Abstract

Introduction

South Africa covers 121.9 million hectares and has a total population of about 45 million people ⁽¹²⁾. Land used for agriculture comprises 81% of the country’s total area, while natural areas account for about 9 %. Approximately 83% of agricultural land is used for grazing, 17% is cultivated for cash crop, forestry accounts for less than 2%, and approximately 12% is reserved for conservation purposes ⁽²⁾. The country is the largest maize producer in Africa with a vegetable industry valued at R1.5 billion, representing approximately 0.2-0.3% of the global production.

KwaZulu-Natal (KZN), one of nine provinces in South Africa, lies on the eastern seaboard of the country. It has a sub tropical climate and is endowed with rich natural resources including abundant water and good soils. The Province is occupied predominantly by African Blacks, who account for some 85% of its total population of 9.4 million. Poverty is pronounced in the province with approximately 54% of the total population classified as poor ⁽¹⁴⁾.

Despite its natural resource potential KZN only contributes R6 billion to the national gross farming income of approximately R53 billion (excluding timber). It has been estimated that the province has the potential to increase the value of its agricultural production to almost R22 billion (2002 rand values) ⁽¹¹⁾.

The national agricultural sector provides full or part-time employment for at least 2,23 million people, with an additional estimated 6 million people depended on agriculture for a livelihood ⁽²⁾. Any negative effect on growth in this sector will have a significant socio-economic impact.

South Africa’s regulatory environment

South Africa’s first democratic election in 1994 marked the beginning of a new political dispensation and radical socio-economic and political changes. These changes included inter-alia new employment opportunities, re-distribution of land, access to new markets, and increased development investment opportunities. This has also placed additional pressure on natural resources.

The catalyst for these changes, the South African Constitution, ensured that the country’s development path would be ecologically sustainable. It entrenched a “safe and healthy environment” as a basic human right in the Bill of Rights. This has caused government to make a clear commitment to sustainable development and prompted a comprehensive environmental law reform programme, culminating in a myriad of new sectoral environmental legislation. The impact of the law reform process on the agricultural sector is significant. The two most noteworthy acts impacting on the sector are the National Environmental Management Act (NEMA) and the National Water Act.

Environmental management in South Africa is governed in terms of the NEMA (Act 107 of 1998), which provides for:

• the application of appropriate environmental management tools in order to ensure the integrated environmental management,
• duty of care and remediation of environmental damage, requiring every person who causes, has caused or may cause significant pollution or degradation of the environment to take reasonable measures to prevent such pollution or degradation from occurring, continuing or recurring,
• tools to ensure integrated environmental management

The Regulations promulgated, in terms of the Act, for managing potential impacts require an assessment (Regulation No. R. 385 of 2006) by an independent practitioner in a specified manner for activities listed (Regulation No. R. 386 & 387 of 2006) and stipulates a decision making process for the relevant authority. These assessments, depending on the nature of the development or location, may either be a Basic Assessment, a Scoping Assessment, or a full Environmental Impact Assessment. In respect of the agriculture sector the following activities apply:

• the construction of infrastructure for the concentration of livestock, aquaculture & mariculture, agri-industrial activities, dams and weirs,
• the removal, damage or transformation of indigenous vegetation
• the abstraction of groundwater
• the subdivision of land
• the release of organisms for biological pest control
• the extraction of peat

The National Water Act (Act 36 of 1998) has most probably the next greatest influence on the sector. The Act provides for:

• the establishment of water quality targets and the determination of resource quality objectives requiring a balance between the need to protect and sustain water resources on the one hand, and the need to develop and use them on the other,
• the distinction between a basic human needs reserve and an ecological reserve ( quantity and quality). The basic human needs reserve provides for the essential needs of individuals whereas the ecological reserve relates to the water required to protect the aquatic ecosystems,
• responsibility for taking measures to prevent pollution of water resources by the person who owns, controls, occupies or uses the land and if measures are not taken, the authority may itself do whatever is necessary to prevent the pollution or to remedy its effects, and to recover all reasonable costs from the persons responsible,
• the regulation of land-based activities which reduce stream flow, by declaring such activities to be stream flow reduction activities, following which an authorization with conditions is required,
• the requirement of additional information from the applicant, which may entail the undertaking of an environmental or other assessment, which may be subject to independent review.

