Pesticide Evaluation Report and Safe Use Action Plan (persuap)
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- EXECUTIVE SUMMARY
ACKNOWLEDGEMENTSThis PERUAP team of Local Consultants in each of the 11 CORAF/WECARD countries and International Environmental Compliance Consultant Alan Schroeder would like to warmly acknowledge the assistance of USAID West Africa Mission staff members for environmental guidance and advice by way of the required Initial Environmental Examination (IEE) recommendations. USAID’s West Africa Mission Regional Environmental Advisor and Africa Bureau Environmental Officer are also acknowledged for reviewing the draft document and providing valuable comments. Various contributions of other individuals and institutions—too numerous to list— who availed themselves for interviews and contributed to the accuracy and completeness of this study are acknowledged. EXECUTIVE SUMMARYIntroduction 22 CFR 216, or USAID’s Regulation 216, in section 216.3 (b)(1)(i), asserts “When a project includes assistance for procurement or use, or both, of pesticides registered for the same or similar uses by USEPA without restriction, the Initial Environmental Examination [IEE] for the project shall include a separate section evaluating the economic, social and environmental risks and benefits of the planned pesticide use to determine whether the use may result in significant environmental impact.” That ‘separate section’ referred to above has evolved into a tool named a Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP). The main purpose of this particular Pesticide Evaluation Report (PER) and Safe Use and Action Plan (SUAP) is to bring CORAF/WECARD into compliance with USAID’s environmental regulations (Title 22 of the Code of Federal Regulations (CFR), part 216, or Regulation 216) on pesticide use. Beyond compliance, this document offers best practices and helps ensure that CORAF/WECARD reduces the chances of environmental and health impacts due to pesticide training, promotion or use. USAID projects desiring to promote or use pesticides rejected by this PERSUAP analysis will need to perform an Environmental Assessment (EA) on those chemicals and their use. Background To achieve their objectives, USAID projects in West Africa may need to support the use of pesticides, as part of an Integrated Pest Management (IPM) approach to crop and livestock production. IEEs have been produced that recommend the production of this PERSUAP study in order to analyze such pesticide use, within the West Africa CORAF/WECARD countries pesticide systems. Purpose Incompliance with USAID’s Pesticide Procedures (22 CFR 216.3(b)), this 2013 Pesticide Evaluation Report and Safe Use Action Plan (PERSUAP) for the USAID/West Africa CORAF/WECARD Agriculture FTF and WASP Portfolios: Establishes the subset of pesticides (of those registered by West Africa CORAF/WECARD countries) for which support is authorized on USAID/West Africa CORAF/WECARD programs, projects and activities. Establishes requirements attendant to support for these pesticides to assure that pesticide use/support (1) embodies the principles of safer pesticide use and, (2) per USAID policy, is within an Integrated Pest Management (IPM) framework. These requirements come into effect upon approval of this PERSUAP. Scope Specifically, the following programs/projects are covered by this PERSUAP: CORAF/WECARD-Implemented Feed the Future (FTF) activities in: Benin, Burkina Faso, Côte d’Ivoire, Ghana, Liberia, Mali, Niger, Nigeria, Sénégal, Sierra Leone and Togo CORAF/WECARD-Implemented West Africa Seed Project (WASP) activities in: Benin, Burkina Faso, Ghana, Mali, Niger, Nigeria and Senegal Legal and Regulatory Standing In 2010, a PERSUAP was drafted to address the activities of CORAF/WECARD’s activities in West Africa at that time. That document is now long out of date. This 2013 West Africa CORAF/WECARDPERSUAP update replaces that 2010 document, and responds to the Conditions that request such a PERSUAP in a current USAID West Africa draft IEE. Most IEEs that cover pesticides recommended a Negative Determination (meaning that a full Environmental Assessment—EA has not been recommended to be done) with Conditions for any pesticide use. In addition to USAID’s regulatory obligations, USAID West Africa’s environmental regulations must be understood and adhered to by all USAID projects. Pesticide Definition by EPA For the purposes of this PERSUAP, the word pesticide is used, following EPA’s guidelines1, for the following: fumigants, insecticides, miticides/acaricides, nematicides, molluscicides, fungicides, antimicrobials, bactericides/biocides, microbicides/antibiotics, herbicides, rodenticides, avicides, algicides, ovicides (kill eggs), disinfectants/sanitizers and anti-fouling agents (chemicals that repel or kill things like barnacles that attach to boats). Even biological agents such as biopesticides, microbial pesticides, attractants/pheromones, repellents, defoliants, dessicants and insect growth regulators are included as pesticides. Support for Pesticide “Use” Pesticide “use” by any USAID Feed the Future project was defined and agreed upon at the outset of this PERSUAP study as including: Promotion during project training, Use on project demonstration farms, Procurement directly by project for beneficiaries or spray services, or Subsidization or financing by the project through sub-grantees or credit agreements. Pesticides rejected by this PERSUAP analysis cannot be ‘used’ for any of the above project activities, unless an Environmental Assessment (EA) is performed. That said, USAID’s manageable interests cannot include control of the procurement—by beneficiaries with their own resources—and use by beneficiaries of pesticides on their own farms (unless they are project demonstration farms), although USAID projects can and should make recommendations for the purchase and use of safer alternatives. Modern Agriculture, Quality Control Standards and Market Access USAID projects that aim to help beneficiaries capture pieces of quality foreign markets by use of volunteer Standards and Certification (S&C) systems, like GlobalGAP, Organic, FairTrade, or Scientific and Certification (S&C) systems that audit and certify export crops in West Africa CORAF/WECARD countries could limit the pesticides permitted on participant farms, in order to meet those standards as a group or cooperative. And, these S&C systems, primarily GlobalGAP, provide quality farm standards, or “Good Housekeeping for the Farm”, that should be adopted by USAID projects without other S&C systems. Pesticides Requested or Desired or Available for use by USAID West Africa CORAF/WECARD Projects This 2013 PERSUAP evaluates pesticides registered and found available in CORAF/WECARD countries so that decisions can be made when choosing, or avoiding, alternatives. It evaluates pesticides that potential project beneficiary farmers may desire and use so that recommendations can be made for safer alternatives as higher risk products are phased out. Findings: Allowed and Rejected Pesticides Upon approval of this 2013 CORAF/WECARD PERSUAP, the pesticide active ingredients (AIs) listed as “allowed” in the Tables that follow—and ONLY those AIs—may be supported with ‘use’ as defined above, by the USAID/West Africa CORAF/WECARDFTF and WASP programs/projects covered by this PERSUAP. Such support is subject to the safer use conditions summarized below and set out in detail in the SUAP, Section 4 of this PERSUAP. For reference, the right hand column in the Tables below also set out all AIs considered but rejected, along with the reasons for the rejection. Allowed pesticides containing AIs are those that passed the 12-factor analyses, particularly Factor A (EPA &West Africa CORAF/WECARD Countries or Harmonized Registration and EPA RUP Status) & Factor E (Acute/Chronic Toxicological Hazards), as analyzed and summarized in Annex 7. Synthesizing across the PER analysis, ONLY the below-listed pesticides active ingredients on the left side of this page are permitted for ‘use’ in USAID/West Africa CORAF/WECARDFTF and WASP program/project activities. 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