify emergent, potentially novel, practices.

Did you encounter any challenges during your study?

The main challenge we encountered was how we conceptualised the role of mandated city authorities. Describing mandated city authorities as ‘local regulators’ emerged organically in discussions. It was considered to represent what this group were doing in practice, rather than their legal status. However, this term was considered contentious, endorsed by some interviewees and rejected by others. It could be construed to imply a conflict of interest, or a reduced responsibility for service delivery. It also became increasingly contentious within the author group, with one author ultimately moving to a review role on the paper due to the use of this terminology. In retrospect ‘co-opting regulatory tools’ would have been a more accurate and less contentious term. However, as an author group we do believe that this emerging role of mandated city authorities is an important part of how faecal sludge emptying and transport services are being delivered in eastern and southern Africa.

What did you find most striking or surprising about your results?

Responses to the results varied across the authors. For those further from implementation the recognition of the informal sector as part of the route to universal access was really striking. The recognition by both national regulators and mandated city authorities that those very low-capacity groups serving informal areas need to be supported was unexpected. We had assumed a more hard-nosed stance would be taken, as it is across many sectors, looking to displace or criminalise informal service providers. For the authors affiliated with WSUP and closely involved in the day to day of trying to scale safe faecal sludge emptying and transport services, the results were just documenting and sharing the realities of practice. Mandated city authorities want to accelerate access but rarely have the resources or experience to scale direct delivery. Most service providers are informal and can evade enforcement efforts; engaging this group is a prerequisite for any change.    

How do you think this research will be used and who do you hope might benefit from these new insights?

Some of these insights are already feeding into guidance being developed by WSUP for ESAWAS and into partnerships with national regulators and mandated city authorities. These insights are also relevant to the Rolling out Regulation in Africa (WSUP 2025) initiative led by WHO, ESAWAS and WSUP, which will support the implementation of the WHO Roadmap for Sanitation Regulation (WHO 2025). We hope that this research will be used to support discussions on these multi-layered systems of regulation, recognising and supporting the new role being taken by mandated city authorities in co-opting regulatory tools. We also hope that the research will be used to support the continued progressive engagement of the informal sector in provision of safe sanitation services.

What further research questions need to be addressed in this area?

There are two major areas of research which would be important for both academics and practitioners. The first is around how mandated city authorities can work effectively with the informal sector who may have limited capacity and may not be able to comply with the rigorous standards being introduced. This research should address both how the informal sector should be engaged and supported to enable dignified livelihoods and safe services, and also how legal frameworks should be adapted to allow for the specific needs of this group. There is a wealth of knowledge around this process for other sectors which we could draw on (e.g. the work of WEIGO – see Chen M. and Carre F. 2020). Secondly, and linked to this first question, is how mandated city authorities and national regulators can effectively support and work through membership-based organisations.

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