Aflasafe™ pea amendment for usaid/East Africa February 2015



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Since independence, the environment in Burundi has been characterized by destruction, land cover, and use change due to agriculture extension and the massive exploitation of forests and wildlife. The high population growth continues to lead to high pressure on natural resources. In a country where the economy is based on agriculture, any degradation of these resources has serious impacts on the nutrition of the population.”


Source: Ezilon.com

Table 2: Eco-climatic Regions of Burundi78



Eco-climatic Region

Percent of Burundi

Elevation (meters)

Average Annual Temperature

Average Annual Rainfall (millimeters)

Imbo plains

7

800-1100

23

800-1100

Mumirwa slopes

10

1000-1700

18-28

1100-1900

Congo-Nile Divide

15

1700-2500

14-15

1300-2000

Central Highlands

52

1350-2000

17-20

1200-1500

Kumoso and Bugesera

16

1100-1400

20-23

1100-1550

This is further evidenced in that only five percent natural forest cover remains in Burundi, with those forests found within the Albertine Rift, the most biologically diverse region in Africa. The forests are present in four of Burundi’s five eco-climatic regions, specifically the Imbo Plains, Congo-Nile Divide, Central Highlands, and Kumoso and Bugesera regions.

Climate Change. Environmental strain has been further exacerbated by climatic inconsistency and change. Over the past 60 years, Burundi has been subject to cycles of excess or deficient rainfall, on a decade-to-decade basis. Over this same period, the country has also seen average temperatures rise and the dry season extend. Four significant weather events in the past 15 years (two severe floods and two severe droughts) affected the northeastern provinces as well as the Bugesara Depression, and each event resulted in an approximate 5-17 percent loss in annual GDP.79

The Institut Geographique du Burundi has found that over approximately the past 10 years, the lakes in northern Burundi have receded 1–2 meters.

While a changing climate likely plays a role in this depletion, other factors such as drainage or the cultivation of marshlands impacting water systems, may also contribute. Should droughts increase or persist, Burundi may be faced with water shortages, hampering agriculture and livestock management. Drought was the cause of a major food crisis and significant livestock loss (35 percent) between 1998 and 2005.80

Burundi’s topography also leaves the country prone to significant erosion, or landslides, in the event of increased rainfall (in volume and frequency). Such events could likewise damage crops, roads, buildings, and introduce heavy siltation into water bodies, reducing biodiversity and hydropower capacity. Heavy rains could also cause flooding among marshlands and lakes, affective vulnerable populations settled in close proximity to their edges.



Protected Areas. As part of a still ongoing effort to better protect the environment, Burundi established the National Institute for the Conservation of Nature (INECN) and, in turn, designated fourteen protected areas. Protected areas in Burundi fall into one of four categories: National Parks, Nature Reserves, Natural Monuments, and Protected Landscapes. These protected areas represent a diverse array of ecosystems, including Guinean and Afromontane forest types, Miombo woodlands, unique palms, savannah and grasslands, and large wetlands. Once representative of the predominant landscapes in Burundi, the protected areas are now fundamentally the remnants of the larger forest and savannah areas found in the country. In total, the protected areas comprise approximately 5.6 percent of the country, and include five protected bird areas and one wetland designated as a Ramsar site.81

Institutional Framework


Ministry of Agriculture and Livestock (MINAGRI)—MINAGRI’s mission is detailed in the Presidential Decree No. 100/38 of January 3, 2006 and entails the following:

  • Planning and design, coordination, and implementation of national policy on agriculture and livestock;

  • Organization and monitoring of agro-food processing;

  • Establishment of sustainable food security systems;

  • Development and implementation of national policies to protect and improve soil fertility, mobilize self-development and popularization of agroforestry-zootechnics, and strategies to improve protection of crops;

  • Oversee implementation of the National Policy, “the promotion and supervision of the exploitation of water, of fishing and fish farming products”, in collaboration with other concerned ministries.

This ministry has four General Directorates: General Directorate of Agricultural and Livestock Planning, General Directorate of Mobilization for Self-Development and Agricultural Extension

(DGMAVA), General Directorate of Agriculture, and General Directorate of Livestock (DGE).



The Institut des Sciences Agronomiques du Burundi (ISABU)82ISABU serves as Burundi’s principle agronomic research institute. ISABU accounts for more than half of the country’s agricultural research capacity and almost 75 percent of agricultural research and development investments. The institute was created in 1962 and is placed under MINAGRIE, with a program is built around four primary areas of focus: crops, livestock, farming systems, and rural socioeconomics. More specifically, ISABU focuses research efforts on production of high-quality seeds, improved forestry/agro-forestry practices, erosion control, livestock improvement, among others. ISABU also conducts soil analyses and plant-health evaluations in collaboration with MINAGRIE.