The agricultural sector is also subjected to a plethora of other acts and regulations pertaining to the day to day practices of farming, ranging from veterinary requirements to issues of labour and occupational health and safety matters.

This paper will not explore all the relevant acts and regulations; suffice to say that the new regulatory framework places huge demands on the sector with the potential to stifle growth. For the individual farmer compliance with such a range of prescripts are fraught with risks.

Global arena

Following a period of economic isolation, South Africa was allowed back into the world trade arena after 1994. The re-entering into the global arena resulted in a rapid growth in the primary production sector with significant economic and social spin-offs. The growth in the agricultural industry was as result of a range of competitive advantages such as world class infrastructure, counter seasonality to Europe, diversity of climates, favourable exchange rate, and competitive input costs which created new opportunities for farmers ⁽⁴⁾.

However, this bliss was soon met with a variety of non-tariff trade barriers ranging from trade restriction in certain products, naming restrictions, and production standards/specification requirements over and above the normal product quality and phytosanitary requirements.

Changes and growth in the global economy, global value chains and market drivers brought about increased pressure in respect of corporate social responsibility and environmental performance. These new drivers were especially evident in the pressures placed upon northern hemisphere buyers controlling the southern hemisphere suppliers and not being able to account for their suppliers occupational and environmental performances ⁽¹⁾. This resulted in increased attention in the international market arena on sound environmental practice by developing countries entering the global market.

The European Union Commission for Agriculture, whilst highlighting the importance of food security, recommended that developing countries be granted time to adapt in order to fully benefit from the expansion of world trade due to new opportunities created and increased market access ⁽¹³⁾. The Commission went on to make a submission which stated that measures aimed at protecting the environment was relevant to both the developed and developing countries. The associated series of recommendations were eventually captured in the Doha Ministerial Declaration. The Commission also indicated that efforts should be made to strengthen and re-focus product-related environmental policies to develop a market for greener products ⁽³⁾. These sentiments were strengthened and expanded in the Millennium Development Goals (No 7, Target No. 9) and the World Summit on Sustainable Development’s Johannesburg Plan of Implementation.

Domestic Sectoral Drivers

Farmers who had the capacity, been in the export market, or who established cooperatives responded to the new standards by implementing Eurepgap (in the EU market context) and getting certified, thus retaining their market position and exposing new opportunities. Emerging and small scale farmers and to some extent commercial farmers who had not been exposed to certification schemes, coupled with the new pressures on the sector resulted in the majority of farmers not being able to meet the new challenges or exploit the new opportunities.

Although there is a year on year growth in export volumes, both commercial and emerging farmers are finding it increasingly difficult to meet export requirements efficiently whilst complying with the environmental, labour, and occupational health and safety legislation. These factors all have a limiting effect on the growth potential of the sector.

The agricultural sector in South Africa raised its objection to the environmental legislation and in particular the impact management Regulations. These Regulations require a formal impact assessment by an independent practitioner. Obviously this takes place at great expense, with great delays, and with no guarantee that the application is going to be successful.

The social changes in SA increased pressure for access to land and resources with the effect that more onus was being placed on farmers to play a defining role in biodiversity conservation. The Sector did however realise that it had to improve and demonstrate that it manages its natural resource effectively. Producers also had to find ways to backup their clean green marketing campaigns, avoid reputational risk and still keep their input costs at a reasonable level.

