GMP is the foundation of every food safety system in Kenya. HACCP sits on top of it. ISO 22000 requires it. KEBS inspectors check for it. Yet most small food businesses in Kenya treat it as an afterthought — until an audit fails or a consignment is rejected. This guide gives you the complete, practical picture.
Good Manufacturing Practice — GMP — is the set of minimum standards that every food business must meet to produce food safely and consistently. It covers your premises, equipment, people, processes, and documentation. GMP does not tell you how to make your specific product. It tells you the conditions under which any food product must be made.
Think of GMP as the hygiene and housekeeping rules of food manufacturing. Before you can analyse hazards (HACCP) or build a management system (ISO 22000), you need a clean, controlled, well-run environment to work in. That environment is what GMP creates.
The Codex Alimentarius definition
"Those practices required to conform with the guidelines recommended by agencies that control the authorisation and licensing of the manufacture and sale of food and beverages... GMP covers all aspects of production, from the raw materials, premises and equipment to the training and personal hygiene of staff." — Codex Alimentarius Commission
In Kenya, GMP requirements are set by the Kenya Bureau of Standards (KEBS) under the Kenya Standard KS 05-795 — Code of Hygienic Practice for Food. This standard aligns closely with the Codex Alimentarius General Principles of Food Hygiene (CXC 1-1969, revised 2020). If your business is KEBS-licensed or seeking certification, KS 05-795 is your primary GMP reference document.
The instinct of many small food businesses in Kenya is to treat GMP as a large factory concern — something for Brookside, Bidco, or Kevian, not for a 10-person processor in Eldoret or a community dairy in Nakuru. This instinct is wrong and costly.
KEBS does not apply GMP requirements on a sliding scale. A small food business that fails a GMP inspection faces the same consequences as a large one — product recall, licence suspension, market exclusion. And because small businesses have fewer resources to absorb a recall or business interruption, the impact is proportionally more damaging.
KEBS Licensing
GMP compliance is a prerequisite for the KEBS Standardisation Mark (S-Mark). Without the S-Mark, you cannot legally sell food in Kenya's formal retail market.
Export Markets
EU, UK, and US buyers conduct supplier audits before listing Kenyan products. The first section of every audit checklist is GMP. A weak GMP score means no listing — regardless of product quality.
HACCP & ISO 22000
Both HACCP and ISO 22000 assume GMP is already in place. Without GMP, your HACCP plan will fail validation. An ISO 22000 audit will flag non-compliant prerequisite programmes immediately.
Consumer Trust
A single food safety incident — contaminated product, foreign body complaint, mould outbreak — can end a small food business in Kenya permanently. GMP prevents those incidents.
GMP is structured around eight core areas. Every KEBS inspection, every food safety audit, and every buyer verification covers all eight. Here is what each one means in practice for a small Kenyan food business.
Your production facility must be designed, constructed, and maintained to prevent food contamination. This includes the location of the facility (away from sources of contamination), the construction of walls, floors, and ceilings (smooth, impervious, easy to clean), adequate lighting and ventilation, and proper drainage.
Kenya context
Many small Kenyan processors operate from repurposed domestic or agricultural buildings. The most common KEBS finding is cracked or unpainted walls and inadequate drainage — both create hygiene risks and are relatively inexpensive to fix before an inspection.
All equipment in contact with food must be made of food-grade materials, be easy to clean and sanitise, and be maintained in good repair. Equipment must be designed to prevent accumulation of dirt, bacteria, and foreign materials. Calibration records must be kept for measuring equipment such as thermometers and weighing scales.
Kenya context
Wooden utensils, rusted equipment, and uncalibrated thermometers are the three most cited equipment findings in Kenyan food processing facilities. Food-grade stainless steel equipment is the standard — replacement costs less than one product recall.
Every person who handles food must practice adequate personal hygiene. This covers handwashing procedures, the use of protective clothing (head covers, gloves, aprons), exclusion of sick workers from food handling areas, and prohibition of personal habits that could contaminate food (eating, smoking, spitting in production areas).
Kenya context
Personnel hygiene is the area where training makes the biggest difference. A well-written procedure for handwashing is worthless if staff do not follow it. Regular, documented training — with sign-off sheets — is what auditors look for. DESMA Consult includes a staff hygiene training session in every GMP implementation engagement.
You must have written cleaning and sanitation procedures — what gets cleaned, how, how often, with which chemicals, and by whom. Records must be kept. The effectiveness of your cleaning programme must be verified, typically through environmental swabbing or visual inspection.
Kenya context
Many Kenyan food businesses clean thoroughly but have no written records. During a KEBS inspection or buyer audit, "we clean every day" is not sufficient — you must show cleaning schedules, verification records, and chemical concentration logs. This documentation takes one afternoon to set up and can save your licence.
A pest management programme must be in place and documented. This includes physical measures (screens, door seals, gap filling), monitoring (bait stations, glue boards, inspection records), and where necessary, chemical control by a licensed pest control operator. All pesticide use must be recorded and chemicals stored away from food areas.
Kenya context
Rodent and insect activity is a critical non-conformance in Kenya — it triggers immediate action from KEBS. A contracted pest control company with a current service contract and visit reports is the minimum standard. Store product at least 15cm off the floor and 30cm from walls to prevent harbourage.
Incoming raw materials must be inspected and tested before use. You must have supplier approval procedures, incoming goods inspection records, and a system for rejecting non-conforming materials. Storage of raw materials must prevent contamination and deterioration — correct temperature, humidity, and separation from finished goods.
