The Practitioners Without Posts: South Africa’s Food Safety Paradox
In the first quarter of 2024, the National Department of Health appointed 2,066 health professionals across South Africa. The breakdown, reported by SAnews, included 1,121 medical officers, 579 professional nurses, 127 allied health workers, 100 pharmacists, 91 radiographers, 23 dentists.
And nine environmental health officers.
Nine.
Six months later, six children in Naledi, Soweto, died after eating snacks from a spaza shop contaminated with Terbufos — an organophosphate pesticide that has no business being anywhere near food. Within weeks, the death toll across Gauteng and KwaZulu-Natal climbed past 22. President Ramaphosa addressed the nation. A massive spaza shop registration drive was ordered. Environmental Health Practitioners were suddenly the most sought-after professionals in the country.
The same profession that received nine posts out of 2,066 appointments.
This is the paradox at the centre of South Africa’s food safety system: a documented shortage of thousands of practitioners, qualified graduates who cannot find work, a national crisis that demands exactly their skills — and a funding architecture that prevents the obvious from happening.
The Numbers Nobody Can Reconcile
The arithmetic is not complicated.
South Africa’s National Environmental Health Policy, aligned with World Health Organisation guidance, sets the benchmark at one Environmental Health Practitioner for every 10,000 people. With a population exceeding 62 million, the country needs approximately 6,200 EHPs.
It has roughly 1,750.
In November 2025, CoGTA Director Mohlatlego Rabothata told the Small Business Development Portfolio Committee the exact figure: 1,751 EHPs employed nationally, with a deficit of 4,450. As SABC News reported, he called it “one of the areas of serious concern” because municipalities simply do not have the capacity to monitor food being sold at spaza shops.
The City of Johannesburg has 33 EHPs for Soweto — a community of more than 1.5 million people. Daily Maverick reporting revealed that Region D1 Soweto had just 16 inspectors for 19 wards. Naledi alone has more than 88 spaza shops.
Cape Town is better resourced — 209 EHPs for the metro, according to the City’s Environmental Health Service. But when Ramaphosa’s registration announcement landed in November 2024, the Cape Town Environmental Health Service received over 1,000 Certificate of Acceptability applications in a single week, as Eyewitness News reported. That is five applications per EHP per day on top of their existing workload — and the registration drive was just getting started.
Between July and September 2024, municipalities across South Africa received 82,924 spaza shop registration applications. Only 18% were approved. Not because the shops were non-compliant — because there were not enough EHPs to inspect them.
The Pipeline That Feeds Nothing
South Africa has at least eight universities producing Environmental Health graduates: the University of Johannesburg, Tshwane University of Technology, Cape Peninsula University of Technology, Durban University of Technology, Central University of Technology, Mangosuthu University of Technology, Sefako Makgatho Health Sciences University, and Walter Sisulu University.
These are four-year degree programmes. Graduates must complete a compulsory community service year — placement at a public facility — before the Health Professions Council of South Africa registers them as independent practitioners. Only then can they practise.
The bottleneck is not education. It is what happens after.
Bhekisisa’s investigation into community service placements revealed that by December 2023, 182 newly qualified health professionals — including environmental health practitioners — had no community service positions. Not because they failed their degrees. Because National Treasury budget cuts forced provinces to limit spending from their cost-of-employment budgets, which fund community service posts.
Without a community service placement, an EHP graduate cannot register with the HPCSA as an independent practitioner. Without HPCSA registration, they cannot practise. Without practice, their skills atrophy. The HPCSA does not require unemployed practitioners to pay annual registration fees — they can apply for voluntary erasure. But restoration later requires fees, CPD compliance, and potentially additional requirements depending on how long they have been off the register. As the Parliamentary Monitoring Group documented, the Health Professions Act provides for this — but the practical effect is that trained practitioners fall out of the system entirely.
Academic research has documented the pattern. A UCT study published in the South African Journal of Communication Disorders noted decreasing employment opportunities specifically for environmental health graduates, placing them within a broader crisis of unemployed health professionals in South Africa.
The result is a profession with a structured exit ramp for the unemployed and no structured re-entry pathway when demand surges — which is exactly what happened in late 2024.
What Children Paid For
The timeline is documented.
In September 2024, the Gauteng Department of Health reported 207 food poisoning cases affecting children since February, with 10 deaths. In October, six children died in Naledi after consuming snacks containing Terbufos. In the same month, 25 learners in Bronkhorstspruit, 21 in Mpumalanga’s Verena, and 43 at a KwaZulu-Natal primary school were hospitalised — all from vendor-purchased food.
