Why Sudan Must Build a Ministry of Safety and Environment Now
Gold, Cooling, and Human Lives
A national policy dialogue with Professor Asim Fadl (Abu Sara) and a practical institutional model linking artisanal mining, refrigeration safety, and climate responsibility
By Eng. Abdelrahman Mohamed Zain (Magdi)
E-mail: mr.zainrac@gmail.com
Editor’s Note
This article reflects the author’s analysis based on a direct policy dialogue with Professor Asim Fadl (Abu Sara), previous field investigations published in The Citizen, and relevant international technical and institutional references.
Introduction: A Question Sudan Can No Longer Postpone
In a recent policy dialogue with Professor Asim Fadl Abu Sara, former Secretary-General of Sudan’s National Biosafety Council and one of the country’s most respected authorities in environmental and occupational safety, I asked a question that has now become unavoidable:
How can Sudan build an effective national environmental governance system—and can it draw practical lessons from Rwanda’s institutional success?
Professor Asim’s response was precise, disciplined, and deeply relevant to Sudan’s present reality:
“Building an effective environmental ministry in a developing country facing complex challenges like Sudan requires a transition from a traditional administrative model to a more comprehensive and integrated one. Rwanda’s experience—despite its own post-conflict challenges—shows that success lies in combining strong central leadership with decentralized implementation, supported by an independent regulatory body and innovative financing mechanisms. This model can form the foundation of an environmental ministry in Sudan.”
This was not simply an academic observation. It was a national blueprint.
In those few sentences, Professor Asim identified the essence of Sudan’s institutional dilemma: the country does not merely suffer from environmental problems; it suffers from fragmented environmental governance.
And nowhere is that fragmentation more dangerous than in two sectors that seem unrelated—but are, in fact, connected by the same regulatory failures:
Artisanal and small-scale gold mining, where unsafe shafts, toxic processing, and neglected occupational health are destroying lives; and
The refrigeration and cooling sector, where delayed policy decisions, weak standards enforcement, and the unresolved question of the Kigali Amendment are pushing Sudan toward technical isolation.
At first glance, gold mining and cooling systems belong to different worlds. In reality, both are governed by the same missing architecture:
Safety. Environmental accountability. Technical regulation. Data. Training. Enforcement. Coordination.
That is why Sudan now needs not another committee, nor another scattered mandate—but a serious institutional answer:
A Ministry of Safety and Environment.
Why Sudan Needs a Ministry of Safety and Environment
Professor Asim identified the core structural failures currently weakening environmental action in Sudan:
Weak coordination and overlapping mandates among ministries and agencies
Chronic shortages of funding and resources
Lack of reliable data and information systems
Technical and human capacity gaps within public institutions
Weak enforcement of environmental laws and safety regulations
These are not theoretical weaknesses. They are already costing Sudan dearly.
In earlier issues of The Citizen, I documented these failures in two separate but deeply connected investigations:
In Issue 89, in the article “Gold, Lungs, and Brotherhood: What Sudanese Miners Learned in Mauritania,” I documented the silent tragedy of Sudanese artisanal miners—young men descending into poorly ventilated shafts, inhaling toxic dust, working around mercury and cyanide, and returning not with prosperity but with damaged lungs, fibrosis, poisoning, and preventable death.
In Issue 84, in the article “Sudan at a Crossroads in Cooling: Kigali, Climate Justice, and the Future of Refrigeration Systems,” I examined Sudan’s continued delay in ratifying the Kigali Amendment to the Montreal Protocol—an unresolved policy gap that risks leaving the country outside major technical support, climate transition pathways, and refrigerant modernization frameworks supported under the Montreal Protocol system. The Kigali Amendment, adopted in 2016, establishes a global phase-down of HFCs, and developing-country parties can access technical and financial support through the Montreal Protocol framework once engaged in implementation.
UNEP – UN Environment Programme +1
The same institutional disease is visible in both sectors:
fragmented authority
weak inspection
poor field enforcement
no unified hazard governance
inadequate training
insufficient reporting systems
delayed policy decisions
Sudan does not lack experts.