The Province of KwaZulu-Natal developed a “Provincial Growth and Development Strategy” following an in-depth analysis of the socio-economic conditions in the province. Based on the outcomes of the analysis a provincial response strategy to economic growth was developed; a selected few are ⁽⁵⁾:

• A framework to ensure the preservation, enhancement, extension, sustainable development and conservation of natural resource assets of the province,
• To create a framework for trade and investment that will facilitate economic growth in the manufacturing and service sectors and to improve access to national and global markets,
• To create a framework to consolidate, develop and diversify the province’s agricultural bases in order to achieve sustainable competitive advantage through value-adding activities, create jobs and transform the economic structure of the province,
• A framework for the promotion of equitable environmental awareness and education programmes to improve environmental literacy, appreciation and increased capacity to deal with environmental issues,
• Ensuring that all programmes are compliant with legislative requirements addressing conservation, environmental management and sustainable development,
• To ensure programmes are integrated at inception, execution and assessment by the three spheres of government, business, labour and civil society as part of the participatory democracy ethos.

The provincial Department of Agriculture & Environmental Affairs responded by developing a vision “to optimize the agricultural potential and environmental stability for sustainable livelihoods” in KZN. In order to achieve this, the department made it its mission to “ensure sustainable livelihoods” by contributing to economic growth, reduce poverty, and develop communities through partnerships, and ensure the sustainable use of agricultural and environmental resources ⁽⁶⁾. The department went on to develop a comprehensive set of programmes, set out in terms of the “ladder of agri-development ⁽⁶⁾, see diagram 1. This “ladder” is used to plot develop and plot projects aimed at achieving the provincial objectives and give effect to the departmental mission.

Diagram 1: Ladder of Agricultural Development (DAEA Strategic Plan 2005-2010)

This “ladder” highlighted the need to integrate environmental aspects throughout the institutional programme levels and the need of an integrated system to assist farmers meet legal and market requirements in their endeavour to move “up” the ladder.

Departmental response to support the sector

The Department considered various options to assist the provincial agri-sector meet international export requirements, access global markets, and stimulate new opportunities, whilst still meeting its environmental objectives. The intention was to assist farmers with implementation, conduct the auditing as an “internal” body and provide a label of certification which will be acceptable to the EU.

However this was eventually deemed as not feasible due to the significant resource requirements it would have placed on the department. Further to which the participant’s individual success depended on the groups’ performance and last but not least it was felt that Eurepgap rather addressed food health and safety issues and not environmental issues in a holistic manner.

Initially the Department considered assisting farmers to implement an ISO 14001 system but was discouraged by the implications of having farmers audited by a third party. The opinion was also held that a conformance based system, such as ISO 14001, would not address issues regarding negative practices and improving environmental conditions. The Department then considered providing farmers assistance in respect of the EurepGAP standards. EurepGAP was considered due to South Africa exporting 35.4% of its total export to the EU ⁽⁷⁾ and it was felt that it provided more environmental practice assurances by promoting good agricultural practices, than ISO 14001 for example ⁽¹⁶⁾:

• The product must be traceable to the point where it was grown,
• A recording system for each field, orchard or greenhouse,
• Dates, quantities, method of application and operator details of fertiliser applications for each field,
• Fertiliser must be stored in a clean, dry, covered area separate from nursery stock, fresh produce and pesticides,
• Protection of crops against pests, diseases and weeds must be achieved with minimum pesticide input and recognised Integrated Pest Management techniques must be used on a preventative basis,
• Chemicals banned in the EU must not be used on crops destined for sale in the EU,
• Records of pesticide applications must be kept, including information on the date, crop, location, trade name, operators name, justification, quantity and machinery used,
• The grower and/or supplier must be able to provide evidence of residue testing.

Various options were considered such as acting as agent for farmers in a “Group Certification Scheme” option (internal verification) allowing them to progress to a “Group Benchmarked Scheme Certificate” (external verification).