In support of research on aflatoxins, the plant pathology laboratory has been used for crop and fungus characterization, and three primary researchers have been identified and trained in relevant research techniques, much of the support fostered through an evolving relationship with IITA. To date, IITA has sponsored the training of Ph.D. scientists, providing clean planting materials for cassava, and explored the possibility of building an office in Burundi

ISABU supports in the surveillance of pesticide use and any resultant adverse impacts. In their support, a member from ISABU joins Office of Plant Protection field teams for field evaluations.

The Office of Plant Protection within MINAGRIE works to prevent pest infestation and disease in plants, with focus on viruses, fungi and bacteria. The office utilizes surveying protocols to evaluate diseases or pests under review, looking at pest populations and disease spread. Additionally, with support from ISABU, the office provides surveillance of pesticide use and any resultant adverse impact. Surveillance entails monitoring behavior of plants following pesticide application and evaluating whether there is any evidence of pest persistence or invasiveness. Such surveillance efforts are typically conducted 3-4 times per year (or once per season), though no specific protocol is established for these evaluations.

Ministry of Environment (MEEATU)—The Ministry of Water, Environment, Land Management and Urban Planning underwent reorganization in November 2005. Prior to the reorganization, the ministry was known as MINATET (Ministère de l’Aménagement du Territoire, de l’Environnement et du Tourisme). Despite the reorganization, the fundamental responsibilities of the ministry remained fairly consistent. These primary responsibilities are:


  • Development and implementation of national water, environmental, land management, and urban planning policy;

  • Promotion of coordinated environmental management;

  • Oversight of environmentally sound management of land, water, forests, and air;

  • Preservation of Burundi’s ecological balance; and

  • Biodiversity conservation.

The ministry is comprised of three General Directorates: the General Directorate of Forests and Environment, the General Directorate of Land Management, Rural Engineering and Land Property Protection, and the General Directorate of Urban Planning and Buildings.

National Institute for Nature Conservation (INECN)—MEEATU contains the INECN, which was established in 1980 as response to the 1972 Stockholm Environment Conference.

In its capacity to safeguard the environment and conservation of Burundi’s natural resources INECN:83



  • Collects and analyzes data provided by national and international organizations informing the status of Burundi’s environment and natural resources;

  • Enforces standards meant to combat pollution;

  • Supports environmentally sound management of natural resources through coordination and cooperation with relevant authorities;

  • Oversees the creation and management of national parks, nature reserves, and protected areas; and

  • Initiates and supports research studies and accompanying measures to support maintenance of Burundi’s environment.

Bureau of Standards and Quality Control (BBN)84—Burundi’s Bureau of Standards and Quality Control oversees implementation of national standards in quality assurance through development, adoption, and adaptation of existing national or regional (e.g. EAC) standards. BBN also provide services in certification, inspection, conformity assessment, measurement, and testing.

BBN is currently looking to expand measurement and analysis capacity, with limited laboratory resources at present. As stated on BBN’s Web site, “{current existing} infrastructures are insufficient to enable {BBN} to effectively meet the growing expectations of {its} stakeholders and partners. BBN has a work plan from 2011 to 2015 to guide the development of its organizational structure to meet the needs of different socio-economic sectors of the country in terms of quality.”



National Center of Food Technology (CNTA)—CNTA is Burundi’s research center for food technology. The center is comprised of four primary divisions: finance and administration, food technology service, food engineering, and studies and promotions.

The food technology service carries out research works related to food technology matters. The center is equipped with laboratories capable of microbiological and chemical analyses, including capacity for HPLC85 and gas chromatography/mass spectrometry (GC/MS) for analysis of pesticides. The laboratories are available for public use, though cost for services will depend on the analyses requested.



Ministry of Public Health (MPH) —MPH oversees efforts within Burundi to monitor and improve the population’s health, with a particular emphasis on HIV/AIDs awareness and prevention efforts. Within MPH, the Directorate of the Promotion of Health, Hygiene, and Sanitation promotes sound hygiene and sanitation practices, supports establishment water quality monitoring systems, and mobilizes community behavior adaptation/change efforts, as well as contributes, generally, to related efforts.

Pesticide/Pest Product Registration Process


The MINAGRIE’s Office of Plant Protection oversees the pesticide registration process vis-à-vis the Pesticide Control and Registration Service. The technical reviewing committee, called the National Committee for the Control and Regulation of Pesticides (Committee), is comprised of the Secretary of the Office of Plant Protection, the General Director of ISABU, an advisor to the Ministry of Environment, a representative from the University of Agriculture, and an advisor from the Ministry of Health.

