title: Environmental health regulation in urban South Africa:
a case study of the Environmental Health Practitioners of the
City of Johannesburg Metropolitan Municipality
Creators: name: Couch, RA
Publisher: name: London South Bank University
Year: 2016

description: Environmental health is concerned with relations between the environment and human health
and their management and remains a considerable public health challenge into the 21st century,
particularly for cities where more than half the world’s population now lives. In South Africa
local government Environmental Health Practitioners (EHPs) have been regulating local
environmental health since Victorian times and are well placed to bring protective and
developmental laws to life but are confronted by challenges not dissimilar to their Victorian
forebears. The main research question is therefore: how do the EHPs of the City of
Johannesburg Metropolitan Municipality (CoJ) regulate environmental health? A literature
review developed an interdisciplinary model of governance to describe and explore how EHPs
regulate environmental health (EH) and the factors that could influence this process. This model
utilised a socio-legal framework grounded in theoretical perspectives from criminology, history,
the law, organisational studies, political science and sociology.
A multiple case study strategy was developed to test this model. Qualitative methods were
conducted on 10 street-level case EHPs from four CoJ regional offices through observation,
interviews, questionnaires and the analysis of regulatory documents. These were supplemented
by observations and interviews with other street-level EHPs and their managers and the analysis
of other relevant documents, including quantitative data on the activities of CoJ EHPs.
A new model of governance was developed by this thesis to describe, analyse and explain how
CoJ EHPs regulate and found most of their work focused on a traditional regulatory ‘law
enforcement’ pathway alongside other activities, notably an EH monitoring role for other CoJ
departments and provincial government. But contrary to their Victorian inspector stereotype,
EHPs behaved as responsive regulators and used mainly persuasive approaches (e.g. education,
advice, negotiation), with more punitive approaches generally used for serious cases or when
persuasion fails. This responsiveness was limited by factors including resources and weaknesses
in more punitive approaches. A second regulatory pathway involving EH project and promotion
activities was documented but remained secondary to traditional regulatory work.
In conclusion, the model of governance conceptualised urban EH regulation as the continuous
circulation of power within and between EHPs and local government itself, other spheres of
government and civil society. Power was unequally distributed between these actors, but there
were many opportunities for challenging power that were rarely captured or closed. Local
government EHPs are therefore contributing towards making cities more productive, inclusive,
sustainable and better governed and the model of governance created by this thesis was a useful
tool for exploring their work.