However, initial discussions revealed a general perception that the volatility of the South African Rand, cumbersome administrative requirements, consumer apathy towards environmental standards, and rigorous external auditing nullified the potential market benefits of a certified system. Compliance to legal provisions and potential market premiums was also deemed to be a poor motivator for a complex system.

It became abundantly clear that a farmer’s lack of resources in implementing a complex management system was but only part of the constraint and that government’s own resource constraints was a limiting factor. Government’s constraint did not only relate to financial and human resources but to the implementation of the environmental legislation. These implementation difficulties is viewed as having an equal effect on the sector responding to a growing market as what non-tariff measures, labour, occupational health & safety, and phytosanitary requirements may have. The positive attributes of self regulation became a major motivation in finding a solution to meeting the sector requirements. As with the Norweigian OHS system the opinion is held that self-regulation must be grounded in the integration of the environmental issues with the internal organization of a company and making it a management issue rather than a compliance problem ⁽¹⁾. Further to which it was felt that a lighter touch in the regulatory environment would increase opportunities, productivity and competitiveness, lessen pressures on government resources and improve the regulators image.

The feasibility of developing a tool which could address good agriculture practices, sound environmental management, occupational health & safety, and labour issues was then considered.

Based on various global practices it was felt that “the “tool” had to meet certain basic requirements, such as:

• It must be voluntary
• provide a win-win outcome for the farmer
• be achievable for emerging farmers and functional for commercial farmers
• must require a stated commitment by the party
• must have measurable objectives and targets
• must include monitoring, reporting & document control
• allow implementation in a staged manner
• be compatible with the ISO 14000 series and Eurepgap
• allow for different levels of complexity, ultimately covering Quality and OHS standards
• have regulatory credibility
• provide for 1^st, 2^nd, and 3^rd party auditing

An environmental management system holds various benefits depending on the extent of implementation and the sector where implemented. The benefits envisaged for both emerging and commercial farmers as well as the provincial economy include:

• Reduction of input costs
• Improved efficiency of resource use
• Improved integration into global value and supply chains
• Increase production of demand products
• Increase value addition and diversification
• Diversification markets
• Competitive infrastructure and systems
• Comparative performance claims
• Improved response to market and environmental changes
• Attract/Develop new technologies
• Expansion of services in respect of certification & training bodies
• Improved access to finance
• Reduction in insurance premiums
• Improvement of relations with authorities
• Reduction in legal risk
• Reduction in administrative burdens of authorities

Proposed EMS model and provincial role-out

In order to achieve success in implementing any system which addresses environmental, social and market related issues, a multi sectoral approach is required. An approach such as this would in other words require the active participation of relevant institutions from all three spheres of government. Government’s role as enabler is primary to success, in that it must provide an institutional platform from which incentives and assistance with ecosystem services analysis, training and material development, and consumer education can be provided.

The Sector’s role on the other hand would be to identify a champion who on behalf of all farmers ensure and promotes consistency and expansion of the systems application. It would be imperative for the sector to establish a network which will develop and maintain specific BMP’s through consensus based decision making and promote consumer awareness.

The opinion is held that the system’s strength lies in its simplicity, consistency and extent of application. Allowing for progressive implementation and comparability with other systems in the value chain will contribute to the systems ease of implementation and sustainability.

For a properly functioning system market competition is required, for competition to be effective well informed consumers are required which exercises real choice. The education of consumers is viewed as the responsibility of both the government as well as the sector representative associations.

The farmer acting as primary driver is the most critical contributor to a system’s success. Primarily the farmer has to accept the prospect of future tangible benefits and not immediate premiums in whichever form. It is further imperative for the farmer to have ability and willingness to identify, manage and understand the impacts their business has on the environment and adopt new management practices. The challenge would however lie in developing incentives which encourage the farmer to maintain and improve system and ultimately report confidently on their performance. Options for incentives abound ranging from rates and tax reductions for natural areas to regulatory relaxations.

