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Controlling substandard products in Nigeria

P.A NWAJAGU

A standard can simply mean a document that specifies the whole requirements that the product must/shall comply with, when it is appropriately examined/evaluated according to specified procedure(s).
Accordingly, the product becomes substandard once any of the important and/or mandatory specifications is not complied with, when examined as above.
A complete standard contains such essential information as (among others), the title, foreword, scope of application; definitions, applicable normative reference(s), mandatory quality/performance criteria, optional criteria, labeling requirements, recommended test methods for evaluation and (sometimes) acceptance criteria.
Appropriate labeling (consumer information) is very important because it provides the consumer with the first line of assistance when making a choice or decision. All over the world (including Ghana Standard Board) appropriate labeling is considered as an important and/or mandatory requirement for quality/regulatory compliance. It is for the same reason that the most successful, widely applied international quality management system standard (ISO, 9001:2008) mandated the implementation of customer-related processes (clause 7.2.1 a-d inclusive). The labeling specification(s) of any product standard provides such information necessary for verification; traceability, recall, identification, applications, specified or intended use, delivery/post delivery services, disposal, statutory and regulatory requirements etc. All these are very important aspects/elements of the quality service, consumer satisfaction and standardization function/management.
The essence of this is that a product that is not appropriately and/or truthfully labeled as required by the relevant standard is definitely substandard. A product is therefore said to be of good standard, or to conform to standard if when examined accordingly and appropriately, the results of such examination(s) conform to its expected quality requirements/specifications or criteria.
Conversely, the product will be substandard if the result(s) of the tests/examinations reveal any form of non-conformance to the stipulated (essential or mandatory) quality requirements/specifications. There is no doubt that a substantial portion of products in our markets are substandard and the need to address this issue is, therefore, very apt.
The concept of quality and its requirements/specifications are applicable to all products whether locally made or imported. While it is true as indicated by the SON that substandard products impact negatively on the economy of any nation, we as a nation need to consider the implication and/or impact of locally made substandard products to our economic misfortunes, if we must move forward. It is largely recognized and well documented that the economies of developing nations (like Nigeria) rest on the strengths/development of the SMEs. The fact also remains that the referenced SMEs in those developed/developing nations are so well articulated that much of what they produce falls within the expected quality specifications. A good study of the growth/development of the emerging economies including the world’s modern factory (China, India) will reveal the fact that a substantial portion of their export products come from their SMEs. The other important observation is that the activities of the SMEs in those developed or developing economies are so well regulated so as not to jeopardize the export potentials/prospects of their respective.
It also needs to be highlighted that a nation whose industrial outputs cannot meet the quality requirements of both the local and export markets is in serious trouble. In such a situation, domestic consumers/demand tends to focus on relatively satisfactory imported products. What needs to be taken out of the above situation is that an unserious domestic industrial output is as dangerous and detrimental to the nation’s economic interests as substandard imported products. The argument may be that it is only a matter of relativity and this should not be entertained by serious minded people. There should be no debate about the fact that Nigeria has a lot of capacity in the SME category to supply much of our demand and drive our development. What is surely lacking is the “appropriate performance” of the SWE (remove the issue of energy or power) to generate/produce what is competitive and, therefore, acceptable to the internal and/or external markets. The cumulative manufacturing attitude of some of our SMEs can be summed up as non-commitment to the first principle of quality management practice, that is, “customer focus”. This lack of commitment results into the unsustainable nature/performance and lack of competitiveness of some of our SMEs.
The simple fact that not every consumer is capable enough to evaluate and confirm the safety/quality of what is sold in the markets (without assistance) and that the protection of the safety of the citizenry is the responsibility of the government, forms the basis/justification for the establishment and funding of the regulatory institutions of any nation.
There is serious public doubt as to the efficacy of the inspections, inspection reports and the subsequent certification/registration of some of these SMEs, their production environments/practices and the products that come out of their activities. What the regulatory authorities of our nation need to appreciate is that these SMEs or “factories” exist among the people and their practices are not hidden from the potential customers. In today’s world of advanced telecommunication and the nascent power of the social media, no information can be hidden for too long. It will surely be exposed and travel far and wide. The control agencies need to know that the apparently silent public may know more than they are prepared to talk, but would rather, react through the exhibition of consumer apathy or rejection of the unfortunate local product(s) and/or preference for the imported alternatives. This is not to say that the same consumer is fully aware of the environment and practices at the foreign factories (SMEs abroad) but because they have not seen the faults, they trustingly accept what comes from abroad.