Kenya context
Aflatoxin contamination in maize, groundnuts, and dried fruit is Kenya's most significant food safety risk. A raw material control programme that includes aflatoxin testing on incoming maize is not optional — it is a life-safety requirement and a KEBS expectation. The Kenya Plant Health Inspectorate Service (KEPHIS) sets maximum limits under the Pest Control Products Act.
Critical production parameters — temperatures, times, pH, water activity — must be defined, monitored, and recorded for every batch. Traceability records must link every finished product batch to the raw materials used, the production date, the equipment used, and the staff involved. Product labelling must be accurate and comply with the Kenya Food, Drugs and Chemical Substances Act.
Kenya context
Batch traceability is the foundation of a product recall system. If KEBS or the Pharmacy and Poisons Board issues a recall notice, you must be able to trace every affected batch within 24 hours. A simple paper-based batch record system — date, batch number, raw material lot numbers, quantity produced — takes one week to set up and could save your business.
All food handlers must receive food safety and hygiene training appropriate to their role. Training must be documented — who was trained, what they were trained in, when, and by whom. Refresher training must be conducted annually. Management must also be trained in food safety principles, not just production staff.
Kenya context
DESMA Learn offers the HACCP Fundamentals course for food handlers in Kenya — practical, affordable, and aligned to KEBS and Codex standards. Completing this course and retaining certificates is evidence of training compliance for any audit. View the course here.
In Kenya, GMP requirements for food manufacturers are governed primarily by:
KEBS conducts both routine and risk-based inspections. A business applying for the S-Mark will receive a pre-certification audit covering all eight GMP areas against KS 05-795. The audit produces a non-conformance report, and the business must close all major non-conformances before certification is granted.
Based on DESMA Consult's experience with Kenyan food manufacturers, these are the ten non-conformances most frequently identified during GMP audits and KEBS inspections:
No written cleaning schedules or records
Cleaning happens but is not documented. Auditors cannot verify frequency or effectiveness.
Uncalibrated thermometers and weighing scales
Critical measuring equipment with no calibration records and no traceable calibration standard.
No batch traceability system
Products cannot be traced from finished goods back to raw material lots. Recall capability absent.
Inadequate handwashing facilities
No running water, no soap, or no handwashing station at the entry to production areas.
No pest control contract or records
Pest control is reactive rather than preventive. No licensed contractor, no service reports.
Non-food-grade storage containers
Industrial plastic containers, non-food-grade bags, or recycled containers used for food storage or processing.
No documented training records
Staff have been trained verbally but no attendance sheets, training content, or assessments exist.
Raw and finished goods stored together
Cross-contamination risk from inadequate segregation of raw materials, work-in-progress, and finished products.
No supplier approval or incoming goods inspection
Raw materials accepted without inspection. No supplier assessment or incoming test records.
Cracked walls, inadequate drainage, poor lighting
Structural non-conformances that harbour bacteria and create cleaning impossibilities.
GMP implementation does not have to be overwhelming. Follow this sequence and you will have a compliant, documented GMP system in place within six to eight weeks — regardless of the size of your operation.
Walk through your facility with the KS 05-795 checklist and assess your current status against each GMP requirement. Score each item: Compliant / Partially Compliant / Non-Compliant. This gives you a prioritised list of what needs to be fixed and in what order.
Repair cracked walls, install handwashing stations, replace wooden utensils, improve drainage and lighting. These physical fixes are prerequisites — documentation written against a non-compliant facility is not sufficient to pass an audit.
Develop written procedures for each of the eight GMP areas — cleaning and sanitation schedules, pest control programme, personal hygiene policy, raw material inspection procedure, batch record system. Keep procedures simple and practical. One page per procedure is usually sufficient for a small operation.
Conduct a structured training session with all food handlers covering personal hygiene, cleaning procedures, and the new GMP system. Document attendance and completion. Enrol relevant staff in the DESMA Learn HACCP Fundamentals course for formal certification evidence.
Run your new GMP system for at least three weeks before any external audit. This generates the records that demonstrate your system is working — cleaning logs, pest control visit reports, batch records, training sign-off sheets, incoming goods inspection records.
Conduct an internal audit using the KS 05-795 checklist before inviting KEBS or an external auditor. Identify any remaining gaps and close them. A DESMA Consult pre-audit readiness review at this stage will identify any remaining issues before they become formal non-conformances on your KEBS record.
GMP and HACCP are not the same thing and are not interchangeable. Understanding the relationship between them is essential before you attempt to implement either system.
GMP (Prerequisite Programme)
HACCP (Hazard Control System)
The Codex Alimentarius Commission defines GMP as a prerequisite programme — a condition that must be in place before HACCP can function effectively. If your facility has poor hygiene, inadequate pest control, and no training records, your HACCP plan cannot control the hazards it is supposed to address because the baseline conditions are not met.
Think of it this way: GMP makes your factory a place where safe food can be made. HACCP makes sure the specific hazards in your specific process are identified and controlled. You need both — in that order.
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DESMA Consult works with Kenyan food businesses at every stage of GMP implementation — from initial gap analysis to pre-KEBS audit readiness. Our engagements are practical, Kenya-specific, and designed for businesses that do not have a full-time food safety team.
GMP Gap Analysis
A structured assessment of your facility against KS 05-795 and Codex CXC 1-1969. You receive a prioritised non-conformance report and a practical remediation plan.
GMP Documentation
We write your cleaning schedules, pest control programme, hygiene policy, batch record system, and supplier approval procedures — in Swahili or English, formatted for your team.
Pre-KEBS Audit Review
A mock KEBS audit conducted by DESMA's technical team before your official inspection. All findings are closed before KEBS arrives.
DESMA Consult works with small and medium food businesses across Kenya. Whether you are preparing for a KEBS inspection, responding to a buyer audit request, or building your food safety system from scratch — we can help.