Diagram 2: Schematic representation of proposed EMS model

As mentioned earlier key to the success of both implementing and sustaining an EMS which caters for commercial and emerging farmers would its simplicity and expanding potential.

The opinion is thus held that the system should consist of a core set of standards, criteria, and management methodology. The management methodology relate to the basic documentary requirements, record keeping systems, legal registers, etc. The argument is that should a farmer not have the capacity to go any further such farmer’s management practice is at least improved.

Upon implementation of the basic or system foundation further criteria could be “plugged in” depending on the nature of the operations, the farmer’s capacity, intended market, or legal risk profile (see diagram 2).

Regardless of the level of system implemented or the number of additional factors included, monitoring, reporting, improvement and expansion would be required as contributing to the long term success and deriving maximum benefits from the implementation. Monitoring happens at two levels, firstly the continual monitoring of actions and performance by the farmer and secondly the annual internal system review which could include a second or third party review or audit.

In order for the system to provide benefit to the farmer, apart from the improvement in management practices and benefits derived from that, advertising and reporting on performance is crucial. It is accepted that farmers may be reluctant in reporting to a regulatory authority in fear of being prosecuted for transgressions. However examples does exist where the farmer reports to the specific sector representative body whom intern provides feed back assistance and in turn report to the regulatory authority.

Last but not least is the improvement of the system and its expansion in respect of more factors being added. Although the system may, in its simplest form may be conformance based, ie. the farmer must conform to the system established, market and legal forces ultimately require a performance based system. As a performance based system the farmer’s performance against a variety of criteria and standards are measured.

Consistency in the nature of the EMS model is seen as critical to the systems’ long term success and increasing consumer understanding and use.

Diagram 3: Schematic representation of EMS role-out

Role-out of an EMS can only commence with political support. This support would act as catalyst for releasing funding and institutional support. Upon receipt of the political support a parallel process of activities or actions are envisaged (see Diagram 3). The Department would be responsible for developing a policy framework and a conceptual EMS document in consultation with a multi-sectoral working group. The working group would primarily consist of regulatory authorities and representatives from the sector.

Upon completion of the basic documents the sector in conjunction with the department would embark upon a training and information dissemination phase during which two or three pilot farms are identified.

It would be incumbent upon the authorities to supply the initial ecosystem services survey in order to ensure a comprehensive and credible environmental baseline. Further to which the sector would also be primarily responsible for the development and refinement of best management practices (BMP’S) for the initial pilot studies. Although the department will assist in this development “ownership” for the BMP’s will only be ensured if the sector and farmers do the development. It is further imperative that the BMP’s are complementary to government legislation and regulation

Following the development of the BMP’s, system implementation and monitoring and reporting becomes a continual cyclic process.

The department on the other hand would maintain a process of facilitating and maintaining the multi-sectoral working group, providing export and sectoral support. Through the implementation of incentives corporate responsibility would be promoted throughout the value chain and thus striving for a life-cycle approach to good environmental practice. What has been evident in a number of similar ventures is the importance of government continuing to play an active role in providing institutional coordination and facilitation. Further to which the opinion is held that considering the government’s research potential, whether directly or indirectly, remains critical in maintaining the integrity of the system and its application across the economic spectrum.

Babarki et al. (2002) in a survey of 177 ISO 14001 certified companies in the United States identified the following factors to be the greatest obstacles and requiring the most effort during implementation of the ISO system:

• time it took to obtain a certificate (8-19 months),
• identification of environmental impacts and aspects,
• high cost of certification due to extensive documentation, employee training, and auditing costs,

At present two forms of risk have been identified firstly risk associated with the development and implementation which could include the following:

• producers are left out of the decision making process
• costs of implementation & maintenance may exceed benefits
• lack of clear market benefits
• lack of institutional support
• limited capacity and resources to implement and maintain
• unavailability of Best Management Practices
• lack of ecosystems services data
• lack information on potential environmental impacts

And secondly risks associated with the maintenance of an EMS, which could include:

• dwindling institutional interest and support
• rigorous regulatory approaches
• lack of monitoring & reporting
• system and labeling inconsistency
• consumer apathy/confusion
• apathy in continual system improvement
• continual changes in market requirements or standards

Considering the approach proposed, several short terms challenges are evident. Initially a process of training the trainers is required in order to build momentum for the role-out, create an understanding of the principles and advice the farmers effectively.