It is for these very reasons above that we need to step up Nigeria’s regulatory attitude and/or functions even if it is just to shore up the confidence of our internal consumers and market. It makes no sense that responsible authorities dwell on mouthed condemnation of apparent substandard imported products without a corresponding effort at confronting the avalanche of substandard products made at home. It could even be argued that the apparent non-regulation or unserious action against local substandard products might be the impetus for the importation of foreign substandard products, because their merchants and/or suppliers may be feeling that there may, after all, be no regulatory control in Nigeria.
The SON’s World Standards Day March (2014) and statements against substandard imported products need to be viewed against the above observations. The Director General of SON in an interview published in the Punch newspapers of Saturday 04th October, 2014, stated that his hands were tied making it impossible for him to tackle merchants of substandard products. The Director General of SON specifically mentioned the ludicrous low fines stipulated by law as penalty for offenders. Granted that this aspect of the legislation is not helpful, it is to be observed that the SON has been destroying offending products/factories over time as routinely published in the daily newspapers of Nigeria. It does not require any debate to say that the seizure and destruction of offending products is a more deterrent punishment than a small fine (in monetary values). It is to be assumed that the SON has been relying on an existing or subsistent legislation to carry out its destructions in the past. What other instrument can be more forceful and/or effective than this for this country to be considerably or relatively saved from the destructive effects of substandard product from home and abroad.
In the same vein, the SON needs to conduct a survey of locally made products and verify what percentage of them that have complied with the SON’s MANCAP regulation. Curiously, this regulation is designed to facilitate compliance to the appropriate product’s specifications, engender consumer confidence, encourage competitiveness in the industry and ultimately facilitate sustainable economic/industrial development. The SON needs to know that the discerning public is aware that not up to (5%) five percent of products made in Nigeria have the MANCAP registration/compliance. It is also curious that the majority of MANCAP compliance is from industries/businesses in the Lagos environment. About 95% of products made outside Lagos do not have MANCAP compliance. It is speculated that many manufacturers/entrepreneurs/businesses outside Lagos have not heard about the SON’s MANCAP regulation. It needs to be ascertained if the SON has no offices in the other states or why this MANCAP regulation can not be enforced throughout Nigeria. Or if it is not a necessary regulation; why did the SON introduce it ab initio? Does it make any sense to have a supposedly important economic regulation that will not be administered or enforced?  When the MANCAP regulation/policy was introduced by the SON, it was largely hailed as one useful instrument for the regulation and/or control of substandard products, at least, from the home source. The SON, therefore, needs to look back (even on itself) for the reduction of the prevalence of substandard products in Nigeria.
On the other side, NAFDAC as a regulatory agency seems to have lost sight of the fact that food and drugs, in all definitions, are very sensitive products whose safety considerations need not be compromised. The agency needs to realize that Nigerians are aware that many of the NAFDAC numbers on products today are fakes and nothing seems to be happening on the side of the agency to identify these so-labeled products and their fake numbers and advertise/publish them for public awareness. NAFDAC needs to realize that Nigerians live among some of the filthy environments that habit the so-called factories (SMEs) whose products/practices have been approved, registered and numbered by NAFDAC.
The products from some of these unwholesome environments/enterprises are curiously registered and carry NAFDAC numbers. Nigerians living in those environments or who know about them are asking what has become of NAFDAC’s regulations for Good Manufacturing Practice (GMP) and Good Hygiene Practices. Living among these local manufacturers/SMEs, and having full knowledge of the unwholesome manufacturing practices and environment, it may be reasonable to think, assume or rationalize the negative consumer behavior towards locally made products and their apparent acceptance for imported ones even when they may be substandard. Again, the argument or rationale may be that such consumers are not even aware of the situations at the foreign places/sources.
Once again, this situation demands for a step-up of our regulatory performance in order to, at least, shore-up our consumer attitude and acceptance of locally-made products. If this happens, it is expected that the demand for imported (substandard) products will be reduced. The Inspectorate Directorates of NAFDAC and SON need to ascertain the integrity/wholesomeness of their registrable enterprises by demanding documented video coverage and photographic coverage of the inspection visits by their state/zonal officers. This is the verifiable evidence or record of what is obtainable on ground and the inspection officers may not take the risk of presenting what will not be verifiable. NAFDAC and SON should also conduct a nationwide market survey, compile a data of products with their “claimed” registration numbers/MANCAP numbers respectively and verify the information against the agency’s registration data base. From this exercise, NAFDAC and SON should publish all products with their fake NAFDAC numbers or products with misleading or non-existing location addresses and products that have infringed other NAFDAC’s labeling regulations. Similarly, the SON should, from their own data, publish the list of products in the market without their MANCAP registration. The entire public and the nation will be the better from these regulatory exercises.
By so doing, the declining public perception of the regulatory functions, the poor regard of locally made products and the unfortunate preference and hence acceptance of imported and (may-be) substandard products (local and/or foreign) would be significantly reduced. Our local industries will also grow, jobs will be available and our economy will grow sustainably.

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