Sudan lacks institutional integration.
Rwanda’s Lesson: Institutions Matter More Than Speeches
Professor Asim pointed to Rwanda not as a symbolic comparison, but as a practical African case study in institutional discipline.
Rwanda’s environmental governance model demonstrates that even a post-conflict state can build an effective framework if it combines:
clear legal mandates,
central strategic leadership,
decentralized implementation,
specialized executive authority, and
innovative financing.
The Rwanda Environment Management Authority operates under the ministry in charge of environment and holds a formal national mandate for environmental protection, conservation, supervision, and advisory functions on environment and climate change. REMA explicitly states that its mission is to supervise and monitor environmental management and ensure environmental issues are integrated into national development plans.
Rwanda Energy Management Authority +1
This is the essence of Professor Asim’s proposal for Sudan: not a symbolic ministry with ceremonial titles, but a functional architecture.
He proposed a Sudanese model built on six pillars:
A three-tier structure: central policy leadership, an executive technical authority, and state-level/local implementation
A strong coordination mechanism, including a National Council for Safety and Environment chaired at the highest executive level
Multi-source financing, including a dedicated national fund
Modern monitoring and evaluation systems, supported by digital tools and field reporting
A national capacity-building strategy, including training, certification, and talent recovery
A renewed legal and governance framework, backed by accountability and public oversight
This is not an administrative luxury. It is a life-saving reform.
From Gold Shafts to Policy Failure: Applying the Model to Artisanal Mining
Sudan’s artisanal mining sector is often discussed in terms of revenue, gold output, and local livelihoods.
But the more urgent truth is this:
Sudan’s artisanal mining crisis is, above all, a safety and environmental governance crisis.
A real Ministry of Safety and Environment should establish within its executive authority a set of specialized technical directorates, beginning with the following:
1) Directorate of Confined Space and Shaft Safety
This unit should make safe shaft entry mandatory—not optional.
That means:
written entry permits,
pre-entry and continuous atmospheric testing,
oxygen monitoring,
toxic gas detection,
mechanical ventilation where required,
rescue harnesses and lifelines,
standby attendants at surface level, and
emergency retrieval procedures.
In mining, as in industrial refrigeration machine rooms and other hazardous enclosures, lack of atmospheric control kills quickly and silently.
2) Directorate of Hazardous Chemicals and Toxic Substances
This unit should regulate and progressively reduce unsafe use of:
mercury,
cyanide, and
uncontrolled toxic reagents in ore processing.
Its mandate should include:
safe storage,
controlled transport,
separation of processing zones from communities,
containment of liquid waste,
safe disposal of solid residues, and
a strict ban on dumping into wadis, flood channels, and agricultural areas.
3) Directorate of Tailings, Waste Recovery, and Site Rehabilitation
This unit should address the legacy of toxic residues already accumulated in mining zones such as Barbar and Atbara.
Its work should include:
tailings stabilization,
residual gold recovery using safer methods,
pilot remediation projects,
environmental site rehabilitation, and
support for local low-cost innovations, including activated-carbon concepts derived from agricultural waste where technically validated.
4) Directorate of Occupational Health and Epidemiological Surveillance
This unit should do what Sudan has failed to do systematically:
register mining-related respiratory disease,
track toxic exposure cases,
identify occupational clusters,
support rural hospitals and field clinics,
train responders for shaft emergencies, and
expand access to oxygen support systems in remote mining zones where feasible.
5) Directorate of Community Relations and Miner Self-Regulation
Enforcement alone is not enough. Social legitimacy matters.
Lessons from Sudanese miners in Mauritania show the value of:
miner associations and cooperatives,
codes of conduct,
community trust-building,
investment in schools and clinics, and
structured reintegration for returning miners.
A modern state does not merely punish informal sectors.
It organizes them into safer systems.