Enough positive examples exist to acquire political interest and support, however maintaining that interest in the face of other social pressures would require positive market responses. Further to which political support would be imperative to secure institutional support and funding. Institutional support need to include consideration of a support structure for bridging the gap between agriculture and environment. It is envisaged that with appropriate understanding and capacity a less heavy handed approach to regulation could be adopted. This in conjunction with other positive spin-offs would provide for a trust relationship to develop between the authorities and the sector.

Funding would need to be secured for conducting the initial ecosystems services surveys and developing BMP’s and farm level indicators.

Last but not least maintaining linkages with other international EMS forums will ensure a uniformity in the application of EMS and thus conformance to international best practice.

The Noordsberg Initiative

The Noordsberg Canegrowers is an association of approximately 200 commercial farmers in KwaZulu-Natal, producing approximately 1.4 million tons of high grade cane per annum (19). Various aspects led the farmers in 1998 to collectively agree on implementing an ISO 14001 system in order to sustain their farming practices and reduce their environmental impacts in a changing economic and market environment. Some of the driving forces included ⁽⁸⁾:

• their previous exposure to Forest Stewardship Council and EuroGap systems
• experienced the potential benefits of improved business, market access & better management,
• envisaged a potential market edge with environmental barriers once trade barriers fall,
• pressure from environmentalists and government,
• pro-active approach to having their activities declared a stream flow reduction activity

This initial process concluded in 2002 with the development of environmental management guidelines, a self audit and second party audit checklist.

In 2004 a partnership between the farmers and Mondi Wetlands Project was established to implement the World Wildlife Fund’s Global Freshwater Programme. With funding acquired from the WWF programme the partnership agreed to review the progress made with developing their “best management practices” and review the current system. The review was also to consider the feasibility of simplifying the existing system, whilst allowing for possible certification of “Green” sugar ⁽¹⁹⁾. The review concluded with the suspension of the ISO 14001 system and a revision of their Environmental Policy. A new Sustainability Charter was developed and the “Noordsberg Canegrowers Environmental Management Guidelines” was amended to incorporate the newly developed principles, criteria, indicators, and verifiers (Scotcher, pers comm).

The newly developed system was called the Sustainable Sugarcane Farm Management System (SuSFarMS). The principles underpinning the new system are ⁽¹⁹⁾:

• That economically viable sugarcane production is maintained or enhanced
• That the rights and wellbeing of employees & local communities are upheld and promoted
• That natural assets are conserved, critical ecosystem services are maintained and agri resources are sustainably used

Subsequent to the initial system implementation and subsequent improvement of the system the farmers have found that their was a much greater willingness by the national water authority and sector association to discuss environmental impacts, stream flow reduction, and work with external parties to improve its environmental performance (Koopman pers comm.) The national water authority went as far to indicate their willingness to favorably re-consider the declaration of sugar farming as a stream flow reduction activity (Scotcher, pers comm).

These endeavors were independent of the provincial Department of Agriculture & Environmental Affairs’ investigation and without involvement from the department.

Observation made during the 2006 Australian Study Tour

What was immediately evident form the National EMS Implementation Plan ⁽²⁰⁾ was the significant Federal political support. This support withits associated financial funding from both Federal and State sources is a major contributing factor in the EMS success. The channeling of this support through the autonomous and functional Catchment Management Agencies allowed for the linking of the EMS to the foundations laid by the Australian Landcare project. In addition, the extent of devolution of powers to these agencies further assists the implementation.