Health Minister Motsoaledi confirmed the cause: organophosphate pesticides being sold informally and used as rat poison in spaza shops, contaminating food stored alongside chemicals. Food Safety News reported that 80 EHPs were deployed to inspect 84 spaza shops in Soweto — finding Aldicarb, another illegal pesticide, during the operation.
By mid-November, the death toll exceeded 22 children. Ramaphosa’s national address ordered a massive inspection campaign: inter-disciplinary teams of military health services, EHPs, police, the National Consumer Commission, and labour inspectors. All spaza shops given 21 days to register or face closure.
The DA’s response quantified the gap precisely: South Africa had only 1,712 EHPs against a required 6,203. The party called for urgent recruitment and deployment, particularly in high-density areas. The EFF joined the call, demanding intensified inspections and an emergency task force.
The deadline was extended to 28 February 2025. CoGTA Minister Hlabisa explained: registration alone does not mean a business is eligible to trade. To obtain a licence, EHPs and other regulatory authorities must inspect each premises. But who inspects when you have 33 EHPs for 1.5 million people?
By that point, 1,041 spaza shops had been closed for non-compliance. Not because enough inspectors had visited — because the ones who did found conditions severe enough to warrant immediate action.
The Cold Chain Connection Nobody Is Making
Environmental Health Practitioners are not peripheral to cold chain operations. They are the front line.
EHPs are the primary enforcers of Regulation 638 — the Regulations Governing General Hygiene Requirements for Food Premises, the Transport of Food and Related Matters. As a comprehensive review published in BMC Public Health documented, EHPs at the National Department of Health (port health) and at metropolitan and district municipalities are the primary stakeholders responsible for ensuring compliance with food safety laws in South Africa.
R638 is not a narrow regulation. It governs food premises — which includes cold storage facilities. It governs the transport of food — which includes every refrigerated vehicle on the road. It governs “related matters” — which encompasses temperature control, storage conditions, contamination prevention, and documentation.
Every cold chain operator who handles food is subject to R638. Every R638 inspection is conducted by an EHP. The entire regulatory compliance architecture for food-related cold chain operations sits on a workforce that is short by 4,450 people.
This is the connection missing from both the cold chain workforce conversation and the food safety crisis conversation. When ColdChainSA’s analysis of the cold chain workforce crisis documents a $20 billion industry growing into a skills vacuum, the EHP shortage is not a separate problem — it is the same problem viewed from the compliance side.
Consider what an EHP does in a cold chain context. They inspect food premises for temperature compliance. They verify that cold storage facilities maintain required conditions. They assess transport vehicles for food safety standards. They issue Certificates of Acceptability — the legal document confirming that a food-handling establishment meets hygiene and safety requirements. They investigate complaints. They enforce closures when standards are not met.
Without enough EHPs, the compliance system that underpins cold chain food safety does not function. Not “functions poorly” — does not function. A cold storage facility in a district with no available EHP has no pathway to a Certificate of Acceptability. A refrigerated transport operator cannot get a premises inspection for a new depot. A food manufacturer expanding into a new province may face months-long delays for basic compliance verification.
The 2018 listeriosis outbreak made this visible at national scale. Then-Health Minister Motsoaledi acknowledged there were flaws in the system, citing a lack of EHPs. Industry sources identified a shortage of at least 3,300 EHPs at that time. He called it a mistake in the constitutional assignment of food safety responsibility to local government, because municipalities could not afford it. Six years later, the shortage has worsened from 3,300 to 4,450, and children are dying from the same structural failure.
The Paradox Made Visible
This is where the story becomes difficult to look at directly.
South Africa has universities graduating Environmental Health Practitioners every year. These graduates complete four-year degrees. They seek community service placements — and some cannot find them because Treasury has cut the funding. Those who do complete community service register with the HPCSA and enter a job market where municipalities have unfunded vacancies. The national government appointed nine EHPs in a quarter where it placed over 2,000 health professionals. Provincial budgets are shrinking. Municipal budgets prioritise water, electricity, and roads over health inspection capacity.
So trained practitioners sit unemployed. Or they leave the profession. Or they take jobs in unrelated fields. Or they let their HPCSA registration lapse because they cannot justify the fees without income.
Meanwhile, the country has a documented deficit of 4,450 EHPs. Children are dying from contaminated food. The cold chain compliance system depends on inspectors who do not exist in sufficient numbers. And every time a crisis strikes — listeriosis in 2018, spaza shop poisonings in 2024 — the system scrambles to deploy practitioners it should have had all along.