Cooling Is Not a Luxury: Applying the Model to Refrigeration and the Kigali Amendment
Sudan’s refrigeration and cooling sector is too often treated as secondary policy space.
That is a mistake.
Cooling is not a luxury sector. It is a public health sector, a food security sector, a medicines sector, a trade sector, and a climate sector.
Cold chain failures affect:
vaccines,
medicines,
perishable foods,
industrial processing,
commercial reliability, and
public confidence in infrastructure.
At the same time, Sudan remains exposed to a serious policy delay: the unresolved national position on the Kigali Amendment.
The Kigali Amendment to the Montreal Protocol was adopted in 2016 to phase down climate-warming HFCs globally, and UNEP’s official materials emphasize that Article 5 (developing) countries are eligible for technical and financial support under the Montreal Protocol framework as they implement transition obligations.
UNEP – UN Environment Programme +1
That means Sudan’s hesitation is not neutral.
It carries a cost.
A serious Ministry of Safety and Environment should therefore establish the following units:
1) Directorate of Low-Climate-Impact Refrigerant Transition
This unit should immediately prepare a structured national position on Kigali by:
submitting a formal Cabinet policy note,
assessing the technical and economic implications of ratification,
coordinating with foreign affairs, industry, customs, standards bodies, and donors, and
preparing a phased HFC transition roadmap.
The choice is straightforward:
Ratify with preparation, or
Drift into technical irrelevance.
2) Directorate of Refrigeration Safety and Code Compliance
This unit should align Sudanese practice with internationally recognized safety frameworks.
ASHRAE’s official materials state that Standard 15 is the Safety Standard for Refrigeration Systems and specifies safe design, construction, installation, and operation of refrigeration systems, while Standard 34 establishes refrigerant designations and safety classifications based on toxicity and flammability data.
ASHRAE +2
That means Sudan should formally modernize its technical guidance around:
ANSI/ASHRAE Standard 15
ANSI/ASHRAE Standard 34
ISO 5149
The ISO 5149 family remains a core international reference for refrigeration safety and environmental requirements:
ISO 5149-1:2014 covers definitions, classification, and selection criteria;
ISO 5149-2:2014 covers design, construction, testing, marking, and documentation;
ISO 5149-3:2014 covers installation site requirements;
ISO 5149-4:2022 covers operation, maintenance, repair, and refrigerant recovery.
iso.org +3
This directorate should specifically address:
equipment room ventilation,
refrigerant leak detection,
emergency shutdown logic,
fire protection compatibility,
safe handling of A2L refrigerants, and
commissioning and servicing rules.
For Sudan, this is especially important as the sector moves toward newer low-GWP refrigerants with different flammability profiles.
3) Directorate of Training, Certification, and Technician Licensing
No refrigerant transition can succeed without technician transition.
As a refrigeration professional, I say this clearly:
If the technician is not trained, the policy will fail in the field.
This unit should:
modernize vocational curricula,
integrate flammable refrigerant safety,
establish mandatory competency certification,
train trainers,
build field-based assessment systems, and
target at least 500 technicians in the first year.
For a country like Sudan—where practical skill often outruns formal systems—this may be the single most important reform.
4) Directorate of Refrigerant Data, Monitoring, and Reporting
Without data, there is no transition.
This unit should build a national system for:
import and customs tracking,
refrigerant inventory mapping,
emissions estimation,
leak-loss analysis,
recovery and reclaim reporting, and
compliance support under the Montreal Protocol framework.
Sudan cannot govern what it does not measure.
Why a Unified Ministry Makes Strategic Sense
This is where Professor Asim’s model becomes truly powerful.
The genius of an integrated Ministry of Safety and Environment is that it creates shared capacity across sectors that appear different but are technically connected.
Consider the overlap:
Mercury, cyanide, and refrigerants are all hazardous substances requiring strong chemical governance
Mining shafts and refrigeration machinery rooms both involve confined or hazardous spaces
Gas detection, leak response, emergency ventilation, and rescue planning are relevant in both
Field inspectors can be cross-trained across occupational safety, environmental sampling, and incident response
A national fund can support both public health protection and climate-aligned technical transition
Public awareness systems can address both toxic dust and refrigerant hazards under one national safety culture
This is what Sudan lacks today.