A further positive result of the above-said was that due to the involvement and active participation of various authorities the EMS concept has credibility with the relevant authorities thereby improving the relationships between the farmers and authorities.

Contrary to most opinions the most successful systems were observed where an ecological goods and services approach was adopted versus an economical approach, supported by a sector specific “Code of Best Practice”, develop by the sector and adopted/ ratified by all parties. Despite this approach it remained linked to competitiveness based in natural resource management objectives.

Other success contributing innovations observed included that the system be simple, cost-effective, user-friendly, adaptable, and integrated with other management tools.

The sustainability of an EMS project lies in a combination of the various approaches requiring a system which can be gradually implemented with each participant choosing the level at which he/she wants to participate.

What was of concern was that no uniform core system was observed. The impression was that the standards of ISO 14001 are, in most instances, adopted to suit each promoting agent or group, and not necessarily in support of the system. Therefore, although improved environmental management in agriculture is achieved, the success of the overall EMS may very well be negatively affected by the various adaptations taking place. The opinion is held that although a specific sectoral group may have a form of EMS its credibility will eventually be measured against its comparability with similar or other recognized systems (viz. ISO 14001 or EurepGAP). Further to which once a product is put on the market there is relatively little that can be done to improve its environmental characteristics. Therefore all environmental efforts will be in vain if consumers do not buy greener products or use them in an environmentally friendly way ⁽³⁾ due the confusion which will arise from a myriad of different standards. This is already evident in the variety of “eco” labels observed, where the differences are fairly obscure.

Beyond implementation no reporting procedures or structures were observed raising the question whether the funding agencies could measure the success of their investment. This concern could be based in the indistinct role of the various federal, state and other agencies in system maintenance and development.

References

1. Jenkins Rhys, April 2001. Corporate Codes of Conduct: Self Regulation in a Global Economy. United Nations Research Institute for Social Development. www.unrisd.org/unrisd

2. Department of Agriculture, 2007. Sectoral Overview and Performance. Strategic Plan DoA. http://www.nda.agric.za/docs/StratPlan07/07sectoral.pdf (April 2007)

3. Commission of the European Communities. 2001. Green Paper on Integrated Product Policy. Brussels. www.europa.eu.int (August 2003)

4. www.southafrica.info.doing_business/economy/key-sectors/agricultural-sector.htm (May 2004)

5. KwaZulu-Natal Government, 2005. Provincial Growth And Development Strategy, Version 3.1

6. KwaZulu-Natal Department of Agriculture & Environmental Affairs, 2005. 2006 – 2007 Annual Performance Plan for KZN Agriculture & Environmental Affairs.

7. Glassheim. E. 2004. EUREPGAP: A private sector initiative to guarantee food safety and environmental standards. www. ngplains.org. (May 2004)

8. Scotsher, J. et al. 2006. The Noordsberg Canegrowers Sustainable Sugarcane Farm Management System (SusFarMS): An example of Sectoral Environmental performance standards.

9. National Environmental Management Systems Implementation Plan (Australia) http://www.affa.gov.au/ems_plan

10. Babakri K.A, Bennet R.A. , Franchetti M. 2002. Critical Factors for Implementing ISO 14001 standard in United States industrial companies. Journal of Cleaner Production 11 (2003) 749-752.

11. KZN Department of Agriculture & Environmental Affairs, March 2007. Cabinet Indaba Presentation V2_1

12. Statistics South Africa, 2004. Stats in Brief 2004. ISBN 0-621-34972-0

13. WTO and Agriculture: European Commission proposes more market opening, less trade distorting support and a radically better deal for developing countries. Brussels, 16 December 2002. IP/02/1892. www.euractive.com (May 2004)

14. KZN Government. 2004. KZN Province – A profile Analysis. Office of the Premier, Pietermaritzburg.