Platforms like FOHESA — the Food, Health and Safety platform founded by environmental health professionals — have recognised this gap. FOHESA explicitly aims to integrate unemployed EHPs into health promotion and community development programmes, offering SETA-accredited training, R638 compliance support, and food safety education. Their model represents what the private sector increasingly needs: practitioners who can bridge the gap between regulatory requirements and operational reality.
But individual platforms cannot solve a structural funding failure. The demand exists — both in public health and in private industry. The supply exists — trained graduates with nowhere to go. What does not exist is the mechanism to connect them.
What the Private Sector Is Missing
The cold chain industry’s response to compliance challenges has largely been to hire internally — quality managers, food safety officers, compliance teams employed directly by operators. This works for large companies. It does not work for the thousands of small and medium operators who make up the bulk of South Africa’s food handling landscape.
The private sector cold chain model needs EHPs in ways that current employment structures do not accommodate. Independent food safety auditing for small operators. R638 gap analysis consulting. Temperature monitoring compliance verification. Certificate of Acceptability facilitation. Training for food handlers — the kind of front-line education that prevents contamination before it starts.
These are services that unemployed EHPs are qualified to provide. They are services that cold chain operators — particularly smaller ones — need but cannot resource internally. The matching mechanism does not exist at scale.
The spaza shop crisis made the public sector dimension visible. But the private sector dimension — cold chain operators who need compliance support, food manufacturers who need regular auditing, transport companies who need R638 verification — remains invisible in the workforce conversation.
As ColdChainSA’s skills crisis analysis documented, the cold chain workforce is invisible in national statistics because workers are counted under “transport,” “agriculture,” or “manufacturing” — never as their own category. EHPs with cold chain competency are invisible in the same way. They are counted as “health professionals” — but the subset who specialise in food safety, temperature compliance, and cold chain operations has no dedicated pipeline, no dedicated funding, and no dedicated placement mechanism.
The Question That Should Keep People Awake
South Africa’s unemployment rate sits at 31.4% as of Q4 2025. Youth unemployment is at 57%. The expanded unemployment rate — including those too discouraged to seek work — exceeds 42%.
Within that national crisis sits a smaller, more pointed one. Qualified health professionals who invested four years in a degree, completed community service, registered with a statutory body — and cannot find work in a country that is short 4,450 of exactly what they trained to do.
The funding sits in municipal budgets that are already overextended. The posts exist on paper but remain unfunded. The graduates exist but cannot be absorbed. The demand — from both public health crises and private sector compliance needs — is documented, quantified, and growing.
Nobody has connected these dots at the level where funding decisions are made.
The Garden Route District Municipality’s career guide for EHPs describes the scope of the profession: inspecting everything from spaza shops to hospitals, ensuring safe drinking water, managing hazardous waste. In the Kannaland region, EHPs continue to run compliance workshops for spaza shop owners — the kind of frontline work that prevents the next Naledi. But they are doing it within existing capacity, not expanded capacity.
The Professional Board for Environmental Health Practitioners, under the HPCSA, has warned about unqualified practitioners entering the market — a predictable consequence of demand outstripping supply. When qualified EHPs cannot find posts, the gap fills with people who lack the training, the registration, and the accountability that the regulatory system requires.
South Africa does not have a shortage of Environmental Health Practitioners. It has a shortage of funded posts for Environmental Health Practitioners. The distinction matters enormously — because the solution to the first problem is more training, and the solution to the second problem is more funding. The country has been treating this as a supply problem. It is a demand problem — or more precisely, a willingness-to-pay problem.
Children are the ones paying the difference.
Sources & References
About These Sources
This article draws on government records, parliamentary proceedings, investigative journalism, academic research, and industry analysis to document the Environmental Health Practitioner workforce paradox. All sources were verified as of February 2026 and represent publicly available information.
Citation Methodology
Direct data points — EHP employment figures, spaza shop registration statistics, child death tolls, and municipal staffing numbers — reference the specific sources listed below. Where analysis connects food safety enforcement to cold chain operations, the article draws on ColdChainSA’s published operational research and R638 regulatory requirements. Readers seeking verification of any cited statistic can access the source material through the links provided.
Currency Note
EHP employment figures, municipal staffing levels, and spaza shop registration statistics reflect data as reported through early 2026. Municipal budgets and staffing levels may have changed since the most recently cited reports. The spaza shop registration process remains ongoing, and compliance enforcement continues to evolve. Readers making operational or career decisions should verify current municipal staffing and regulatory requirements.