Instead, the country remains trapped in fragmentation:
mining under one silo,
environment under another,
occupational health under another,
refrigeration under scattered industrial and standards channels,
and climate obligations delayed by institutional diffusion.
The consequences are no longer abstract.
They are visible:
young miners losing lungs and lives,
contaminated landscapes expanding,
unsafe refrigerant handling persisting,
modernization delayed,
international opportunities missed.
The First 100 Days: What a Real Ministry Should Do Immediately
If Sudan were to establish such a ministry, its first 100 days should not be symbolic.
They should be practical, visible, and life-saving.
1) Publish a National Safety Guide for Artisanal Mining
Including:
shaft-entry protocols,
gas testing requirements,
minimum rescue equipment,
ventilation rules, and
toxic residue handling.
2) Resolve Sudan’s Position on the Kigali Amendment
Prepare a formal Cabinet memorandum and complete a clear six-month decision path.
3) Establish an Occupational Health Emergency Fund
To support respiratory response, field rescue readiness, and oxygen support capacity in remote mining zones.
4) Launch a Pilot Tailings Recovery and Remediation Project in Barbar
Using locally adaptable methods, with health and environmental impact assessment built in.
5) Start a National Safety Awareness Campaign
Through:
radio,
mosques,
mining markets,
technical institutes,
refrigeration workshops, and
community leadership structures.
Topics should include:
toxic dust,
mercury and cyanide risks,
oxygen deficiency hazards,
refrigerant leak risks,
ventilation basics, and
safe service practice.
6) Update Sudanese Refrigeration Technical Guidance
In coordination with the national standards authority, aligned with:
ASHRAE 15,
ASHRAE 34, and
ISO 5149.
This is not optional if Sudan wants safe modernization.
Conclusion: From Fragmentation to a National Safety State
Professor Asim Fadl Abu Sara summarized the vision in one statement that deserves to be repeated at the highest levels of government:
“This model, inspired by Rwanda and adapted to Sudan’s realities, is ambitious—but entirely achievable.”
He is right.
Creating a Ministry of Safety and Environment is not an administrative luxury.
It is not a donor slogan.
It is not a bureaucratic exercise.
It is a national necessity.
Today’s fragmented structure—where the Higher Council for Environment, the Ministry of Minerals, the Ministry of Health, the Ministry of Industry, and other institutions act in partial isolation—has already cost Sudan too much:
In the mines, it has cost lives, lungs, and futures.
In the cooling sector, it has cost time, credibility, and modernization.
In climate policy, it has delayed opportunity.
In public trust, it has deepened fatigue.
Rwanda’s example proves that post-conflict states can build disciplined environmental institutions when political will is matched by institutional design. REMA’s formal mandate under the ministry in charge of environment shows how a specialized authority can be embedded in a national system rather than left as a weak advisory body.
Rwanda Energy Management Authority
Sudan, despite the wounds of war, still possesses exceptional human capital:
Professor Asim Fadl Abu Sara
Professor Yasser Hanafi
Eng. Ibrahim Mohammed Ali
and many others whose knowledge should no longer remain scattered across disconnected systems.
Gold may come from the earth.
Cooling may preserve food and medicine.
But lungs belong to people—and climate belongs to all of us.
Sudan now faces a choice:
continue paying the price in lives, pollution, and technical delay,
or
build the integrated model its own experts have already outlined.
A state that cannot protect workers, regulate hazards, and prepare for technical transition cannot call its development sustainable.
The time for institutional courage is now.
About the Author
Eng. Abdelrahman Mohamed Zain (Magdi)
Industrial Refrigeration and Absorption Cooling Expert
Member, ASHRAE (USA)
Member, Society of Environmental Engineers (UK)