The registration process entails the following steps:



  1. Registrant provides a completed dossier to the president of the Committee, (the Director General of the Ministry of Agriculture)

  2. The dossier is then sent to the Office of Plant Protection for review of documentation and quality verification. Product quality is compared against international standards.

  3. The Office of Plant Protection prepares a working document detailing their evaluation for consideration by the Committee.

  4. The product is field tested across multiple locations

    1. The field-testing process typically takes 2-3 years.

    2. The results of the field testing is included in the working document.

  5. The Committee discusses the findings in the working document and makes recommendation regarding product registration (typically a 2-3 day process).

If the product is approved, the process is as follows:

  1. Provisional registration, which lasts for two years;

  2. The Committee continues to monitor the product for on-field impacts; if impacts on health or environment are observed, the Committee may reject the product.

  3. If no issues are observed, the Committee may provide full approval at the end of the two-year provisional approval period. This grants a ten-year accreditation for the product.

Legal Framework and Relevant Laws


Currently, there is no legislation in place for bio-controls or bio-pesticides, though a law is currently being discussed in parliament. Burundi does have existing maximum accepted tolerable limits of aflatoxins for selected crops and products. The maximum acceptable tolerable limits are as follows:

  • Maize: 5 ppb

  • Peanuts: 10 ppb

  • Oilseed: 10 ppb

  • Wheat flour: 10 ppb and 5 ppb for aflatoxin B1

  • Sorghum: 5 ppb

  • Millet: 10 ppb and 5 ppb for aflatoxin B1.

Additionally, a recent study on the inventory of national environmental norms and standards determined that, for the most part, those standards required by certain laws in Burundi are not actually followed in practice. Burundi, for the most part, utilizes a list of norms and standards used by COMESA as the basis for internal standards). Burundi has a law that allows for the adoption of COMESA’s standards as official national standards by the BBN.86

The agricultural sector policy for Burundi is described within the national agricultural strategy (adopted in 2008). The inception of the Comprehensive Africa Agriculture Development Programme (CAADP) in 2003, coupled with support from COMESA, helped the nation agricultural strategy function more effectively as a resource for informing investments and support planning for future actions and use of resources. The CAADP encouraged development of a National Agricultural Investment Plan (NAIP). The NAIP, which covers 2012-2017, was produced through collaboration between and support by COMESA, technical and financial partners, national experts, and international consultants, among other key stakeholders. It was approved by the government in July 2011.87

The relevant conventions for EIA/SEA which Burundi has signed/ratified include:88


  • Convention on Biological Diversity,

  • Convention on the Fight against Desertification,

  • Convention on Climate Change,

  • International Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES),

  • Convention on the Conservation of Wetlands of International interest (RAMSAR)

  • African Convention on the Conservation of Nature and Natural reserves

  • Convention on the Protection of plants among the Member Countries of the Economic Community of the Great Lakes

  • Convention on the Sustainable Management of Lake Tanganyika.

  • Stockholm Convention on Persistent Organic Pollutants (POPs)

  • Rotterdam Convention on Prior Informed Consent (PICs)


Gap Analysis

Bio-control Research and Development


To date, bio-control research and development efforts within Burundi have reached only the preliminary stages of sample collection for the analysis of aflatoxins.89 The first batch of samples has been collected and sent to Kenya for laboratory analysis, which underscores either the lack of capacity to perform such analysis within Burundi, or a lack of awareness of such existing capacity.90 With results of the analysis still pending, sufficient information to map levels of aflatoxins throughout Burundi is not currently available.

Awareness Raising and Demand Creation


While efforts to increase and raise awareness in Burundi have begun and made measurable inroads with selected policy-makers, overall familiarity with aflatoxins remains low throughout the country, even among many government officials. The current efforts underway to raise awareness of aflatoxins within Burundi are being conducted in coordination with IITA.

Similarly, country officials are only at the preliminary stages of understanding the public health impact aflatoxins have had in Burundi. While a representative from the Ministry of Public Health (MoPH) presented the issue of aflatoxins within Burundi, when first introduced,91 consultations with stakeholders suggest that any epidemiological review of aflatoxin-related illnesses in Burundi is, at best, in preliminary stages.

Looking forward, the planned approach to the evaluation of aflatoxins and sensitization efforts within Burundi will consist of the three phase approach outlined below:


  1. Evaluation of the distribution of aflatoxins across several geographic regions within Burundi

  2. Evaluation of diseases currently occurring or observed that are linked to aflatoxins

  3. Establishment of aflatoxin-control measures

MINAGRIE officials indicate that, at the small-holder farmer level, there is an understanding of external factors adversely affecting yields, but not an explicit awareness of aflatoxins. From the perspective of these officials, the current priority in the effort to control aflatoxins should be improving drying and storage techniques to reduce moisture levels and, in turn, make crop production less favorable to A. flavus.