Government & Regulatory
- SAnews — “Health Addressing 2,000 Unfunded Vacant Posts of Medical Doctors” — April 2024. Breakdown of 2,066 health professional appointments: 1,121 medical officers, 579 nurses, 9 environmental health officers.
- SABC News — “Environmental Health Practitioner Shortage Strains Spaza Regulations” — November 2025. CoGTA Director Mohlatlego Rabothata: 1,751 EHPs nationally, deficit of 4,450. 82,924 spaza registration applications, 18% approved.
- CoGTA — “Extension of the Deadline for Registration of Spaza Shops” — December 2024. Registration deadline extended to 28 February 2025. 1,041 spaza shops closed for non-compliance.
- Parliamentary Monitoring Group — NW489 Question to Minister of Health — HPCSA legislation on unemployed practitioners; voluntary erasure and restoration provisions.
- City of Cape Town — “Environmental Health Food Safety FAQs” — 209 EHPs employed by the City of Cape Town. R638 enforcement scope and Certificate of Acceptability processes.
Political & Parliamentary
- DA — “DA Urges Government to Bolster Food Safety Standards and EHP Deployment” — November 2024. 1,712 EHPs against required 6,203. Call for recruitment in high-density areas.
- IOL — “DA and EFF Call for Increased Inspections” — November 2024. Cross-party calls for EHP deployment and inspection intensification.
News & Investigation
- Daily Maverick — “Lack of Health Inspectors in Soweto Jeopardises Safety of Our Children” — October 2024. City of Johannesburg: 33 EHPs for Soweto (1.5 million people). Region D1: 16 inspectors for 19 wards.
- Eyewitness News — “CoCT Environmental Health Service Receives at Least 1,000 COA Applications” — November 2024. Over 1,000 Certificate of Acceptability applications in one week.
- Mail & Guardian — “Spaza Shops Implicated in Deaths of Children to Be Closed Immediately” — November 2024. Ramaphosa national address: 890 food-borne illness incidents, 22+ child deaths.
- Food Safety News — “Chemical Linked to Fatal Poisoning in South Africa Revealed” — October 2024. Terbufos identified. 80 EHPs deployed to 84 Soweto spaza shops.
- Bhekisisa — “No Patient Left Behind?” — December 2023. 182 health professionals without community service placements due to Treasury budget cuts.
Academic & Research
- South African Journal of Communication Disorders (PMC) — “Increasing Unemployment Rate Amongst Health Professionals” — Decreasing employment opportunities for environmental health graduates.
- BMC Public Health — “Unlocking Food Safety” — July 2024. EHPs as primary stakeholders for food safety law compliance.
- Restaurant Association of South Africa — Food Safety Initiative — 2018 listeriosis context. EHP shortage of at least 3,300.
Regional Government
- Garden Route District Municipality — “Understanding the Role of EHPs” — June 2025. EHP scope of practice, qualification requirements.
- Garden Route District Municipality — “Kannaland Spaza Shop Owners Receive Refresher Training” — May 2025. R638 compliance training.
Industry & Professional Bodies
- HPCSA — Professional Board for Environmental Health Practitioners — Registration requirements, scope of practice.
- HPCSA Blog — “Warning Against Unqualified Environmental Health Practitioners” — Concern about unqualified practitioners entering the market.
Labour Market
- Trading Economics — South Africa Unemployment Rate — Q4 2025: 31.4% official rate. Youth unemployment (15-24): 57%.
ColdChainSA Analysis
- ColdChainSA — “Cold Chain Workforce Crisis: South Africa’s Invisible Skills Gap” — Seven converging demand shocks on cold chain workforce.
- ColdChainSA — “South Africa’s Cold Chain Skills Crisis” — Baseline artisan data, gender gap analysis, workforce data vacuum.
Related Resources
- Cold Chain Workforce Crisis: South Africa’s Invisible Skills Gap — The demand-side workforce analysis this article complements.
- South Africa’s Cold Chain Skills Crisis — Baseline artisan and skills gap analysis.
- Understanding Cold Chain Certifications — R638 and food safety certification context.
- Tertiary Certifications & Professional Qualifications — Career pathways including environmental health.
- Cold Chain Glossary — Technical terminology.
About ColdChainSA
ColdChainSA.com is South Africa’s specialised cold chain industry directory and resource platform, connecting operators with qualified service providers while building the information infrastructure the sector needs to develop professionally.