However, they also indicate a persistent belief that aflatoxins are predominantly originating via importation of products. Conclusion of current efforts to analyze aflatoxins will help clarify from where impacts associated with aflatoxins in Burundi are primarily being sourced.


Registration of aflasafe


Historically, bio-control has been successfully introduced in Burundi, utilized to control pests harming cassava production. However, stakeholders’ lack of familiarity with the proposed technology means there are several unresolved or misunderstood concerns about the manufacture and use of aflasafe. Voiced concerns include: risk of introducing a parasitic fungus, the potential for use of resistant maize varieties instead of bio-control, and the impacts of geographic conditions on fungal development. Conversation with BBN and MINAGRIE officials indicate that BBN has been part of discussions with EAC to develop regional registration procedures specific to bio-pesticides and that upon development BBN is likely to adopt the procedures as its own. Additionally, all relevant ministries have already signed sanitary and phyto-sanitiary protocol, which covers aflatoxins and will, in turn, govern any future policy specific to aflatoxins. Ultimately, though, even with the adoption of these procedures, members of the National Committee for the Control and Regulation of Pesticides must be satisfied that any concerns they may have regarding use of aflasafe, including but not limited to those highlighted above, are not so salient as to undermine the benefits the product could provide.

Establishment of Manufacturing


Given the preliminary state of aflatoxin-related efforts in Burundi, the reality is that manufacture and use of aflasafe products is not feasible in the near-term. Conversation with IITA’s country representative revealed that, optimistically, they see aflasafe production in Burundi occurring about five years down the road. This aligns with remaining needs to identify hotspots of aflatoxins within the country, identify and isolate strains for aflasafe production, register the product for use, and select (and screen) sites for manufacture.

As Burundi approaches the point of product manufacture, it will further need to have the capacity not just to support the site selection, establishment of manufacturing facility, and production of aflasafe, but also to support independent oversight of product manufacture. ISABU is a logical candidate to fill that role, so long as they are not also involved in product manufacture, either directly as the manufacturers, or indirectly through receipt of capacity building support from those manufacturing aflasafe. Institutions such as BBN would need considerable support, both in capacity building and receipt of equipment, to be able to independently evaluate levels of aflatoxins and ensure adherence with the standards for safe food they currently have in place. CNTA, while better equipped in terms of trained scientists and laboratory capacity than BBN, is not primarily responsible for the type of oversight anticipated for quality control of manufactured aflasafe.


Manufacturing Processes and Production of aflasafe


Training and capacity building will be needed to establish adequate Quality Assurance and Quality Control (QA/QC) mechanisms. The legal framework in Burundi addresses regulatory environmental compliance though does not have regulatory requirements for manufacturing facilities such as those proposed for aflasafe production.

Post-Production Storage and Distribution


Burundi’s agricultural value chain is not particularly robust, with most agricultural production subsistence based. MINAGRIE, with donor assistance has been involved in many efforts to provide training and capacity building to farmers focused on improved agricultural techniques, including post-harvest handling. Generally speaking, officials in Burundi indicated challenges maintaining or verifying quality controls on products, both at import, and in upholding internal standards. These issues are primarily due to limitations in resources and technical capacity and are indicative of struggles likely to persist in attempting to uphold the core aflasafe PEA requirements.

Use of aflasafe


While agriculture extension services are in place, their current reach is limited. Extension agents currently operate in each of Burundi’s 17 provinces, with approximately one trained service agent working in each commune92 and while there is proposal to further bolster the extension services to have a trained technician for each community, resource constraints presently pose severe limitations on the ability of these agents to consistently address all matters within their service area. Current sensitization efforts are focused primarily on building awareness among high-level government officials93 and small-holder farmers; a well-trained extension service with sufficient capacity to reach farmers is a clear area of need in the country.

MINAGRIE, with donor assistance, is overseeing efforts aimed toward improving agricultural techniques through training and capacity building. Given the current stage of aflatoxin-awareness in the country, these efforts are representative of future avenues for outreach, rather than channels to utilize for current awareness-raising campaigns.94


Food Safety Surveillance


Monitoring food safety, following the introduction of aflasafe, will likely prove a challenge given the current technical capacity in Burundi. ISABU’s current efforts to evaluate levels of aflatoxins serve as an important baseline for long-term evaluation of food safety. Over time, results from similar sampling efforts can be tagged to the introduction of aflasafe and, with effective design, determine the efficacy of measures introduced to control aflatoxins.

Organizations beyond ISABU have a clear need for similar exposure to the technological processes and sampling procedures that will enable such evaluation of the prevalence of aflatoxins and, in turn, efficacy of controls over time.




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